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HomeMy Public PortalAbout20210601plCC701-32 DOCUMENTS IN THIS PACKET INCLUDE: LETTERS FROM CITIZENS TO THE MAYOR OR CITY COUNCIL RESPONSES FROM STAFF TO LETTERS FROM CITIZENS ITEMS FROM MAYOR AND COUNCIL MEMBERS ITEMS FROM OTHER COMMITTEES AND AGENCIES ITEMS FROM CITY, COUNTY, STATE, AND REGIONAL AGENCIES Prepared for: 06/01/2021 Document dates: 05/12/2021 – 05/19/2021 Set 1 Note: Documents for every category may not have been received for packet reproduction in a given week. 1 Baumb, Nelly From:Amie Ashton <aashton@gmail.com> Sent:Monday, May 17, 2021 11:45 AM To:Council, City Subject:Item 11 - CIP, Charleston-Arastradero Corridor Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council,     Please support the Finance Committee’s recommendation to use SUMC funds so a construction contract may be  awarded immediately using current bids, combining Phases 3 and 4 (or Phases  3a and 3b) to complete the full scope of  the Charleston/Arastradero Corridor Project. I bike this area almost every day (one less car) and look forward to these  vital improvements.    This is for the safety of our kids and the further creation of community ‐ something we desperately crave after covid. We  all want to get out and enjoy the world and others again! There is nothing better than being on a bike to be able to do  so.     Thank you,    Amie Ashton  Silicon Valley Bicycle Coalition Board Chair  2 Baumb, Nelly From:Lynnie Melena <lynniemelena@gmail.com> Sent:Monday, May 17, 2021 9:03 AM To:Council, City Subject:Item 11--CIP--Charleston-Arastradero Project CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Councilmembers, As a long-time supporter of the Charleston-Arastradero project, I urge you to approve the Finance Committee’s recommendation to use SUMC funds so a construction contract may be awarded immediately using current bids, combining Phases 3 and 4 (or Phases 3a and 3b) to complete the full scope of the Charleston/Arastradero Corridor Project. The major intersections along this corridor are some of the most hazardous locations and need to be upgraded to ensure safety for bicyclists. Thank you. Lynnie Melena 3 Baumb, Nelly From:Ken Kershner <ken@triomotors.co> Sent:Monday, May 17, 2021 10:08 AM To:Council, City Subject:Item 11--Capital Improvement Fund--Charleston-Arastradero Corridor Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council,     Vision Zero priority means financial support is necessary.     Please support the Finance Committee’s recommendation to use SUMC funds so a construction contract may be  awarded immediately using current bids, combining Phases 3 and 4 (or Phases  3a and 3b) to complete the full scope of  the Charleston/Arastradero Corridor Project.     Safety is worth the money spent to make the corridor safer for pedestrians and biking.      Thank you.     Ken  ‐‐   Ken Kershner | Co-Founder & CEO Cell 650-248-9059 | Email ken@triomotors.co  Trio Motors | Palo Alto     4 Baumb, Nelly From:Elke MacGregor <bemacgregor@earthlink.net> Sent:Monday, May 17, 2021 8:02 AM To:Council, City Subject:Charleston- Arastradero & El Camino bike crossing CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Esteemed Council members    Please support the finance committee’s recommendation to use SUMC funds to complete the construction of phases  three and four of the Charleston Arastradero Corridor project. We really look forward to the improvements for bicyclists  especially at the El Camino crossing    Elke MacGregor and family   650‐207‐3321  (sent en route)    Begin forwarded message:  From: Elke MacGregor <bemacgregor@earthlink.net>  Date: May 6, 2021 at 6:25:05 AM PDT  To: city.council@cityofpaloalto.org  Subject: Fwd: Charleston‐ Arastradero & El Camino bike crossing     Esteemed council members    We would like to reiterate how important we think it is to repair and upgrade the El Camino Crossing  portion of the Charleston Arastradero bike  improvements. This section of that Corredor is dangerous  and in extreme need of upgrades (please see previous emails below).    Elke   650‐207‐3321  (sent en route)    Begin forwarded message:  From: Elke MacGregor <bemacgregor@earthlink.net>  Date: March 21, 2021 at 10:42:42 PM PDT  To: city.council@cityofpaloalto.org  Subject: Re: Charleston‐ Arastradero & El Camino bike crossing  Esteemed council members    We would like to strongly support the completion of the Charleston Arastradero  improvements.   Crossing El Camino on a bike is scary for seasoned cyclists and  dangerous for children.  There are no bike lanes or protection and the road is potholed  5 and pitted.  We really look forward to this essential safety measure on a busy bicycle  route.    Elke MacGregor and family  650‐207‐3321  (sent en route)      On Jan 3, 2021, at 9:34 PM, Elke MacGregor  <bemacgregor@earthlink.net> wrote:    Esteemed council members     We applaud all of the work that has been done on the bike boulevards  and lanes in Palo Alto.  We are a family of avid cyclists and really  appreciate these.    The Charleston Arastradero bike lanes and safety measures are  especially wonderful as we live close by and ride this road weekly.  We  hope that the El Camino crossing will be addressed soon as well.  This  portion of Charleston‐Arastradero has no bike lanes or safely measures  and the asphalt has large linear potholes. The combination of these  factors makes this an unnerving cyclist crossing.    With appreciation for all of the  bike friendly measures that you have  implemented,    Elke & Bruce MacGregor  55 Roosevelt Circle  650‐207‐3321    On Feb 23, 2020, at 1:19 PM, Elke MacGregor  <bemacgregor@earthlink.net> wrote:    Esteemed council members    Our family really appreciates the effort and thought  that you and the community have put into Palo Alto’s  bike transportation infrastructure.  Our children have  utilized the safe bike routes to the 3 schools in our  neighborhood as well as the bike boulevards to  downtown and park areas.   In addition, all four of us  travel along Charleston Arastradero multiple times per  week for bike rides in the foothills.  These routes as well  as the prioritization of environmentally friendly  6 bike/walk transportation have changed our lives  immeasurably for the better.      We are proud to be a part of a community that teaches  our children and encourages our adults to enjoy their  surroundings from the vantage of foot power.  Please  continue to support this vision.    Elke & Bruce MacGregor  55 Roosevelt Circle,   Palo Alto  7 Baumb, Nelly From:Marianne Cumella Reddan <mcreddan@stanford.edu> Sent:Monday, May 17, 2021 9:05 AM To:Council, City Subject:Palo Alto Junior Museum and Zoo CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Hi City Council,    Thank you for reducing your intended admission fee increase from $18 to $10 for the Palo Alto Junior Museum and Zoo. While this is great news, many of us recognize that $10 can still be a burden for many families. Please instead implement a "pay what you can" option with a suggested $10 admission fee.     Low income families have already been set back by over a year of lost education due to the pandemic, and the educational opportunities accessible to low income families are insufficient beyond the pandemic. The very least we can do is keep public education institutions available to those who do not enjoy the privilege of a financially comfortable life.     If my local zoo was not free on Wednesdays, maybe I would not have been so interested in animals and biology as a child, and maybe I would never have thought it was possible to become a scientist.    Financial barriers are what create and reinforce systematic oppression. We have the ability to lessen this oppression with this one small step.    Thank You,  Dr. Marianne Reddan  8 Baumb, Nelly From:Kevin Ma <kevinma.sd@gmail.com> Sent:Sunday, May 16, 2021 11:56 PM To:Council, City Subject:Comment on Item 11: Charleston-Arastradero Corridor Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council,     Please support the Finance Committee’s recommendation to use SUMC funds on the Charleston‐Arastradero Corridor  Project so a construction contract may be awarded immediately using current bids. Doing so can complete the full scope  of the project much faster, a project necessary to provide safety on a heavily trafficked bike corridor. As the SCAP  update has shown, we need to be taking strong measures to decarbonize our transportation sector, and providing  physical improvements in bike and pedestrian infrastructure is key to get people to not use their cars. This should not be  delayed further.     Sincerely,  Kevin Ma  9 Baumb, Nelly From:David Coale <david@evcl.com> Sent:Sunday, May 16, 2021 8:42 PM To:Council, City Subject:Item 11--Capital Improvement Fund--Charleston-Arastradero Corridor Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Mayor and City Council,     Please support Finance Committee’s recommendation to use SUMC funds so a construction contract may be awarded  immediately using current bids, combining Phases 3 and 4 (or Phases  3a and 3b) to complete the full scope of the  Charleston/Arastradero Corridor Project. This project has been delayed long enough.    Besides the obvious safety issue, this is also how the council should continue to close the 8% gap on our 80 X 30 goal of  reducing GHGs in the City.  We must make our community more bike and pedestrian friendly so that our residents will  choose other means to get around then the automobile.    If the City can choose to build an unnecessary parking garage in the middle of a pandemic that increase auto use and  thereby reduces safety in our community while increasing our GHG emissions, against the top priorities of the council, I  hope you can now see your way to finishing up this important bike and pedestrian corridor that will improve safety,  decrease GHG and will be cheaper than putting this off to a later date while fulling some of the City’s top priorities.     Thank you for your consideration,    Sincerely,    David Coale        10 Baumb, Nelly From:Arnout Boelens <a.m.p.boelens@gmail.com> Sent:Sunday, May 16, 2021 8:16 PM To:Council, City Subject:Item 11--Capital Improvement Fund--Charleston-Arastradero Corridor Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council members,    Please support the Finance Committee’s recommendation to use SUMC funds to pay for the Charleston/Arastradero  Corridor Project Phase 3b. This way a construction contract may be awarded immediately using current bids, combining  Phases 3 and 4 (or Phases  3a and 3b) to complete the full scope of the project.     Combining both phases means that there will be no further delays, and that all the hazardous locations along the  corridor will be fixed as soon as possible. In addition, completing  both phases means that when the South Palo Alto  Bikeways Project is completed, Fabian Way will properly connect to Charleston Road and be part of a complete bicycle  network.    Kind regards,    Nicole, Arnout, & Ava Zoeller Boelens  11 Baumb, Nelly From:Melanie Grondel <mel.grondel@gmail.com> Sent:Sunday, May 16, 2021 6:29 PM To:Council, City Cc:Melanie Grondel Subject:Cutting Community Services - Community Gardens CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Major Dubois and City Council Members,     Especially in the light of the recent talks of the need to increase the housing density in the City of Palo Alto to  avoid  conflict and crisis in relation to housing development requirements by the State of California, it is hardly the  moment to take away the Community Gardens and community services. With large numbers of small and micro units  under consideration, Community Gardens and Community services are especially important to maintain the livability of  our city, the quality Palo Alto is most famous for.     The community Gardens are one of the treasures of Palo Alto and serve as a place for community par excellence. It is  interesting open space and a place where you meet interesting people, even just on a visit. It is the first place my  husband and I, newcomers then, made a connection to friendships that last to this very day. That was when we arrived  in Palo Alto in 1970.  It still is an excellent place to connect to the Community,  and to  environmentally oriented people and organizations in  particular. This is a place where the new newcomers can make the connection to the Palo Alto community in all its many  forms with the Library complex nearby.     Connection is something we hear constantly in the housing discussions with a new generation that seeks to be part of  our community but finds it difficult to do so, in part due to lack of housing and social opportunity.      Let's welcome new neighbors in one of the many ways that are open to us. The Services, Community Gardens, Libraries,  Parks, Children's Theater, the Children's Museum and Zoo,  are the reason we have a great Community here in Palo Alto  and will have in the future.    Unless .... we loose these treasures that are impossible to restart, once lost. Think of the investment of thousands of  unpaid volunteer hours over the last fifty years I speak of, and even further back. That investment is an indelible part of  this Community over and beyond the financial contributions by the City Government.  That is why these services are  considered our treasures.    When City Manager Shikada could not envision more efficient ways to cover our current budget deficit than to take  away these treasures in exchange of only modest relief to his budget problems, Vice Mayor Pat Burt suggested the  possibility of looking into some credit instruments to cover this temporary financial setback resulting from the  consequences of the Pandemic, until the vibrant economy roars back. Palo Alto is at the heart of a tech boom and will be  soon at the heart of a boom in Life Sciences as well.    Manager Shikada could envision only an exchange of cutting one service in favor of saving another City service. Even  essential services such as Fire and maintenance of other essential services, were not spared this zero sum game.     Residents were asked to fill out a survey with 10 options to cut. In this survey I could fill out only one preference and  one way to offset it, by opting for a temporary surcharge to my electrical bill, before the survey folded into a stuck mess.  I feel that represents the stuck manner in which the financing of our city's treasures is being approached.    12 Palo Altans are willing to help retain what we are proud of and we expect the City Council to come up with additional  options such as some form of temporary borrowing, to keep these services afloat until the returning vibrant economy  puts sufficient funds in the City coffers again.    With these treasured Services   intact, we can welcome the   new neighbors and all together we share, enjoy and pay for our Community Services including the Community Gardens.    With that concept in mind, we can start working on housing development in currently underused commercial  spaces.  These parcels need to provide enough space to accomodate housing development at the various income levels,  consisting of standard size apartments for a family, not  micro units, room for fresh open air,  a park or other green  space, a safe bike path to schools, one parking space per unit so the family has access to competitively priced shopping  and to "Foothill Park" and other regional outdoors not available by our limited public transit.      These larger pieces of land can be found at underused commercial, county and other government properties.     These are the longterm problems I hope the City Council will focus on primarily, once this temporary budget crisis has  been resolved in an imaginative combination of new revenue or credit instruments, found efficiencies in City  administration, and a modest contribution by Palo Alto residents.     This is the all‐hands on‐deck solution in order to not cut our treasured Community Services any further than the cuts  that were made already last year in the name of the Emergency of the Pandemic.    Thank you for your consideration,  Melanie Grondel  Palo Alto ‐ College Terrace     13 Baumb, Nelly From:Jennifer Antonow <jennifer.antonow@gmail.com> Sent:Sunday, May 16, 2021 5:42 PM To:Council, City Subject:Please restore support for the Children's Theatre CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council members,      Our family has been involved with the Palo Alto Children's Theatre, both as donors and participants in their programs,  over many years. To say it is a gem in our community is an understatement. The quality of the instructors and programs  is second to none, and it's places like PACT that make up our children's fondest memories of their hometown. We are  proud to live in a community that values arts education, sets high expectations for our kids, and nurtures their interests.     While we know budgets are tight given the pandemic, it would be short‐sighted not to fight to keep this operation alive.  Like other community members, we have pitched in to help close the gap and we hope the City will as well. Please  restore support for these vital programs that light kids up every day.      Best regards,  Jennifer and Eric Antonow  14 Baumb, Nelly From:forest light <forest129@yahoo.com> Sent:Sunday, May 16, 2021 4:17 PM To:Council, City Subject:City Council Meeting May 17 2021, Agenda Item 11: Continued Discussion of the Fiscal Year 2022 Budget: Capital Improvement Fund--Charleston-Arastradero Corridor Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Mayor DuBois and City Council Members,    Please support Finance Committee’s recommendation to use SUMC funds so a construction contract may be awarded immediately using current bids, combining Phases 3 and 4 (or Phases 3a and 3b) to complete the full scope of the Charleston/Arastradero Corridor Project.     Some of us, in this end of town all too painfully remember the events of January 28, 2003 when one of our south-end children, a 10 year old school girl, was struck and killed and her friend had her leg broken by a hit- and-run high school student speeding on her way to school. And many of us also remember our grief and disbelieving shock at the aftermath. One such incident was more than enough to make the points that: -Yes, it CAN happen -One such incident is far too many -It could easily happened to our children, your children — any of our community’s children and families. -Structural approaches to creating safe transit corridors are our only realistic hope of controlling traffic and making our transit corridors safe for our children — and everyone else. -We all need to do our share, and prioritize, and make sacrifices and do what it takes to keep our children, our community safe. The most hazardous of the several hazardous intersections on the school commute corridor, are Middlefield/Charleston and El Camino Real/C-A. At El Camino, the bike lanes disappear completely on the eastbound and westbound approaches to the eight-lane state highway intersection. It is clear that safety concerns should be heavily re-emphasized here since the most likely victims of such hazards are, in this instance, the city’s schoolchildren. Please keep in mind that this Infrastructure project has been ongoing for 20 years(!) and aligns with the approved goals, policies and programs of the 2012 Bicycle & Pedestrian Transportation Plan, the 2017 Comprehensive Plan Transportation Element and the 2017 Sustainability & Climate Change Action Plan which prioritize safety, sustainability and healthy, active alternatives to driving solo. By approving the the full completion of the Charleston/Arastradero Corridor Project now, we lock in the current bid rather than face what will predictably be a much higher cost later in order to finish Phase 4 in the future — which risks that the project will never be completed. 15 Our thanks to the Finance Committee for finding a way to enable the project to be finished in its entirety at this time, using the current bid. Thank you for your support, Michael & Judith Maurier Fairmede Ave. 16 Baumb, Nelly From:NTB <aarmatt@gmail.com> Sent:Sunday, May 16, 2021 3:36 PM To:Council, City Subject:Item 11--Capital Improvement Fund--Charleston-Arastradero Corridor Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Mayor DuBois and City Council Members, I am writing to ask you to please support the Finance Committee’s recommendation to use SUMC funds so a construction contract may be awarded immediately using current bids, combining Phases 3 and 4 (or Phases 3a and 3b) to complete the full scope of the Charleston/Arastradero Corridor Project. My reasons for requesting this action: 1. By approving NOW the full completion of the Charleston/Arastradero Corridor Project, you lock in the current bid rather than risk what will definitely be a much higher bid later in order to finish Phase 4 in the future. Such a delay, requiring a greater outlay of capital, risks that the project will end up never being completed. 2. The Council has emphasized safety for school students and bicycle riders. Safety of students, bicyclists, and drivers has been the whole modus operandi of the C/A Corridor Project from its very inception.....20 years ago! Thank you to the Finance Committee for finding a way to enable the project to be finished in its entirety at this time, using the current bid. What is needed now is the support of the City Council to make this happen. Twenty years is a mighty long time for a safety project to 17 be realized. Let's get it done.....now! Thank you, in advance, for your support. Nina Bell Los Palos Ave. 18 Baumb, Nelly From:Sonya Bradski <sonyangary@gmail.com> Sent:Sunday, May 16, 2021 2:28 PM To:Council, City Subject:Item 11--Capital Improvement Fund--Charleston-Arastradero Corridor Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Dear City Council Members,     Please support Finance Committee’s recommendation to use SUMC funds so a construction contract may be awarded  immediately using current bids, combining Phases 3 and 4 (or Phases  3a and 3b) to complete the full scope of the  Charleston/Arastradero Corridor Project.     Here are excerpts from the note I sent previously explaining why I support this project.      Thank you.     Sonya Bradski     I ride my bike on Charleston-Arastradero every single day. I have been supporting this project since my oldest daughter (who is now a college graduate) was in preschool. My youngest child recently graduated from Gunn High School, so my children will never benefit from the bike safety improvements the city promised years and years ago. My husband and I still need them. We mostly bike for local trips, and Charleston Arastradero is the main road that connects our neighborhood to the rest of the city.     I have spoken at many City Council meetings and been to so many community meetings over many years on this. When is it going to be completely done?     19 Two sections have no bike lanes:     1. Charleston-Arastradero leading up to at El Camino Real both directions. It is hard, even for a strong rider, to merge with traffic here. The bike lanes should go all the way to and through the intersection. The pork chop islands need to go.. We have to cross seven state highway lanes here. That is not easy. Drivers can be impatient and rude when you take a lane there. Why do drivers get two continuous through lanes and a turning lane at this intersection, but bicyclists get no lane at all?    2. On Charleston, the bike lanes disappear between Fabian and San Antonio. Both of those intersections are very difficult to ride, though I shop down that way. My husband used to bike to work at a start-up in that area. He had some very scary experiences near San Antonio.     I have friends who have been hit by cars on this road. Why delay this again? Please finish this project this year. This is a school route. What are we waiting for?    Thank you.    Sincerely,    Sonya Bradski       To help protect your privacy, Microsoft Office preautomatic download of this picture from the Intern   Virus-free. www.avg.com   [§] 20 Baumb, Nelly From:Jeffrey Lu <jeffreylu6@gmail.com> Sent:Sunday, May 16, 2021 2:21 PM To:Council, City Subject:comment on Item 11 (Capital Improvement Fund, Charleston-Arastradero project) CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Council Members,    I urge you to support the Finance Committee’s recommendation to use SUMC funds so a construction contract may be  awarded immediately using current bids on the Charleston Arastradero Corridor Project. Using SUMC funds will allow us  to complete the Charleston Arastradero Project without further delay, another round of bidding, and potential future  cost increases.    Safety improvements on Charleston Arastradero will greatly benefit all road users in Palo Alto, particularly when folks  are getting around on foot or bicycle. I am glad the city has already made efforts to improve the corridor (I already feel  less stressed out biking near Mitchell Park!), and this last phase of the project will help close remaining safety gaps.     Thank you for your consideration.    Jeffrey Lu  Midtown  21 Baumb, Nelly From:Amy Kacher <amyewardwell@yahoo.com> Sent:Sunday, May 16, 2021 1:46 PM To:Council, City Subject:Please restore Children’s Theater funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear City Council    I ask that you restore the money that was cut from the theater programming so they can put on more than 1‐2 shows  per year.  At this moment in time particularly, we must not cut programming for kids. The Arts are often overlooked in  this town of STEM focused people.    Please protect this theater so we can provide much needed outlet for our kids to engage and grow that is NOT on a  screen.    Sincerely  Amy Kacher    Sent from my iPhone  22 Baumb, Nelly From:pennyellson12@gmail.com Sent:Sunday, May 16, 2021 1:08 PM To:Council, City Subject:Item 11: Capital Improvement Fund --Charleston Arastradero Plan Funding CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Honorable City Council Members,    I was glad to see the staff memo attached to Item 11 today.  (I almost missed it!)    I’m writing to ask you to please support Finance Committee’s recommendation to use SUMC funds so a construction  contract may be awarded immediately using current bids, combining Phases 3 and 4 (or Phases 3a and 3b) to  complete the full scope of the Charleston/Arastradero Corridor Project.    Some of you know that many of my personal friends and family have been hit by cars on this street while walking, biking  and driving.  I walk, drive and bike that corridor every single day. It was the school route my children used every single  day through their K‐12 PAUSD experience. It is the primary route from my neighborhood to the rest of the community  and region, as is true for other neighborhoods in this part of town.  The overall collision history and my personal  experience on the corridor have given me a sense of urgency about getting this done.  This project is well overdue, and I  am grateful to see that Finance Committee has identified a way to fund it expeditiously and make the corridor operate  more safely and efficiently for people who drive, bike and walk.       This is the mitigation plan for the aggregate traffic impacts of nearly a thousand units of housing in multiple higher  density projects (including many very affordable units for low income people), CJL, Elks Club, SRP expansion, Treehouse,  and Challenger School—all completed many years ago now.  Corridor neighborhoods supported that development with  the understanding that promised traffic mitigations would be delivered by 2007.  In 2021, we are still waiting.      Please approve this use of SUMC funds and make this right. It’s time.    Thank you for considering my comments,    Sincerely,    Penny Ellson          To help protect your privacy, Microsoft Office preautomatic download of this picture from the Intern   Virus-free. www.avg.com   [§] 23 Baumb, Nelly From:Audrey Gold <audreygold@gmail.com> Sent:Sunday, May 16, 2021 12:45 PM To:Council, City Subject:Item 11: Please fund the C/A Corridor Project CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.        Dear City Council,     I ask that you URGENTLY support the Finance Committee’s recommendation to use SUMC funds in order that a  construction contract may be awarded immediately using current bids, combining Phases 3 and 4 (or Phases  3a and 3b)  to complete the full scope of the Charleston/Arastradero Corridor Project.     This route is used by many students that bike to both Fletcher and Gunn schools and will greatly improve their  safety.   Car traffic on Arastradero is a problem and the anticipated change of the high school start time to 9:00 am is  likely going to make the problem worse.   We really need to encourage cyclists and giving them safer bike lanes is key.    This project has been delayed for years.  Please do the right thing and fund it now.     Regards,  Audrey Gold  cyclist and parent of teen cyclists      24 Baumb, Nelly From:Eric Smith <eric.of.smith@gmail.com> Sent:Sunday, May 16, 2021 12:42 PM To:Council, City Subject:Please make it a priority to restore the Children's Theatre's budget in full CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear City Council,  Please make it a priority to restore the Children's Theatre's budget in full.  Our children really love this theatre and it is a  unique resource for our city, and really the county at large.  We’ve been patrons of this facility for nearly ten years and  we would love to see them get back to delivering high quality performing arts programs and productions to the  community.  Sincerely,  Eric Smith & Polina Sokolova  102 Middlefield Rd, Palo Alto, CA 94301  25 Baumb, Nelly From:Leslie Braun <lesliehbraun@gmail.com> Sent:Sunday, May 16, 2021 8:32 AM To:Council, City Subject:Palo Alto Children's Theatre CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Members of the City Council,   I was pleased to see that you have decided not to further cut the funding  for the Children's Theater. However, the  $850,000 that was cut from the theatre's budget last year has not been restored. I would encourage you to  use a  portion of the Covid funding to restore as much of these funds as possible.  Our children need all the support that we can give them.      Leslie Braun  **Please note this is my new email address.  lesliehbraun@gmail.com. **  26 Baumb, Nelly From:Rajan Perkash <rperkash@gmail.com> Sent:Sunday, May 16, 2021 7:58 AM To:Council, City Subject:Palo Alto Childten’s Theatre CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Please restore full pre‐COVID funding to the Palo Alto Children’s Theatre.  It is a valuable community resource and my  daughter has had ongoing very positive experiences attending camps, performing, and working with the programs there.    Sincerely,    Rajan Perkash    Sent from my IPhone  27 Baumb, Nelly From:Bartleby St Clair <rbartstc@yahoo.com> Sent:Saturday, May 15, 2021 11:10 PM To:Council, City Subject:Restoring Funds to Palo Alto Children's Theatre CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  I am writing to you to ask that you support funding for the Palo Alto Children’s Theatre.  This critical community  organization experienced a reduction of over $800k in city funding last year and as we look to a post‐Covid world they  will not be able to serve the community with the wonderful programming that they offer if funding is not restored to  their prior levels.      Can you please prioritize funding for the important community arts organization providing such terrific opportunities  and offerings for our young residents?    Thank you,    Bartleby St Clair  Resident of Palo Alto  585 Washington Avenue  rbartstc@yahoo.com  917‐653‐6073      28 Baumb, Nelly From:Lesley Rappaport <lrport1@yahoo.com> Sent:Saturday, May 15, 2021 7:14 PM To:Council, City Subject:PA Children's Theater-restore funding! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear Council Members,  I no longer have children to participate in the theatre, however, I see this organization as Necessary to the culture of our  city and the well‐being of our children and families.  The 45% cut in funding has crippled the theatre's ability to perform  it's mission and must be restored!  The PACT is a treasure and should be supported!  Thank you,  Lesley Rappaport  Edgewood Drive  Palo Alto  Sent from my iPhone  29 Baumb, Nelly From:Esther Rubin <emrubin36@gmail.com> Sent:Saturday, May 15, 2021 1:48 PM To:Council, City Subject:Junior Museum CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Here I am again, letter number 3, advocating on behalf of children and families in Palo Alto.  The Junior Museum has  been a focal point in our family for decades.  First when our own children attended and now we enjoy it again with our  grandson.  Before the covid closures, my grandson and I would spend at least 2‐3 mornings each month at the museum  on Cubberly.  As my grandson matured, I loved watching him rediscover all the interactive displays and learning more  each time.  We became members of the museum so that he could come early on the weekends and get to know the  animals with Lee as his guide.    We have mourned the temporary loss of the museum this past year, and are appalled at the exorbitant fee fo $18/pp  that has been proposed.  Thank you, council members for bringing down the fee to $10.  I’m not sure if that is per family  as it was before or will be per person.  I hope that you will make it per family so that more children from diverse  backgrounds will be able to afford to attend on a regular basis.  The museum should be as it was before, a place as  familiar as Rinconada Park or the Children’s Library and Theater.  The experiences that children have had in these places  over decades, because they have been so accessible to the wider public, enrich the children who then bring their gained  knowledge, curiosity, and inspiration to their learning which continues to enrich classrooms, research projects, and  possibly vocational choices.    What makes Palo Alto special and why we are willing to pay so much to live here is because of all of these enriching  opportunities and institutions.  Other cities do not have these resources, and why would we want our city to lower  rather than elevate what we provide for our children.  Please don’t view the Jr Museum as a cash cow, see it for it’s  original purpose......enriching children by the availability of experiencing the beauty of nature and science right in their  own home town.    Thank you,  Esther Rubin  Greer Rd.    Sent from my iPad  30 Baumb, Nelly From:Robin Metz <robinmetz@gmail.com> Sent:Saturday, May 15, 2021 1:47 PM To:Council, City Subject:Children’s Theater CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Please fund the children’s theater. It’s been an important part of our children’s education and should remain for the  next generation of Palo Alto children.      Robin Metz  3201 Kipling Street   31 Baumb, Nelly From:Esther Rubin <emrubin36@gmail.com> Sent:Saturday, May 15, 2021 1:32 PM To:Council, City Subject:Children’s Library CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    I greatly appreciate that you are reconsidering keeping the Children’s Library open.  This Library is an historical treasure  and a unique environment for inspiring the love of reading and books to children.  Not only have my own children  benefited from using the Children’s Library, but as a teacher I frequently used books and resources from the library,  brought my kindergarteners on field trips there, and in recent years I brought my grandson to the library weekly for  storytime until the covid shutdown.  As I checked out his weekly book assortment, he would look at the curio cabinets  filled with other children’s LEGO creations and ask if he could come there to do that, too.  I promised him that when he  would be old enough I would bring him to the library to participate.  We always had snack and a rousing game of hide  and seek in the garden after storytime.  So many memories have been made here and I hope that as covid is more  controlled we will have more enriching experiences there and build more lifetime memories.  Thank you for your consideration,  Esther Rubin  Greer Rd.    Sent from my iPad  32 Baumb, Nelly From:Luce, Gwen <GLuce@cbnorcal.com> Sent:Saturday, May 15, 2021 12:10 PM To:Council, City Subject:Children’s Theatre CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Please restore funding cuts!  Sincerely,  Gwen Luce    Gwen Luce  Coldwell Banker Realty  650‐224‐3670  gluce@cbnorcal.com  www.gwenluce.com  CalRE 00879652  Sent from my iPhone  *Wire Fraud is Real*.  Before wiring any money, call the intended recipient at a number you know is valid to confirm the  instructions. Additionally, please note that the sender does not have authority to bind a party to a real estate contract  via written or verbal communication.  33 Baumb, Nelly From:Teresa Luna <teresasmo2003@yahoo.com> Sent:Saturday, May 15, 2021 11:46 AM To:Council, City Subject:Please restore the childesn’s CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear Palo Alto City Council,    This email serves as a request to preserve and restore the Palo Alto Children’s theater.  I attend performances the  children perform at the theater pre and hopefully post COVID. If you need to increase ticket prices to restore the  theater, or ask for donations please do so.  You will be surprised how many residences and former residences will  donate.    This theater is an opportunity for the children of Palo Alto to practice a craft in the arts. Not only will these children  develop an artistic craft, but they will continue to learn to be innovative, learn how to speak in front of an audience.  The  opportunity to entertain in front of an audience and tell a story is unimaginable for a small child growing up in Palo Alto.    The Palo Alto children’s theater is a historical landmark for the city of Palo Alto. As a child growing up in Palo Alto, I  watched my siblings perform.  What an amazing experience as a child to learn and practice lines at home and perform  on stage. I participated in puppetry at the children’s theater and performed to an audience.  This helped me come out of  my shell as a shy child to overcome the fear of performing in front of an audience.    By closing the children’s theater will be a loss to the community and development for children in the arts.    Sincerely,  Teresa Ortiz‐Luna      Sent from my iPad  34 Baumb, Nelly From:Esther Rubin <emrubin36@gmail.com> Sent:Saturday, May 15, 2021 11:34 AM To:Council, City Subject:Restore funding to Children’s Theater CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    I am heartened that the council is considering the issue of restoring funding for the Children’s Theater and hope that it  will be approved.  Palo Alto cannot let it’s kids down whether it is those who participate in the productions or those that  enjoy being in the audience.  This is one of the venerable programs that make Palo Alto a stand out city.  Thank you,  Esther Rubin  Greer Rd    Sent from my iPad  35 Baumb, Nelly From:Mary Holzer <mbholzer@gmail.com> Sent:Saturday, May 15, 2021 4:53 AM To:Council, City Cc:Kwan, Karen Subject:Budget cuts for Arts Organizations CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Dear Members of the Palo Alto City Council,    I was extremely happy to hear that the Finance Committee has decided to restore funding for the Palo Alto Art Center,  Libraries and other Community Services. And FYI, my responses to the Budget Priorities survey, including comments, are  included below.    The importance to the Palo Alto Community of the Arts and Activities organizations cannot be understated. Being able  to resume participation in the activities provided by the various groups ‐ Art Center, Children’s Theatre, Sports, Libraries  . . . etc. is one of the things that has been a bright light at the end of this pandemic tunnel.  It would be devastating to  the community if they were to no longer exist, or only exist as pale shadows of former programs.      Regards,    Mary Holzer       36         2022. Pa1o Alto Budget Priorities 2022 Palo Alto Budget Priorities 15 days left before deadline Introduction Feedback Your Response Outcome * OpenGov will share your response with the City of Palo Alto staff. Do you also want your response shown on this website? 0 Yes -show it with my name Sign In and be yourself Sign In and let others know who you are and what you think. You can sign In now or after you submit your response. You'll be able to read your response on this website and change ,t ,f you change your mind. O_llead_mc;,r,:_~_2 Yes -show it w ithout my name No -just show it without my name to staff • required * Please prioritize the following Citywide Service Areas. Item Up Down Remove Community/Library Services Pia nnlnir/Transportatlon Publlc Safety Stnt91lc Support A A A A X .., X .., X .., X Proposed reductions for Council consideration are below. From the list of FY 2022 Proposed Budget reductions, please prioritize up to ten (10) proposal(s) that are the most important to restore. Rank #1 is the highest priority service to be restored. Item Reduce Arts Center Operating Hours & Programming and Increase Fees Reduce Children's Theatre Opentlons and Production Staffing Reduce Teen Center Opentlons and Use the Think Fund/Bryant Street Gange Fund Ellmlnate Cubberley Artist Studio Administration Staffing Add Funding for 2021 Counell Priority: Climate Change Protection and Adaptation Reduce Cubberley Theater Opentlons Staffing Reduce Sports and Recreation Programming and Increase Fees Close Nelshborhood Libraries and Maintain Distribution Services Reduce Crossing Guard Services 50% Up Down Remove "' .., )C "' V )C "' V )C "' V )C "' V )C "' V )C "' V )C "' V )C "' V )C 37       If you could balance the budget through alternative funding sources, how would you rank the following funding sources? Funds would be used to provide City services such as libraries, community services, and public safety. Rank one (1) is the highest priority for use/pursuit. Item Up Down Remove Establish a New Revenue (requires voter approval; e.g. a business tax or a charge on cu•tomc,r 11tlllty blll$) Reduce City Reserves by 50% Advance the 2nd Year American Rescue Program Act (ARPA) Funding set aside for FY 2022-23 In FY 2021·22 Pick your next priority, if you have one. Reduce City Reservu by 65% Reduce City Reserves by 10% Increase an Existing Tax (requires voter approval) Reduce City Reserws by 25% • required Please share any additional comments on the 2022 Proposed Budgets. V IC ,. V IC ,.. V IC The extensive activity shut downs and school closures has inflicted much stress and isolation on the members of our community. Being able to interact again with friends and members of the arts, music, theatre, sports etc. communities will go a long way to help restore the fabric of life in Palo Alto. The great activities and programs that Palo Alto has for residents -both children and adults -should be top of the funding priority list. These intangibles are what make life worth living. The city should be doing everything it can and exploring every avenue possible to provide funding for the arts, music, and theatre, including business taxes, and even asking for donations from wealthy business owners and residents. Shredding the things that feed the soul will just make things worse. 38 Baumb, Nelly From:Fletcher Middle School PTA <fletchermiddleschoolpta@gmail.com> Sent:Friday, May 14, 2021 8:12 PM To:Council, City Cc:Rachel Gibson; Jennifer Silva Subject:Crossing guards are imperative for child safety CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Office of the City Mayor and City Council  250 Hamilton Avenue  Palo Alto, CA 94301    Dear Honorable City Council Members,    We are deeply concerned about any reductions in the budget to fund crossing guards in Palo Alto, and any reduction in crossing guard services. We are particularly concerned about losing that safety mechanism for our most vulnerable pedestrians and cyclists at a time when:      bell schedules are changing for secondary schools,  putting walking and cycling students on our City streets at later morning and afternoon times than in the past;      our whole community of cyclists, pedestrians, and drivers  will be resuming school-time commute patterns after nearly a year and a half of significantly fewer commuters;      and less than two years after our community experienced  the devastating death of a PAUSD student while biking.    We urge you to retain full funding for crossing guards. This is imperative for child safety.    Regards,  Fletcher PTA Executive Board    39 Baumb, Nelly From:Virginia Tincher <vatincher@gmail.com> Sent:Friday, May 14, 2021 3:24 PM To:Council, City Subject:Thank you and support for a $10 Junior Museum and Zoo entry fee CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Hi,     As a member of the Friends of the Palo Alto Junior Museum and Zoo I extend my thanks to the Council Finance Committee for proposing a $10 entry fee to the new JMZ and fully support and encourage the full council to adopt the Finance committee’s recommendation at the City Council Meeting on Monday, May 17th.    Regards,    Virginia Van Kuran  879 Garland Drive  Palo Alto, CA 94303    40 Baumb, Nelly From:Paula Maurano <pgmaurano@gmail.com> Sent:Friday, May 14, 2021 7:03 AM To:Council, City Subject:Preserve the public gardens CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Please preserve the public gardens in Palo Alto.  They are a valuable addition to the community and provide a much  needed source of sustainable organic fruits and vegetables.  Much of what is raised in these gardens is spread  throughout the community via donations.  These gardens provide the only available community based source of food in  the area.  You should be establishing more public gardens all over the City as demand for access to them is  overwheming.  If you fill in all the remaining open areas in Palo Alto the quality of life will continue to decrease.    41 Baumb, Nelly From:Judy Hyrne <jhyrne@atriumcapital.com> Sent:Thursday, May 13, 2021 7:17 PM To:Council, City Subject:Community Gardens CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Palo Alto City Council,  I heard that Palo Alto may be considering cuts for community gardens. I wanted to weigh in and let you know how  appreciative I have been of the locally grown organic produce from the community garden at Eleanor Pardee Park.  A  friend who lives in Palo Alto loves to garden there and is generous to share her bounty with me.    In the March 2021 AARP Bulletin there was an article based on the research done at University of Washington  encouraging rethinking neighborhood environments to facilitate outdoor activities, particularly for older  people.  Community gardens provide so many enriching benefits including open green spaces, meaningful activity and  healthy eating.    I hope you continue to support them!    Judy Hyrne  865 Hobart Street  Menlo Park    42 Baumb, Nelly From:Anne Hochberg <anne.hochberg@gmail.com> Sent:Thursday, May 13, 2021 4:02 PM To:Council, City Subject:Please support the Palo Alto Art Center CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  May 13, 2021    Dear Members of the City Council:    I write to urge support for the Palo Alto Art Center in the city’s FY2022 budget. To further reduce funding for PAAC programs beyond last year’s drastic cuts would result in terrible losses for the community.    PAAC is a beloved and vital resource for seniors, teens, school-age kids, and families. It provides high quality, meaningful engagement in the arts for everyone who walks through its doors. Its gallery exhibits reliably inform, challenge and delight–-not just the top-notch curated displays of professionals' works, but also the thrilling creations of schoolkids that enliven the hallways and encourage young artists to explore new ways of seeing and responding to the world.     Art brings people together. If there ever was a time to support programs that help people understand and appreciate cultural diversity, it’s now. It’s also very much the right time to help people–-especially children–-find ways to connect with others and strengthen their capacity to express themselves.    I am not a Palo Alto resident, but for years I have been a frequent visitor to Art Center exhibitions, a volunteer for the community printmaking space PAAC operates at Cubberley, and a student in adult painting and printmaking classes.     I hope you will find a way to provide funding to keep the Art Center programs strong and effective for the many members of your community who enjoy, learn, grow and heal through them.    Sincerely,    Anne McG. Hochberg  113 Princeton Rd  Menlo Park, CA 94025    43 Baumb, Nelly From:Victor Zilinskas <vzilinskas@sbcglobal.net> Sent:Thursday, May 13, 2021 10:52 AM To:Council, City Subject:Do Not Defund the Police and Fire Department CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council, Public safety should be the number one budget priority for the City of Palo Alto. We need police patrolling the streets, and available for emergencies. The fire department is essential for stopping any fires from getting out of control. These department must be fully funded. Otherwise we are sending a signal to criminals that Palo Alto is open to crime. If we do not protect public and private property the city infrastructure will degrade. Public works is the third priority. Without utilities and roads we will become a third world city. Maintaining parks should be the fourth priority. Keep the grass cut. Maybe if needed we could organize some community clean-up days to get rid of trash or debris to help with the budget until we recover. Get the Boy Scouts involved to organize and help with park clean-ups. You need to defund other "nice to have programs" to fund the above until the economy can recover from the state government over reach shutdown. You must also be the voice against SB-9 that will allow Sacramento to zone all Palo Alto Single Family homes allowing Duplex Construction. This a a state power grab that does not respect the economic rights of California residents. Zoning and building decisions should be made at the city level. We made a decision to purchase a property in Palo Alto for its look and feel. This will destroy Palo Alto and make it like other high density disjointed communities. These are very critical issues to me and my other family voting members. We will not support those government officials that support defunding safety and state zoning laws. Sincerely, Victor J. Zilinskas 524 Patricia Lane Palo Alto, CA 94303 44 Baumb, Nelly From:Carol Saal <carol@saal.org> Sent:Thursday, May 13, 2021 9:47 AM To:Council, City Subject:BUDGET CUTS CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  To City of Palo Alto City Council:    You have chosen some very unfortunate places to make your budget cuts.  First of all, WHY the Children's Theatre and Art Center, both of which affect our children? And, you are planning this  after 15 months of isolation following the pandemic! Have you no sense or heart?  As for cutting funds from the Community gardens, you are literally taking food out of people's mouths. It seems to be  such a puny way to balance the budget.  Where are the big bucks that can actually make a dent in the budget? You can  even postpone some projects that aren't urgent until things settle down, but to cut ART, GARDENS, and THEATRE IS A  SLAP IN THE FACE OF THINGS THAT GIVE LIFE JOY and MEANING.  Please reconsider your decisions.    Carol Saal  1955 Bryant St.    -- ========================================================== Carol Saal <Carol@Saal.org> Palo Alto: Voice: 650-328-7745 FAX: 650-328-1948 Sonoma: Voice: 707-935-6397 FAX: 707-935-6398 ========================================================== 45 Baumb, Nelly From:Sue Dinwiddie <s.dinwiddie@icloud.com> Sent:Wednesday, May 12, 2021 9:55 PM To:Council, City Subject:Funding for Police and Fire Departments CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Honourable City Council Members,    We are very concerned about cuts in the budgets for both our Police and Fire Departments.    Our safety depends on both police and fire fighters and when budgets are cut and the number of personnel is cut, the  safety of the community suffers.  The extra time it takes to reach an emergency can mean someone dies while waiting  the extra time for medical or safety help.    We urge you to reconsider these cuts.    Ken and Sue Dinwiddie  543 Jackson Drive  Palo Alto, CA 94303    Sent from my iPhone  46 Baumb, Nelly From:Pat Kinney <pkinney@ix.netcom.com> Sent:Wednesday, May 12, 2021 5:34 PM To:Council, City Subject:Please don't cut services to Youth CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Hi, I’m writing as a citizen of Palo Alto and also as the Session Member for Social Justice for First Presbyterian Church of Palo Alto. Please don’t balance our budget on the backs of the mental /emotional health of our young people. We especially support the Youth Connected Initiative supported by Youth Community Services, and the Children’s Theatre. Both programs support youth who often have little other support in our system. After a difficult time during the pandemic, we need to focus on the mental/emotional health of our youth more than ever. The proposed cuts do little to balance our budget, and can be offsett by other funding sources, so please do not move forward with a budget that includes these cuts. Patricia Kinney 689 Wildwood Lane Palo Alto, CA Elder for the Social Justice Ministry First Presbyterian Chuch of Palo Alto 47 Baumb, Nelly From:J Martin O'Malley <omalley@fertitta.com> Sent:Wednesday, May 12, 2021 4:19 PM To:Council, City Subject:Police Department budget CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear Palo Alto City Council Members,  Please adjust the FY 2022 Budget to avoid eliminating 5 police officers.  Palo Alto employed 50 police officers in FY 2020, budgeted 39 in FY 2021 and proposes to budget 34 in FY 2022.  We must have an adequate number of police officers to ensure public safety.  Sincerely,  Martin O’Malley  40 Crescent Drive  Palo Alto        48 Baumb, Nelly From:E Nigenda <enigenda1@gmail.com> Sent:Wednesday, May 12, 2021 2:33 PM To:Council, City Subject:Budget item: Community Gardens CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council members,     I don’t have a plot at the Community Gardens.  Unfortunately, I don’t even have a green thumb.      Still, food is essential for everyone and, as we see after every disaster and as we continue to see during this pandemic,  our supply chains are only as strong as the weakest link.      I believe it’s essential to keep our community gardens strong and flourishing so that, if necessary, in times of scarcity,  they could be repurposed for wholly growing food for our community.  This can’t happen unless there’s a plan and a  structure in place which includes good soil and good governance.      I therefore ask that the Community Gardens be considered an essential community resource that feeds not only the  spirit but also the body and that in support of this essential resource, the Community Garden Coordinator position be  retained as City Council faces challenging decisions regarding the City's budget.    Additionally, in this time of food scarcity for many, participants might realize their importance to our community's well‐ being if their participation agreement includes contributing fresh fruits and vegetables to food pantries.      Thank you for considering my comments,  Esther Nigenda  Emergency Services Volunteer (speaking for myself)  1 Baumb, Nelly From:Rohini Chakravarthy <rohini.chakravarthy@gmail.com> Sent:Thursday, May 13, 2021 10:25 AM To:Matt B Cc:Sue Dinwiddie; Meera Saxena; Steve Bisset; Crescent Park Assoc; Council, City; Police Subject:Re: [CPNA] Police and Fire Cut - Call to Immediate Action CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  I echo Steve and others’ sentiments. There was a related article about Santa Monica lifeguards who earn up to $392K  and city employees who retire with 79% of salary/benefits at age 55 that might interest people on this thread.    https://www.wsj.com/articles/the‐392‐000‐lifeguard‐baywatch‐as‐union‐shop‐11620858328    An anecdote that highlights the gap between what we are spending vs. the services we are receiving here in Palo Alto.. A  decade ago, my then 9 year old did not qualify for the times required to swim with PASA at the Rinconada swim club.  They had (have) cuts as young as age 6 since they are a competitive swim club. We were schlepping him to Burgess Pool  in Menlo Park 5 days a week, which was inconvenient and didn’t have the community feel biking over and  swimming at  Rinconada would.     I talked to several people at City Parks and Recreation about this: Rinconada is the only city public pool, it has been  turned over to a private company that serves kids from all over the Bay Area, which is great, but it is no longer a  community service. Shouldn’t we at least request them to take all interested Palo Alto kids? No dice. We ultimately  drove my son to Burgess for 5 years (about 2000 car trips on Middlefield) before he moved on to other sports. There  were several other PA parents in the same boat as us.    I would be curious if anyone has done the analysis of how many employees are associated with managing the kids’ swim  program at Rinconada, lifeguards present and past and any subsidies given to PASA. We spend the money, but we don’t  get the services.    I am sure the same is true of the libraries..  we have to fund fixed items like “management” and “past employee  obligations”, while hours are cut, volunteers discouraged and there is minimal innovation in services offered.    Rohini        Sent from my iPhone      On May 13, 2021, at 10:03 AM, Matt B <mbuch2938@gmail.com> wrote:     Neighbors:    According to a report posted this morning on Palo Alto Online,  the city council has decided to use federal funds to avoid  2 making the recently proposed cuts to city services, including  the cuts proposed to city fire and police staffing.  The article is  posted here:    https://www.paloaltoonline.com/news/2021/05/13/palo‐alto‐ prepares‐to‐tap‐into‐federal‐funds‐reserves‐to‐avoid‐budget‐ cuts    Nonetheless, I support the analysis in Steve Bisset's email  regarding staffing levels in the city.  When future budget  pressures arise, we need to consider reductions in city  administration staffing before we contemplate further  reductions in public safety positions.  The city cut several police  and fire positions in 2020, cutting deeper seems dangerous.    Matt    On Wed, May 12, 2021 at 9:56 PM Sue Dinwiddie <sued@daise.com> wrote:  Thanks for the reminder. We just sent off our email.      Sue Dinwiddie   Sent from my iPhone      On 12 May 2021, at 7:53 pm, Meera Saxena <meerasax@gmail.com> wrote:     Dear neighbors and Council Members,    I would like to second Steve Bisset's views here.  So, many services and programs we  value are on the cutting board it's impossible to rate them.  To expand on Steve's point,  we have the crossings guards positions on the list too!!  How much salary do these  people get and for some it's a much needed income.      Please reconsider how and what we cut.      Thank you for your consideration,  Meera Saxena        3 On Wed, May 12, 2021 at 12:02 PM Steve Bisset <steve@bisset.us> wrote:  Dear neighbors and Council Members,    I support Lauren's position.  We need a well‐staffed, well‐funded Police  Department.  We also need an effective way to terminate officers with a  history of racial or ethnic bias and/or excessive use of force, which is a critical  component of support for our competent and courageous officers.    There are so many valuable services that are being cut.  The Police Department  is a high priority, but so are libraries and potholes (for example).    The real problem is that city staff are vigorously ignoring the real problem,  which is that Palo Alto has accumulated, over the years, far more staff in  management positions than necessary to provide efficient and high quality  services.  The salaries of this excess number of managers consume a vast sum  of money, and as they retire, our city's pension obligations  increase.  Whenever we have a budget shortfall, staff proposes cuts that affect  services, and that often reduce employment or income for staff or contractors  who actually do the direct work of serving our residents.  Staff never proposes  cuts in the management layers.      Several years ago we had a city auditor who quietly kept shining a light on  comparative staffing levels in similar cities, and on management "span of  control".  She also analyzed things like how long our planning department took  for various tasks, and showed that we have higher staff levels but substantially  longer delays.  We had a few residents who did some convincing comparisons  with other cities, a few years back.  We could have better service with fewer  managers.    To protect our valuable services, and to avoid city bankruptcy in the future, we  need to address this issue.  It will never be addressed by staff,  understandably.  To address it, citizens must expend resources and deliver  credible data to the Council and to fellow citizens.  This is not a criticism of city  staff individuals, whom I have found to be almost always competent,  conscientious and courteous.  It's a recognition of what bureaucracies cannot  see from the inside, which is an inefficient and top‐heavy organization that  creates work for itself internally.  Until we deal with this we will see more and  more threats to our public safety, arts, libraries, services in general and  infrastructure.    Without looking at comparative best practices data for other cities, staff and  Council will continue to believe that their hands are tied by fiscal reality, but  they are not.      By the way, experienced staff are in short supply in many cities, so those staff  who need to find jobs outside Palo Alto will be able to get them.  This will be a  change that will cause some discomfort, but not hardship.  Hardship is what is  4 caused by reductions in staffing at the bottom rung of the ladder, when those  who provide service directly to the public are terminated.    Regards,  Steve Bisset    On Wed, May 12, 2021 at 10:52 AM Lauren Sims <laurensims@gmail.com> wrote:  Dear CP Neighbors and City Council,     I have been concerned about the lack of police presence over the last couple of years. I have seen an alarming increase in lawlessness. I have had to write into the online police website for speeding issues, reckless driving, and have needed to call the non-emergency a number of times this year for various issues. Our family has relied on the PA Police numerous times needing their help. I can't imagine how scary it will be not to have them there. We live near University Ave and I am often passed by drivers (going into oncoming traffic) when I am going 30mph. My children are biking to school and I worry about their safety and the safety of other children and pedestrians.     Now reading this article in the Palo Alto Weekly, I see why police presence and traffic control has stopped: https://www.paloaltoonline.com/news/2021/05/02/city-plans-further-cuts-to- police-fire-and-community-services    'The Police Department would lose five more patrol officers under the proposed budget, following a year in which 11 positions were cut. "As a result, the Department anticipates increased response times and non-response to various types of calls for service, a transition to mandatory online reporting for certain report types, reduced capacity to perform patrol-level investigations and respond to quality of life issues, and reduced adopt-a- school (K-8) traffic enforcement," the budget states.' I have no interest in a political debate. If your stance is defund the police then please disregard. This email is for those that have the same concerns and do not want further police and fire cuts. Please reach out immediately to city council members (copied here) as this is happening now. Our safety as a community is not a place to cut costs. Police and fire need our support as they are who we are going to turn to in an emergency. Please message me privately if you want to join other residents who have had enough.  Best,  Lauren Sims  Crescent Drive  5 ‐‐   You received this message because you are subscribed to the Google Groups  "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to  crescent‐park‐pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit  https://groups.google.com/d/msgid/crescent‐park‐ pa/CA%2BRkotR7o00bDHhtMHVnDHTUmV7hCETsvRZvqQ8EqFwLULmfzQ%40mail.g mail.com.  ‐‐   You received this message because you are subscribed to the Google Groups  "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to  crescent‐park‐pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐ park‐pa/CALVpHEdUOWj1‐L7M19Quze‐ p55T4xGeud09%2BTe1ds81AozGtaA%40mail.gmail.com.  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent  Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to  crescent‐park‐pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐ park‐ pa/CAKgZpy6KuGYkbh_EmcT2cEBefi%3DQWGHc4rUkRGNqmKo_aCUqgw%40mail.gma il.com.  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/E74AD43C‐EF7B‐4BF9‐B935‐59884D859CB7%40daise.com.  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CAFRdr5zw08rd6wpVV3tqKfWY%2Bx%2BaSiRdK_CeGKXZi0qinVm7zw%40mail.gmail.com.  6 Baumb, Nelly From:S Chang <fivechangs@gmail.com> Sent:Thursday, May 13, 2021 7:41 AM To:Council, City Subject:Fwd: [CPNA] Police and Fire Cut - Call to Immediate Action CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council Members,    I support Lauren Sims’ position below.  At a time when budget considerations must be made, community safety and  emergency services must remain a top priority for our children, for our elderly and everyone in between.      Respectfully,  Siu Chang  Jefferson Drive    ‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐  From: Lauren Sims <laurensims@gmail.com>  Date: Wed, May 12, 2021 at 10:52 AM  Subject: [CPNA] Police and Fire Cut ‐ Call to Immediate Action  To: Crescent Park Assoc <crescent‐park‐pa@googlegroups.com>, City Council <city.council@cityofpaloalto.org>,  <pd@cityofpaloalto.org>    Dear CP Neighbors and City Council,     I have been concerned about the lack of police presence over the last couple of years. I have seen an alarming increase in lawlessness. I have had to write into the online police website for speeding issues, reckless driving, and have needed to call the non-emergency a number of times this year for various issues. Our family has relied on the PA Police numerous times needing their help. I can't imagine how scary it will be not to have them there. We live near University Ave and I am often passed by drivers (going into oncoming traffic) when I am going 30mph. My children are biking to school and I worry about their safety and the safety of other children and pedestrians.     Now reading this article in the Palo Alto Weekly, I see why police presence and traffic control has stopped: https://www.paloaltoonline.com/news/2021/05/02/city-plans-further-cuts-to-police-fire-and-community-services    'The Police Department would lose five more patrol officers under the proposed budget, following a year in which 11 positions were cut. "As a result, the Department anticipates increased response times and non-response to various types of calls for service, a transition to mandatory online reporting for certain report types, reduced capacity to perform patrol-level investigations and respond to quality of life issues, and reduced adopt-a-school (K-8) traffic enforcement," the budget states.' 7 I have no interest in a political debate. If your stance is defund the police then please disregard. This email is for those that have the same concerns and do not want further police and fire cuts. Please reach out immediately to city council members (copied here) as this is happening now. Our safety as a community is not a place to cut costs. Police and fire need our support as they are who we are going to turn to in an emergency. Please message me privately if you want to join other residents who have had enough.  Best,  Lauren Sims  Crescent Drive  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CA%2BRkotR7o00bDHhtMHVnDHTUmV7hCETsvRZvqQ8EqFwLULmfzQ%40mail.gmail.com.  8 Baumb, Nelly From:Priya Chandrasekar <priya_chandrasekar@yahoo.com> Sent:Wednesday, May 12, 2021 10:14 PM To:Council, City; Police Subject:Re: [CPNA] Police and Fire Cut - Call to Immediate Action CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear council members ,      Please set the priorities right we need police and fire people to help us live a safe life .     Incase of emergency it will be a disaster . Already I see people speeding and no enforcement at all in Palo Alto and lots  of enforcement in Menlo Park and atherton . We can make more money by doing patrols and catching offenders .     There has been so many car breakins and then think about the 7 or 8 buglary that happened in one month during  pandamic. We don’t want a repeat of that . Emergency services are crucial for safety of citizens.     Please don’t reduce the fire and police staff .   Priya Chandrasekar          On May 12, 2021, at 12:02 PM, Steve Bisset <steve@bisset.us> wrote:     Dear neighbors and Council Members,    I support Lauren's position.  We need a well‐staffed, well‐funded Police Department.  We also  need an effective way to terminate officers with a history of racial or ethnic bias and/or  excessive use of force, which is a critical component of support for our competent and  courageous officers.    There are so many valuable services that are being cut.  The Police Department is a high  priority, but so are libraries and potholes (for example).    The real problem is that city staff are vigorously ignoring the real problem, which is that  Palo Alto has accumulated, over the years, far more staff in management positions than  necessary to provide efficient and high quality services.  The salaries of this excess number of  managers consume a vast sum of money, and as they retire, our city's pension obligations  increase.  Whenever we have a budget shortfall, staff proposes cuts that affect services, and  that often reduce employment or income for staff or contractors who actually do the direct  work of serving our residents.  Staff never proposes cuts in the management layers.      Several years ago we had a city auditor who quietly kept shining a light on comparative staffing  levels in similar cities, and on management "span of control".  She also analyzed things like how  9 long our planning department took for various tasks, and showed that we have higher staff  levels but substantially longer delays.  We had a few residents who did some convincing  comparisons with other cities, a few years back.  We could have better service with fewer  managers.    To protect our valuable services, and to avoid city bankruptcy in the future, we need to address  this issue.  It will never be addressed by staff, understandably.  To address it, citizens must  expend resources and deliver credible data to the Council and to fellow citizens.  This is not a  criticism of city staff individuals, whom I have found to be almost always competent,  conscientious and courteous.  It's a recognition of what bureaucracies cannot see from the  inside, which is an inefficient and top‐heavy organization that creates work for itself  internally.  Until we deal with this we will see more and more threats to our public safety, arts,  libraries, services in general and infrastructure.    Without looking at comparative best practices data for other cities, staff and Council will  continue to believe that their hands are tied by fiscal reality, but they are not.      By the way, experienced staff are in short supply in many cities, so those staff who need to find  jobs outside Palo Alto will be able to get them.  This will be a change that will cause some  discomfort, but not hardship.  Hardship is what is caused by reductions in staffing at the bottom  rung of the ladder, when those who provide service directly to the public are terminated.    Regards,  Steve Bisset    On Wed, May 12, 2021 at 10:52 AM Lauren Sims <laurensims@gmail.com> wrote:  Dear CP Neighbors and City Council,     I have been concerned about the lack of police presence over the last couple of years. I have seen an alarming increase in lawlessness. I have had to write into the online police website for speeding issues, reckless driving, and have needed to call the non-emergency a number of times this year for various issues. Our family has relied on the PA Police numerous times needing their help. I can't imagine how scary it will be not to have them there. We live near University Ave and I am often passed by drivers (going into oncoming traffic) when I am going 30mph. My children are biking to school and I worry about their safety and the safety of other children and pedestrians.     Now reading this article in the Palo Alto Weekly, I see why police presence and traffic control has stopped: https://www.paloaltoonline.com/news/2021/05/02/city-plans-further-cuts-to-police- fire-and-community-services    'The Police Department would lose five more patrol officers under the proposed budget, following a year in which 11 positions were cut. "As a result, the Department anticipates increased response times and non- response to various types of calls for service, a transition to mandatory online reporting for certain report types, reduced capacity to perform patrol-level investigations and respond to quality of life issues, and reduced adopt-a- school (K-8) traffic enforcement," the budget states.' 10 I have no interest in a political debate. If your stance is defund the police then please disregard. This email is for those that have the same concerns and do not want further police and fire cuts. Please reach out immediately to city council members (copied here) as this is happening now. Our safety as a community is not a place to cut costs. Police and fire need our support as they are who we are going to turn to in an emergency. Please message me privately if you want to join other residents who have had enough.  Best,  Lauren Sims  Crescent Drive  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CA%2BRkotR7o00bDHhtMHVnDHTUmV7hCETsvRZvqQ8EqFwLULmfzQ%40mail.gmail.com.  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CALVpHEdUOWj1‐L7M19Quze‐p55T4xGeud09%2BTe1ds81AozGtaA%40mail.gmail.com.  11 Baumb, Nelly From:Sue Dinwiddie <sued@daise.com> Sent:Wednesday, May 12, 2021 9:57 PM To:Meera Saxena Cc:Steve Bisset; Crescent Park Assoc; Council, City; Police Subject:Re: [CPNA] Police and Fire Cut - Call to Immediate Action CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Thanks for the reminder. We just sent off our email.      Sue Dinwiddie   Sent from my iPhone      On 12 May 2021, at 7:53 pm, Meera Saxena <meerasax@gmail.com> wrote:     Dear neighbors and Council Members,    I would like to second Steve Bisset's views here.  So, many services and programs we value are on the  cutting board it's impossible to rate them.  To expand on Steve's point, we have the crossings guards  positions on the list too!!  How much salary do these people get and for some it's a much needed  income.      Please reconsider how and what we cut.      Thank you for your consideration,  Meera Saxena        On Wed, May 12, 2021 at 12:02 PM Steve Bisset <steve@bisset.us> wrote:  Dear neighbors and Council Members,    I support Lauren's position.  We need a well‐staffed, well‐funded Police Department.  We also  need an effective way to terminate officers with a history of racial or ethnic bias and/or  excessive use of force, which is a critical component of support for our competent and  courageous officers.    There are so many valuable services that are being cut.  The Police Department is a high  priority, but so are libraries and potholes (for example).    The real problem is that city staff are vigorously ignoring the real problem, which is that  Palo Alto has accumulated, over the years, far more staff in management positions than  necessary to provide efficient and high quality services.  The salaries of this excess number of  12 managers consume a vast sum of money, and as they retire, our city's pension obligations  increase.  Whenever we have a budget shortfall, staff proposes cuts that affect services, and  that often reduce employment or income for staff or contractors who actually do the direct  work of serving our residents.  Staff never proposes cuts in the management layers.      Several years ago we had a city auditor who quietly kept shining a light on comparative staffing  levels in similar cities, and on management "span of control".  She also analyzed things like  how long our planning department took for various tasks, and showed that we have higher  staff levels but substantially longer delays.  We had a few residents who did some convincing  comparisons with other cities, a few years back.  We could have better service with fewer  managers.    To protect our valuable services, and to avoid city bankruptcy in the future, we need to  address this issue.  It will never be addressed by staff, understandably.  To address it, citizens  must expend resources and deliver credible data to the Council and to fellow citizens.  This is  not a criticism of city staff individuals, whom I have found to be almost always competent,  conscientious and courteous.  It's a recognition of what bureaucracies cannot see from the  inside, which is an inefficient and top‐heavy organization that creates work for itself  internally.  Until we deal with this we will see more and more threats to our public safety, arts,  libraries, services in general and infrastructure.    Without looking at comparative best practices data for other cities, staff and Council will  continue to believe that their hands are tied by fiscal reality, but they are not.      By the way, experienced staff are in short supply in many cities, so those staff who need to  find jobs outside Palo Alto will be able to get them.  This will be a change that will cause some  discomfort, but not hardship.  Hardship is what is caused by reductions in staffing at the  bottom rung of the ladder, when those who provide service directly to the public are  terminated.    Regards,  Steve Bisset    On Wed, May 12, 2021 at 10:52 AM Lauren Sims <laurensims@gmail.com> wrote:  Dear CP Neighbors and City Council,     I have been concerned about the lack of police presence over the last couple of years. I have seen an alarming increase in lawlessness. I have had to write into the online police website for speeding issues, reckless driving, and have needed to call the non-emergency a number of times this year for various issues. Our family has relied on the PA Police numerous times needing their help. I can't imagine how scary it will be not to have them there. We live near University Ave and I am often passed by drivers (going into oncoming traffic) when I am going 30mph. My children are biking to school and I worry about their safety and the safety of other children and pedestrians.     Now reading this article in the Palo Alto Weekly, I see why police presence and traffic control has stopped: https://www.paloaltoonline.com/news/2021/05/02/city-plans-further-cuts-to- police-fire-and-community-services    13 'The Police Department would lose five more patrol officers under the proposed budget, following a year in which 11 positions were cut. "As a result, the Department anticipates increased response times and non- response to various types of calls for service, a transition to mandatory online reporting for certain report types, reduced capacity to perform patrol- level investigations and respond to quality of life issues, and reduced adopt- a-school (K-8) traffic enforcement," the budget states.' I have no interest in a political debate. If your stance is defund the police then please disregard. This email is for those that have the same concerns and do not want further police and fire cuts. Please reach out immediately to city council members (copied here) as this is happening now. Our safety as a community is not a place to cut costs. Police and fire need our support as they are who we are going to turn to in an emergency. Please message me privately if you want to join other residents who have had enough.  Best,  Lauren Sims  Crescent Drive  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA"  group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CA%2BRkotR7o00bDHhtMHVnDHTUmV7hCETsvRZvqQ8EqFwLULmfzQ%40mail.gmail.com.  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CALVpHEdUOWj1‐L7M19Quze‐p55T4xGeud09%2BTe1ds81AozGtaA%40mail.gmail.com.  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CAKgZpy6KuGYkbh_EmcT2cEBefi%3DQWGHc4rUkRGNqmKo_aCUqgw%40mail.gmail.com.  14 Baumb, Nelly From:Meera Saxena <meerasax@gmail.com> Sent:Wednesday, May 12, 2021 7:53 PM To:Steve Bisset Cc:Crescent Park Assoc; Council, City; Police Subject:Re: [CPNA] Police and Fire Cut - Call to Immediate Action CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear neighbors and Council Members,    I would like to second Steve Bisset's views here.  So, many services and programs we value are on the cutting board it's  impossible to rate them.  To expand on Steve's point, we have the crossings guards positions on the list too!!  How much  salary do these people get and for some it's a much needed income.      Please reconsider how and what we cut.      Thank you for your consideration,  Meera Saxena        On Wed, May 12, 2021 at 12:02 PM Steve Bisset <steve@bisset.us> wrote:  Dear neighbors and Council Members,    I support Lauren's position.  We need a well‐staffed, well‐funded Police Department.  We also need an  effective way to terminate officers with a history of racial or ethnic bias and/or excessive use of force, which  is a critical component of support for our competent and courageous officers.    There are so many valuable services that are being cut.  The Police Department is a high priority, but so are  libraries and potholes (for example).    The real problem is that city staff are vigorously ignoring the real problem, which is that Palo Alto has  accumulated, over the years, far more staff in management positions than necessary to provide efficient and  high quality services.  The salaries of this excess number of managers consume a vast sum of money, and as  they retire, our city's pension obligations increase.  Whenever we have a budget shortfall, staff proposes cuts  that affect services, and that often reduce employment or income for staff or contractors who actually do the  direct work of serving our residents.  Staff never proposes cuts in the management layers.      Several years ago we had a city auditor who quietly kept shining a light on comparative staffing levels in  similar cities, and on management "span of control".  She also analyzed things like how long our planning  department took for various tasks, and showed that we have higher staff levels but substantially longer  delays.  We had a few residents who did some convincing comparisons with other cities, a few years  back.  We could have better service with fewer managers.    15 To protect our valuable services, and to avoid city bankruptcy in the future, we need to address this issue.  It  will never be addressed by staff, understandably.  To address it, citizens must expend resources and deliver  credible data to the Council and to fellow citizens.  This is not a criticism of city staff individuals, whom I have  found to be almost always competent, conscientious and courteous.  It's a recognition of what bureaucracies  cannot see from the inside, which is an inefficient and top‐heavy organization that creates work for itself  internally.  Until we deal with this we will see more and more threats to our public safety, arts, libraries,  services in general and infrastructure.    Without looking at comparative best practices data for other cities, staff and Council will continue to believe  that their hands are tied by fiscal reality, but they are not.      By the way, experienced staff are in short supply in many cities, so those staff who need to find jobs outside  Palo Alto will be able to get them.  This will be a change that will cause some discomfort, but not  hardship.  Hardship is what is caused by reductions in staffing at the bottom rung of the ladder, when those  who provide service directly to the public are terminated.    Regards,  Steve Bisset    On Wed, May 12, 2021 at 10:52 AM Lauren Sims <laurensims@gmail.com> wrote:  Dear CP Neighbors and City Council,     I have been concerned about the lack of police presence over the last couple of years. I have seen an alarming increase in lawlessness. I have had to write into the online police website for speeding issues, reckless driving, and have needed to call the non-emergency a number of times this year for various issues. Our family has relied on the PA Police numerous times needing their help. I can't imagine how scary it will be not to have them there. We live near University Ave and I am often passed by drivers (going into oncoming traffic) when I am going 30mph. My children are biking to school and I worry about their safety and the safety of other children and pedestrians.     Now reading this article in the Palo Alto Weekly, I see why police presence and traffic control has stopped: https://www.paloaltoonline.com/news/2021/05/02/city-plans-further-cuts-to-police-fire-and-community- services    'The Police Department would lose five more patrol officers under the proposed budget, following a year in which 11 positions were cut. "As a result, the Department anticipates increased response times and non-response to various types of calls for service, a transition to mandatory online reporting for certain report types, reduced capacity to perform patrol-level investigations and respond to quality of life issues, and reduced adopt-a-school (K-8) traffic enforcement," the budget states.' I have no interest in a political debate. If your stance is defund the police then please disregard. This email is for those that have the same concerns and do not want further police and fire cuts. Please reach out immediately to city council members (copied here) as this is happening now. Our safety as a community is not a place to cut costs. Police and fire need our support as they are who we are going to turn to in an emergency. Please message me privately if you want to join other residents who have had enough.  Best,  16 Lauren Sims  Crescent Drive  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CA%2BRkotR7o00bDHhtMHVnDHTUmV7hCETsvRZvqQ8EqFwLULmfzQ%40mail.gmail.com.  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐pa/CALVpHEdUOWj1‐ L7M19Quze‐p55T4xGeud09%2BTe1ds81AozGtaA%40mail.gmail.com.  17 Baumb, Nelly From:Dale Tatum <daletatum@hotmail.com> Sent:Wednesday, May 12, 2021 4:46 PM To:Council, City; Police; Lauren Sims Subject:Re: [CPNA] Police and Fire Cut - Call to Immediate Action CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  City Council Members,    I join Lauren and others in being dismayed by the idea of reducing Palo Alto police.  I don't want to see more  burglaries or robberies or vandalism of parked cars in this city and its neighborhoods.  There is already too  much.    Dale    From: 'Harish Belur' via Crescent Park PA <crescent‐park‐pa@googlegroups.com>  Sent: Wednesday, May 12, 2021 11:12 AM  To: Crescent Park Assoc <crescent‐park‐pa@googlegroups.com>; City Council <city.council@cityofpaloalto.org>;  pd@cityofpaloalto.org <pd@cityofpaloalto.org>; Lauren Sims <laurensims@gmail.com>  Subject: Re: [CPNA] Police and Fire Cut ‐ Call to Immediate Action      Thank you, Lauren. Dear City Council Members, I join Lauren in respectfully requesting that we maintain and strengthen our commitment to law enforcement. I see the speeding and other lawlessness increasing in my neighborhood and we definitely need more resources allocated to law enforcement Thank you! Harish, Fulton St. On Wednesday, May 12, 2021, 10:52:49 AM PDT, Lauren Sims <laurensims@gmail.com> wrote: Dear CP Neighbors and City Council, I have been concerned about the lack of police presence over the last couple of years. I have seen an alarming increase in lawlessness. I have had to write into the online police website for speeding issues, reckless driving, and have needed to call the non-emergency a number of times this year for various issues. Our family has relied on the PA Police numerous times needing their help. I can't imagine how scary it will be not to have them there. We live near University Ave and I am often passed by drivers (going into oncoming traffic) when I am going 30mph. My children are biking to school and I worry about their safety and the safety of other children and pedestrians. Now reading this article in the Palo Alto Weekly, I see why police presence and traffic control has stopped: https://www.paloaltoonline.com/news/2021/05/02/city-plans-further-cuts-to-police-fire-and-community-services 18 'The Police Department would lose five more patrol officers under the proposed budget, following a year in which 11 positions were cut. "As a result, the Department anticipates increased response times and non-response to various types of calls for service, a transition to mandatory online reporting for certain report types, reduced capacity to perform patrol-level investigations and respond to quality of life issues, and reduced adopt-a-school (K-8) traffic enforcement," the budget states.' I have no interest in a political debate. If your stance is defund the police then please disregard. This email is for those that have the same concerns and do not want further police and fire cuts. Please reach out immediately to city council members (copied here) as this is happening now. Our safety as a community is not a place to cut costs. Police and fire need our support as they are who we are going to turn to in an emergency. Please message me privately if you want to join other residents who have had enough. Best, Lauren Sims Crescent Drive -- You received this message because you are subscribed to the Google Groups "Crescent Park PA" group. To unsubscribe from this group and stop receiving emails from it, send an email to crescent-park- pa+unsubscribe@googlegroups.com. To view this discussion on the web visit https://groups.google.com/d/msgid/crescent-park- pa/CA%2BRkotR7o00bDHhtMHVnDHTUmV7hCETsvRZvqQ8EqFwLULmfzQ%40mail.gmail.com. ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/1399684065.1674509.1620843130702%40mail.yahoo.com.  19 Baumb, Nelly From:Michael Collins <collinsmichaelp@gmail.com> Sent:Wednesday, May 12, 2021 3:15 PM To:Lauren Sims Cc:Council, City; Police; Vivian Chow Subject:Re: [CPNA] Police and Fire Cut - Call to Immediate Action CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Lauren,     Thank you for your email.     My wife, Vivian, and I live with our two boys on Fulton Street.      We support your position and agree that we need a well‐staffed and well‐funded Police Department. The public safety  and order, and general helpfulness that the police provide, are fundamental to the success of our Palo Alto community.      We strongly request that the City Council support and further invest in our Police Department.      We also thank our law enforcement officers for their commitment and service to our community.  They have a difficult  job, and we appreciate what they do for us.     Thank you.     Warm regards,    Michael Collins         On Wed, May 12, 2021 at 10:52 AM Lauren Sims <laurensims@gmail.com> wrote:  Dear CP Neighbors and City Council,     I have been concerned about the lack of police presence over the last couple of years. I have seen an alarming increase in lawlessness. I have had to write into the online police website for speeding issues, reckless driving, and have needed to call the non-emergency a number of times this year for various issues. Our family has relied on the PA Police numerous times needing their help. I can't imagine how scary it will be not to have them there. We live near University Ave and I am often passed by drivers (going into oncoming traffic) when I am going 30mph. My children are biking to school and I worry about their safety and the safety of other children and pedestrians.     Now reading this article in the Palo Alto Weekly, I see why police presence and traffic control has stopped: https://www.paloaltoonline.com/news/2021/05/02/city-plans-further-cuts-to-police-fire-and-community-services    'The Police Department would lose five more patrol officers under the proposed budget, following a year in which 11 positions were cut. 20 "As a result, the Department anticipates increased response times and non-response to various types of calls for service, a transition to mandatory online reporting for certain report types, reduced capacity to perform patrol-level investigations and respond to quality of life issues, and reduced adopt-a-school (K-8) traffic enforcement," the budget states.' I have no interest in a political debate. If your stance is defund the police then please disregard. This email is for those that have the same concerns and do not want further police and fire cuts. Please reach out immediately to city council members (copied here) as this is happening now. Our safety as a community is not a place to cut costs. Police and fire need our support as they are who we are going to turn to in an emergency. Please message me privately if you want to join other residents who have had enough.  Best,  Lauren Sims  Crescent Drive  ‐‐   You received this message because you are subscribed to the Google Groups "Crescent Park PA" group.  To unsubscribe from this group and stop receiving emails from it, send an email to crescent‐park‐ pa+unsubscribe@googlegroups.com.  To view this discussion on the web visit https://groups.google.com/d/msgid/crescent‐park‐ pa/CA%2BRkotR7o00bDHhtMHVnDHTUmV7hCETsvRZvqQ8EqFwLULmfzQ%40mail.gmail.com.        ‐‐   Michael Collins       21 Baumb, Nelly From:Laure MAZZARA <lauremazzara@comcast.net> Sent:Wednesday, May 12, 2021 12:40 PM To:Council, City; Police Subject:Re: [CPNA] Police and Fire Cut - Call to Immediate Action CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear council members I am in complete agreement with Steve Bisset. Laure Mazzara On 5/12/21, 9:02 PM, "Steve Bisset" <steve@bisset.us> wrote:  Dear neighbors and Council Members, I support Lauren's position. We need a well-staffed, well-funded Police Department. We also need an effective way to terminate officers with a history of racial or ethnic bias and/or excessive use of force, which is a critical component of support for our competent and courageous officers.Dear concil member There are so many valuable services that are being cut. The Police Department is a high priority, but so are libraries and potholes (for example). The real problem is that city staff are vigorously ignoring the real problem, which is that Palo Alto has accumulated, over the years, far more staff in management positions than necessary to provide efficient and high quality services. The salaries of this excess number of managers consume a vast sum of money, and as they retire, our city's pension obligations increase. Whenever we have a budget shortfall, staff proposes cuts that affect services, and that often reduce employment or income for staff or contractors who actually do the direct work of serving our residents. Staff never proposes cuts in the management layers. Several years ago we had a city auditor who quietly kept shining a light on comparative staffing levels in similar cities, and on management "span of control". She also analyzed things like how long our planning department took for various tasks, and showed that we have higher staff levels but substantially longer delays. We had a few residents who did some convincing comparisons with other cities, a few years back. We could have better service with fewer managers. To protect our valuable services, and to avoid city bankruptcy in the future, we need to address this issue. It will never be addressed by staff, understandably. To address it, citizens must expend resources and deliver credible data to the Council and to fellow citizens. This is not a criticism of city staff individuals, whom I have found to be almost always competent, conscientious and courteous. It's a recognition of what bureaucracies cannot see from the inside, which is an inefficient and top-heavy organization that creates work for itself internally. Until we deal with this we will see more and more threats to our public safety, arts, libraries, services in general and infrastructure. Without looking at comparative best practices data for other cities, staff and Council will continue to believe that their hands are tied by fiscal reality, but they are not. 22 By the way, experienced staff are in short supply in many cities, so those staff who need to find jobs outside Palo Alto will be able to get them. This will be a change that will cause some discomfort, but not hardship. Hardship is what is caused by reductions in staffing at the bottom rung of the ladder, when those who provide service directly to the public are terminated. Regards, Steve Bisset On Wed, May 12, 2021 at 10:52 AM Lauren Sims <laurensims@gmail.com> wrote:  Dear CP Neighbors and City Council, I have been concerned about the lack of police presence over the last couple of years. I have seen an alarming increase in lawlessness. I have had to write into the online police website for speeding issues, reckless driving, and have needed to call the non-emergency a number of times this year for various issues. Our family has relied on the PA Police numerous times needing their help. I can't imagine how scary it will be not to have them there. We live near University Ave and I am often passed by drivers (going into oncoming traffic) when I am going 30mph. My children are biking to school and I worry about their safety and the safety of other children and pedestrians. Now reading this article in the Palo Alto Weekly, I see why police presence and traffic control has stopped: https://www.paloaltoonline.com/news/2021/05/02/city- plans-further-cuts-to-police-fire-and-community-services 'The Police Department would lose five more patrol officers under the proposed budget, following a year in which 11 positions were cut. "As a result, the Department anticipates increased response times and non- response to various types of calls for service, a transition to mandatory online reporting for certain report types, reduced capacity to perform patrol-level investigations and respond to quality of life issues, and reduced adopt-a-school (K-8) traffic enforcement," the budget states.' I have no interest in a political debate. If your stance is defund the police then please disregard. This email is for those that have the same concerns and do not want further police and fire cuts. Please reach out immediately to city council members (copied here) as this is happening now. Our safety as a community is not a place to cut costs. Police and fire need our support as they are who we are going to turn to in an emergency. Please message me privately if you want to join other residents who have had enough. Best, Lauren Sims Crescent Drive  1 Baumb, Nelly From:Mila Zelkha <mila@manzanita.works> Sent:Saturday, May 15, 2021 12:07 PM To:Council, City Cc:Shikada, Ed; Kamhi, Philip Subject:Fw: Proposal: Manzanita Transit Attachments:CityPaloAlto_Proposal_5-11-21.pdf; Brochure_ManzanitaTransit_Spring2021.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council,    I'm writing to share with you the proposal I sent to the Finance Committee last week, briefing them on  our Manzanita Transit program's subregional TMA known as the "Ravenswood Transit Consortium".    During the committee proceedings, there was a question about the words "in development" used in our  brochure to describe our involvement with Caltrain. I would like to clarify here.    After voting on a GoPass distribution policy change last January, Caltrain staff is currently formulating a  pilot program where community based organizations throughout the region could play a role in  distributing GoPasses to nonregular and contract workers for the large employers who purchase TMAs.    We have been in talks with Caltrain about the potential of our organization to be named as one such  organization and therefore that collaboration is "in development". We await Caltrain to decide how  they intend to proceed with all organizations.    In the meantime, here is a link to our 'Essential Express' ‐ a follow up to the free long‐haul transit pilot  we provided during shelter in place to essential workers.  https://www.manzanita.works/essential‐express    Happy to provide any additional information if of interest.    With appreciation,  Mila      From: Mila Zelkha  Sent: Tuesday, May 11, 2021 2:30 PM  To: Cormack, Alison <Alison.Cormack@CityofPaloAlto.org>; Eric.Filseth@cityofpaloalto.org  <Eric.Filseth@cityofpaloalto.org>; Pat.Burt@cityofpaloalto.org <Pat.Burt@cityofpaloalto.org>  Cc: Ed.Shikada@cityofpaloalto.org <Ed.Shikada@cityofpaloalto.org>; philip.kamhi@cityofpaloalto.org  <philip.kamhi@cityofpaloalto.org>; kiely.nose@cityofpaloalto.org <kiely.nose@cityofpaloalto.org>  Subject: Proposal: Manzanita Transit      Dear Council Finance Committee,  2   I share for your review and consideration, a proposal for collaboration and transportation demand  management outreach from our organization, Manzanita Works.    We offer this proposal as a cost‐effective option to approach single occupancy vehicle mode shift as the  region navigates the return to in‐person work in the weeks and months ahead.    Please let us know if you have any questions about our proposal, our Manzanita Transit program  (brochure also included) or our organization.    With appreciation,    Mila Zelkha  Chief Executive Officer  Manzanita Works  650‐518‐0040  M A N Z A N I T A EXPANDING COMMUTE OPTIONS MAKING AFFORDABLE , RELIA BLE, AND CO NVENIENT TR ANSP ORT ATION A REALITY FOR OUR WO RKFORCE TRANSIT Workers of our regional economy live and work interspersed in communities throughout the Bay Area. Their commute is challenged by lack of options that meet their particular needs. Manzanita Works is fixing the Bay Areas' broken commute through the Manzanita Transit program, a network of subregional consortiums consisting of public, private and nonprofit sector members. These consortiums, also known as transportation management associations (TMAs), operate to integrate and expand Transportation Demand Management (TDM) options that better connect commuters between home and their place of work as our region navigates returning to in-person work in the coming weeks and months. public sector- with the funding and experience to design, build and operate transportation systems for public benefit,private sector - with the financing and expertise to deploy entrepreneurial, performance-based approaches to commuting arrangements and transportation demand management, andcommuter– the target customer for complete commute options services that reduce reliance on single-occupancy vehicle (SOV) trips This multi-sector composition is designed to enable a more flexible collaboration between the: By leveraging existing transportation options to create a more cost-effective, convenient commute for the region’s diverse workforce, we will strengthen public transportation in the long run. MANZANITA TRANSIT Adaptive locally-based commute options that support thewelfare of workers and their families • • • Commute Pilotage- 1:1 sessions to understand existing resources Community VanPool GoPass Distribution- access to Caltrain’s GoPass for non-regular and contract workers Bike Loan & Bike Share Car Access during the Workday First and Last Leg Connections Guaranteed Ride Home TRANSPORTATION RESOURCES & SERVICES EXISTING RESOURCES LAUNCHING SUMMER 2021 Essential Express- shared long-haul transit for essential & returning workers IN DEVELOPMENT Auto/Bike Insurance Discount Carpool Bike Commuter Support ~ t .... .dill !II ' EMAIL Or contact us directly Mila Zelkha, CEO mila@manzanita.works Nora Razón, Director of Community Partnerships nora@manzanita.works EXPLORE MEMBERSHIP ARE YOU AN EMPLOYER LOOKING TO PROVIDE SAFE, FAIR, AND DESIRABLE BENEFITS TO YOUR REGIONAL EMPLOYEES? LEARN MORE FROM US TO SEE THE PERKS YOU CAN OFFER YOUR EMPLOYEES. BECOME A P A RT OF OUR MULTI-SECTORCONSORTIUMS WORKING COLLABO RATIVELY TORESOLVE REGIONAL DILEMMAS BY SOLVING LOCALPROBLEMS A T AN ECONOMY OF SCALE THAT WORKS CONTACT US TO SET UP A TIME TO EXPLO RE MEMBERSHIP & BENEFITS www.manz anita.works ONLINE FORM Share your contact information with us & we will contact you! https://www.manzanita.works/manzanita-transit IF YOU'RE AN EMPLOYEE AND ARE IN NEED OF BETTER TRANSPORTATION OPTIONS, LET YOUR EMPLOYER KNOW ABOUT THIS PROGRAM OR CONNECT DIRECTLY WITH US. Manzanita Works’ Transit Demand Management Proposal Introduction: Within the Ravenswood subregion, a geography from Sunnyvale to Redwood City, Manzanita Works manages the ‘Ravenswood Transit Consortium’, a transportation management association (TMA) which designs and delivers TDM services that help private, public and nonprofit employers realize their mode shift goals. The objective of the work outlined in this proposal is to: a)to build a relationship with the City, and b)become a point of contact for City TDM efforts that integrate private and public commuter options. Request: As Manzanita Works leads efforts with employers to integrate their respective TDM programs across the subregion, including employers located in Palo Alto, we will: a) assist with TDM compliance per city or state policy including development agreements; b) partner with the City to implement required current and future TDM policies; and c) request City capacity building grant funding for outreach to local employers. Objectives: Manzanita Works proposes a mode shift goal of 100 commuters for every $100,000 in grant funds awarded. Mode shift is measured as a switch away from single occupancy vehicles (SOV) use at least 3 days per work week among a ridership from various sectors, job types and income levels. By enhancing local and regional TDM programs and emphasizing strategies that greatly increase person throughput and high occupancy vehicle use on regionally significant congested corridors, these programs will provide: 1.trip reduction improvements as mandated development agreements; 2.local street traffic flow improvement; 3.reduction of cut-through traffic in residential neighborhoods; 4.increased capacity of service to workers whose employers are unable to otherwise provide commute benefits with potential for travel time savings; 5.solutions to first and last leg connection challenges; 6.reduction of greenhouse gas emissions and other air pollutants by increasing transit use and other alternative commute options while reducing SOV trips; and 7.advocate to transit providers for additional service as needed. Page ! of !1 3 Background: The City was a key participant in Joint Venture Silicon Valley’s Manzanita Talks, which took a deep dive into thinking strategically about how to deploy TDM programs in cities and regions more effectively. The Talks joined private industry transportation leaders with elected officials and produced the Manzanita Report and Alternatives Analysis. The Ravenswood Transit Consortium is a response to this report and Manzanita Works proposes to partner with the City as the consortium integrates TDM programs to improve commuter connectivity and reduce SOV drivers in Palo Alto. The vision is for a practical, phased deployment of city-wide TDM programs based on job-center neighborhoods and transit- oriented development, and access to transportation resources from within the larger subregion. The nature of this proposal is public-private where partnership from City of Palo Alto is needed for effective TDM compliance. In addition, as a local employer who might benefit from the proposed programs, the City may choose to join the Ravenswood Transit Consortium itself. Valley Transportation Authority (VTA), the local congestion management agency, has been invited to create program recommendations should the City partner with this initiative. The Manzanita Transit program outlined in this proposal is deployed by Manzanita Works within its nonprofit mission in partnership with established service providers. Oversight responsibility rests with the Board of Directors of Community Initiatives until such time as Manzanita Works is recognized as exempt under section 501(c)(3) of the U.S. Internal Revenue Code. Funding: Operating funds come from a mix of private and public funding sources including employer dues (sliding scale), corporate sponsorship, and philanthropic grants. Soon, public funds will be sought to diversify funding sources from regional entities such the Bay Area Air Quality Management District and the Metropolitan Transportation Commission. Program Services: •Commute Counseling - 1:1 sessions to understand existing resources, subsidies & incentives •Essential Express - long-haul transit for essential and returning workers •Bike Commuter Support - bike repair clinics, bike safety classes, bike-to-work rides •Community Vanpools - including subsidies & incentives •Guaranteed Ride Home •TDM compliance support In Development: •Caltrain GoPass Distribution - access for non-regular and contract workers •Commuter Insurance •First and Last Leg Connections (7 miles or less) •Bike Loan & Bike Share •Car Access during the workday Page ! of !2 3 Schedule: Provided the City of Palo Alto welcomes this proposal, Manzanita Transit program activities would be supported Q3 of 2021 through Q2 of 2022. Metrics: Employers participating in the Ravenswood Transit Consortium are encouraged to participate in annual surveys. Measurement of mode shift will be provided from both program ridership data and regional traffic data using a Street Light Data software subscription. About Manzanita Works: Manzanita Works mission is to support the welfare of workers and their families to live fruitful, dignified lives. Our vision is to create a thriving regional workforce in collaboration with multi- sector partners. Manzanita Works is a fiscally sponsored project of Community Initiatives in Oakland, CA. Previously known as Bay Area Forward, we have supported community-led efforts to create housing and transportation options in the San Francisco Bay Area since 2014. Our team: Mila Zelkha, Chief Executive Officer, has a background in architecture, social entrepreneurship and the intersections of historic preservation & sustainability, regional dilemmas & local action. Nora Razón, Director of Community Partnerships, oversees the partnerships and collaboration between community serving nonprofits and public education institutions. Justine Burt, Future of Work Program Lead, oversees outreach to commuting workers. Her background is in behavior change in the transportation and clean energy sectors. Douglas Kolozsvari, Ph.D., is the Principal of Solutions 2050, a climate science planning and policy firm working with Bay Area public agencies to meet GHG emission reduction goals. Lynette Busby and Chris Romero are transportation consultants with MRG, LLC with over 30 years of experience designing and implementing TDM programs, which resulted in trip reductions of up to 32% in Contra Costa County including the Contra Costa Centre TMA. Our founding board: Ian Bain, Former Mayor of Redwood City Yii-Jan Lin, Associate Professor of New Testament, Yale Divinity School María Marroquín, Executive Director of the Day Worker Center of Mountain View Terry Sandoval, SEIU-United Health Care Workers Kaloma Smith, Reverend of University AME Zion Church and Chair of the City of Palo Alto Human Relations Commission Contact: Mila Zelkha mila@manzanita.works Page ! of !3 3 3 Baumb, Nelly From:Michael Mok <michael.mok@gmail.com> Sent:Saturday, May 15, 2021 8:45 AM To:Council, City Cc:DuBois, Tom; Burt, Patrick; Cormack, Alison; Filseth, Eric (Internal); Kou, Lydia; Tanaka, Greg Subject:PA Arts Center Attachments:Michael Mok Letter Save PA Art Center.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council,     Attached is my letter.     Cheers,      ‐‐   Mike    Rehabbing Casa Video and Blog: rehabbingcasa.com    YouTube Channel: Rehabbing Casa    Facebook: Michael J Mok    Twitter: @michaelmoksfbay    Design and Build: bridgesmr.com    Dear City Council members, Did you know that the Palo Alto Art Center celebrates its 50th anniversary this year? Did you know that for 50 years, Palo Alto Art Center has pride itself in providing creative opportunities for ALL AGES to see and make art? Did you know that the SEEING part-the part that makes the Art Center a MUSEUM and not simply a community center providing art classes and camps-has garnered national recognitions including federal grant supports from the very prestigious National Endowment for the Arts and the Institute for Museum and Library Services? Did you know that the SEEING part-our exhibitions-also bring in works from Picasso (yes, Picasso), MacArthur Foundation Genius Award artists Titus Kaphar and Whitfield Lovell (both of them are in our current exhibition The Black Index), and many widely-recognized contemporary artists in the San Francisco Bay Area and nationally, in addition to art works from PAUSD K-12 students? Did you know that the SEEING part-our exhibitions-also form the basis of our school tour program Project Look where nearly 4,000 students, teachers and chaperones participated in 176 tours during the 2019-20 school year? These students, teachers and chaperones came from 38 schools in Palo Alto, East Palo Alto, Belmont, Cupertino, Foster City, Fremont, Los Altos, Menlo Park, Mountain View, Portola Valley, Redwood City, San Carlos, Santa Clara, and Saratoga. Did you know that Project Look support the development of 21st-century skills-critical to the overall development of these youngsters? If you have school-age children, chances are they have participated in at least one Project Look tour. Teachers report their Art Center experience allowed their students to practice creativity (100%), communication (92%), critical thinking (96%), and collaboration (58%). Did you also know that the Palo Alto Art Center Foundation contributes more than $200,000 annually to supplement the city budget for all Art Center programs? Did you know that by ELIMINATING our exhibition program, Project look, free Teen & Family programs, and Cultural Kaleidoscope, you take away the causes for support, severely reducing the Foundation's ability to raise $750,000 a year from institutional and individual donors?- We hope there's little need to continue listing the impact the proposed budget cuts will have on the viability of the Palo Alto Art Center-a gem in the City of Palo Alto. What the City chooses to spend money on reflects its values. Are we a city that think the arts are extra and expandable? Are we a city that believe "cost-recovery" trumps ensuring accessibility for all? l(fdflµ ·/l1, Jzaa,,/ /Jllofr 6 3 '1 ~ ea{e,-,4v -e.. {\do A--lh Cfr 4 Baumb, Nelly From:lisa Matar <misslisamatar@gmail.com> Sent:Saturday, May 15, 2021 1:48 PM To:Council, City Subject:Please help CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    The children’s theater is so important For the lives of many children in the area. I cannot think of a more uplifting and  fulfilling organization. This organization deserves the support from the city post Covid world ‐ please help them with  their financial challenges as it is not their fault for such trouble. The theater helps many children stay out of trouble and  express themselves and healthy way. Let’s keep it going!    Sent from my iPhone  5 Baumb, Nelly From:Shree Sandilya <shreebee.sandilya@gmail.com> Sent:Sunday, May 16, 2021 2:28 PM To:Council, City Subject:C-A Corridor Plan CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council,    Please support Finance Committee’s recommendation to use SUMC funds so a construction contract may be awarded  immediately using current bids, combining Phases 3 and 4 (or Phases  3a and 3b) to complete the full scope of the  Charleston/Arastradero Corridor Project. It would make riding immeasurably safer for the hundreds of kids who take this  route to school, and would also further encourage the use of bikes in our community, which is an awesome thing.     Thank you.    Shree Sandilya  6 Baumb, Nelly From:Charlotte Epstein <ch8r_e@yahoo.com> Sent:Sunday, May 16, 2021 2:30 PM To:Council, City Subject:Support the Arts and Community Organizations CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  I appreciate all the efforts of the Finance Committee that went into the budget process. Palo Alto citizens have expressed their support for restoring funding to the organizations that have made Palo Alto such a special place to live such as the Art Center, the libraries, Children's Theatre and all the organizations that thrive at Cubberley Center. Please support the organizations that offer ways for people of all ages, especially the children, to find their way back to "normal" life. Charlotte Epstein 2192 Waverley St Palo Alto CA 650.714.0388 7 Baumb, Nelly From:Barron Park PTA <barronparkpta@gmail.com> Sent:Monday, May 17, 2021 2:15 PM To:Council, City Subject:Opposition to budget cuts towards crossing guards and PAPD Traffic Team CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    May 17, 2021    Dear City Council Members,    On behalf of the Barron Park Elementary School PTA Executive Board, we are writing in full support of Palo Alto Council of PTA’s stance in opposition of proposed budget cuts to crossing guards staffing and the PAPD Traffic Team. Our children’s safety is a top priority. With the return to normalcy for next school year, there will be a strong need for maximum staffing of both crossing guards teams and the PAPD Traffic Team to ensure our children’s safety.    If anyone has been near a school during the morning drop-off or afternoon pick-up times, you will understand the chaos that surrounds the immediate area -- besides cars, there are bikes, scooters, skateboards, strollers, and pedestrians on all the nearby sidewalks and streets. The physical presence of a single crossing guard dramatically increases the safety of street crossing even on a small street such as Barron Avenue not to mention the larger street crossings such as El Camino and Embarcadero. Crossing guards ensure that the vehicular traffic actually stops when there are people present at crosswalks.    Also, the City has always advocated for the reduction of vehicular traffic in the city by encouraging its citizens to choose alternate options to driving through the creation of bike boulevards and traffic safety enhancement projects. However, this proposed budget cut goes against what the City has always advocated. Reducing the number of crossing guards visibly reduces the number of safe street crossings for students. As a result, the number of parents who drive their students to and from school will increase because perceived safety is a key factor in a family’s decision whether to allow their student to walk or bike to school.    The physical presence of PAPD officers directly correlates to safer driving behavior. Reducing the PAPD Traffic Team will reduce traffic enforcement which is especially critical during times when students and commuters converge on our city streets such as morning rush hour. The city of Palo Alto has always had an unusually high number of commuters coming into the city in the morning and leaving in the afternoon to early evening. These times of higher vehicular traffic coincide with when schools start and end and these are exactly the times we need preventative traffic enforcement from PAPD.    The Barron Park Elementary School PTA Executive Board requests that you fully fund the Crossing Guards and PAPD officer staffing. Your decisions on traffic safety directly affects the safety of our students. Thank you for your consideration.    Sincerely,    Pearlin Yang  Barron Park PTA President 2020-2021     Elizabeth Gardner  8 Barron Park PTA President 2021-2022      701-32 DOCUMENTS IN THIS PACKET INCLUDE: LETTERS FROM CITIZENS TO THE MAYOR OR CITY COUNCIL RESPONSES FROM STAFF TO LETTERS FROM CITIZENS ITEMS FROM MAYOR AND COUNCIL MEMBERS ITEMS FROM OTHER COMMITTEES AND AGENCIES ITEMS FROM CITY, COUNTY, STATE, AND REGIONAL AGENCIES Prepared for: 06/01/2021 Document dates: 05/12/2021 – 05/19/2021 Set 2 Note: Documents for every category may not have been received for packet reproduction in a given week. 9 Baumb, Nelly From:Mora Oommen <mora@youthcommunityservice.org> Sent:Monday, May 17, 2021 3:15 PM To:Council, City; DuBois, Tom; Cormack, Alison; Burt, Patrick; Tanaka, Greg; Kou, Lydia; Stone, Greer; Filseth, Eric (Internal) Subject:Over 2,500! Attachments:petition_comments_jobs_28696217_20210517204927.pdf; petition_signatures_jobs_28696217_ 20210517204932.pdf; 2019-20 SP Annual Report_final.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Hon City Council Members,    Attached is the most recent download of the collective signatures (over 2,500) and comments submitted by the public to request restoring funds for children and youth programs and services in the 2021-22 Budget.     I am specifically writing to point out that it is not clear in the Agenda published for tonight's City Council Meeting that the funding for Youth Connectedness Initiative youth mental health program on Page 202 (printed page #) of the 2021-22 proposed budget will be part of the parking lot for discussion. Of all the General Human Service Contracts, the only one that is being cut in this proposed budget in the middle of a pandemic is the youth mental health contract for YCI. (PACCC, Avenidas and the Mediation services are all intact). This is not the time to be cutting funds from youth mental health services, see the article from this weekend's New York Times Magazine.     In recognition of important work done by YCI, Santa Clara County has already extended its share of the YCI contract in  2021‐22, the work of YCI is far from expired and the City of Palo Alto’s support for youth suicide prevent remains  essential.    According to Santa Clara Clara County’s Suicide Prevention 2019-20 Annual Report, compared to other age groups, youth (15-24 years old) have the highest rates of visits to the emergency room for suicide ideation or attempts. California Healthy Kids Survey (2019) reported 20% of students in 5th grade idicated they felt sad most or all of the time and about 33% of students in grades 7 and 11 indicated incapacitating sadness and 15% reported contemplating suicide.     These feelings of isolation both among youth and adults have only been exacerbated during the COVID-19 pandemic. Palo Alto must continue to invest in youth-led programming that offers “upstream” protective factors against rampant depression and isolation.     Thank you,    Mora Oommen  Executive Director   Youth Community Service      2019-20 Suicide Prevention Annual Report Reporting Period: July 2019-June 2020 COUNTY OF SANTA CLARA Behavioral Health Services Supporting Wellness and Recovery 1 Table of Contents Background 2 FY20 highlights by numbers 3 Suicide data and discussion 4 FY20 progress on program objectives • Objective 1: Increase early identification and support for people thinking about suicide • Objective 2: Increase use of mental health services • Objective 3: Strengthen community suicide prevention and response systems • Objective 4: Reduce access to lethal means • Objective 5: Improve messaging about suicide in the media 12 15 22 31 32 Conclusion and recommendations 34 Acknowledgments 36 Attachments 38 References 40 2 BACKGROUND Established in 2010, the Santa Clara County Suicide Prevention (SP) Program designs, implements, and evaluates population-based, public health approaches to reducing and preventing suicides. Suicide prevention in the County is guided by the County’s Suicide Prevention Strategic Plan, which was passed by the Board of Supervisors in 2010. The plan recommends the below five evidence-based public health strategies to guide a comprehensive community effort to prevent suicide. ● Strategy One: Implement and coordinate suicide intervention programs and services for high-risk populations ● Strategy Two: Implement a community education and information campaign to increase public awareness of suicide and suicide prevention ● Strategy Three: Develop local communication “best practices” to improve media coverage and public dialogue related to suicide ● Strategy Four: Implement a policy and governance advocacy initiative to promote systems change in suicide awareness and prevention ● Strategy Five: Establish a robust data collection and monitoring system to increase the scope and availability of suicide-related data and evaluate suicide prevention efforts The SP Program coordinates the Suicide Prevention Oversight Committee (SPOC) and five Workgroups, which are each tasked with supporting a different strategy of the County Suicide Prevention Strategic Plan: Interventions (Strategy One), Communications (Strategies Two and Three), Policy (Strategy Four), Data (Strategy Five), and the South County Suicide Prevention Workgroup (regional focus). SPOC oversees and approves the work of the Workgroups. This annual report covers the period of Fiscal Year 20: July 1, 2019 to June 30, 2020. 3 FY20 SUICIDE PREVENTION HIGHLIGHTS BY NUMBERS 11 school districts participating in the Schools for Suicide Prevention partnership 795 text conversations received over the County Crisis Text Line 1,281 community members reached with suicide prevention and mental health resources, through 30 community outreach events attended 3,670 people trained to be community helpers for suicide prevention and mental health 32,451 calls received by the Suicide and Crisis Services hotline 339,937 YouTube views of the “Benjamin” suicide prevention campaign for older adults 3,174,272 impressions of the social media campaign promoting Crisis Text Line, as a response to the COVID-19 pandemic 4 SUICIDE DATA AND DISCUSSION Suicide deaths: After a three-year decline from 2014-17 (155 in 2014, 149 in 2015, 134 in 2016, and 133 in 2017; see Figure 1), the County’s suicide count and rate increased to 148 deaths (7.6 per 100,000) in 2018. Initial analysis of 2019 suicide death data indicates that the increase continued last year, with 169 deaths (8.8 per 100,000, see Figure 1). The County’s suicide rate continues to be lower than the California state suicide rate, which was 10.9 per 100,000 in 2018 and which has increased each year since 2015 (2019 state suicide data is not yet available) (Centers for Disease Control and Prevention, 2020). Figure 1. 2015-2019 suicides in Santa Clara County As of August 2020, a comparison of suicide death counts indicates that suicide deaths did not increase during the COVID-19 pandemic. From January to August 2019, 113 suicide deaths occurred in the County, compared with 106 deaths during the same period in 2020. (Note that these numbers may increase for two reasons: 1. The Medical Examiner-Coroners’ Office still has pending cases for 2020, and 2. This data does not include suicide deaths of County residents occurring outside of the County; this data is captured by the state.) However, the initial death counts from 2020 suggest that the increases seen in 2018 and 2019 are sustaining in 2020, regardless of the COVID-19 pandemic. The Behavioral Health 149 134 133 148 169 7.77 6.98 6.95 7.63 8.76 0 20 40 60 80 100 120 140 160 180 2015 2016 2017 2018 2019 Count Per 100,000 -- --- ■ ■ 5 Services Department’s (BHSD’s) Decision Support team is in the process of analyzing the 2019 data, and the Suicide Prevention Data Workgroup is working on additional analyses to better understand the increase since 2018. Suicide attempts and ideation: Between 2014-17, the County’s suicide death rate saw a slight decrease. In contrast, the FY19 annual report shared that the suicide Emergency Department (ED) and hospitalization rate for attempts and ideation increased during the period of 2007-14. To better understand this increase, in FY20, the Data Workgroup conducted an in-depth review of the suicide attempt and ideation data that is available from the state’s Office of Statewide Health Planning and Development (OSHPD), through the County’s Public Health Department (PHD). As part of this review, the Data Workgroup examined suicide attempt and ideation data from 2014-17 (the same period as the noted decrease in deaths). The Data Workgroup also determined what additional data and analyses could help to understand the increase during this period. These analyses can be organized around three main research questions: 1. Why did a suicide attempt occur (e.g., from where were suicidal individuals brought to the ED; what mental and physical health diagnoses did individuals present with)? 2. What occurred during the suicidal individuals’ stay in the ED (e.g., were the length of stays appropriate; what type of care was assigned)? and 3. What occurred after the ED visit (e.g., where were individuals discharged to)? The Data Workgroup also requested analyses of these three research questions disaggregated by cultural/demographic variables. In January 2020, the PHD presented the initial suicide attempt data analysis to the Data Workgroup, using 2013-17 data. This analysis included counts and rates of ED visits and hospitalization rates for suicide attempts or ideation, disaggregated by the demographic variables sex, age, and race/ethnicity. During 2014-17, the overall ED visit rate for suicide attempts stayed relatively flat (see Figure 2). The increase in ED visits was attributed to an increased number and rate of visits for suicidal ideation (see Figure 2). Past increases in suicide attempts in the 2007-14 period may be consistent with the increase in suicide ideation rates from 2014-17. Literature has long shown that the history of a previous attempt is the strongest predictor for future suicidal behavior, including ideation (Beautrais, 2004). The increased rate may also be attributed to increased disclosure 6 by/identification of community members thinking about suicide, or increased reliance on the ED as a response to suicidal ideation. The Data Workgroup’s additional analysis will seek to better understand the driving factors behind the increase in ED visits for suicidal ideation. Figure 2. Emergency department visits for suicide attempt and ideation, 2013-17 "' ... ·;;; ·s: 0 w -0 ai s:, E ::, z Number and age-adjusted rate of ED Visits for suicide attempt/self-harm, 2013-2017 1200 1000 800 600 400 200 0 2013 2014 2015 2016 2017 Note: In coch orooh above, the colored baN rcprc::,c,,,1 the number ond the blodc line reor~eM~ lhc aoc-,odl1ntecl r01c per I 00,000 oeo!lk. 70 60 <11 C. 0 50 ~ 0 40 8 o' 30 S ai 20 c. 21 "' 10 a: 0 Number and age-adjusted rate of ED Visits for suicide ideation harm, 2013-2017 :! ·;;; 3000 2500 ·;: 2000 0 w 0 1500 ~ 'e 1000 :> z 500 0 122.6 2013 2014 146.6 128.9 135.3 2015 2016 2017 Note: In coch groph ocbove, the colored baN rcprcl-C'l'II the number cand the blodc line reprelcnl~ lhc a9c-,odj1ntecl r01c per 100,000 people. 160 140., Q. 120 i Q. 100 g 0 80 o 0 60 ~ Q. 40 2! " 20 "' 0 7 After January 2020, the PHD’s work on this data analysis stopped short because of the pandemic and the PHD epidemiologists’ need to focus on COVID-19 data and disaster response. Through its partners at Palo Alto University (PAU), the Data Workgroup is now developing a proposal to the Institutional Review Board (IRB) to directly obtain suicide attempt data for analysis. Importantly, ED visits and hospitalizations do not represent all suicide attempts or ideation, but are indicative of more serious self-harm incidents. The Data Workgroup will also continue to pursue additional data sources for suicide attempts and ideation. County populations impacted by suicide Sex, age, and race/ethnicity (suicides among older white men): Men continue to die by suicide at higher rates than women (11.91 per 100,000 among men, compared with 3.25 per 100,000 among women, in 2018). While suicide rates among older adults decreased from 2014-2018, seniors 75 years and up still had the highest suicide rates in 2018 (12.81 per 100,000 for 75-84 years and 13.33 per 100,000 for 85+ years), compared with other age groups. From 2014-2018, the white/Caucasian population accounted for the largest number (445) of County suicide deaths, followed by the Asian (127) and Hispanic/Latinx (106) populations. In 2018, the white/Caucasian population had a suicide rate of 14.52 per 100,000, which was the second-highest rate after Pacific Islanders (67.00 per 100,000). The most common demographic patterns seen in County suicide deaths mirror national-level suicide data. The higher number of deaths among older white men has been attributed to a range of factors, including social norms around suicide and aging, and the suicide method used. These factors are further discussed below. Traditional cultural norms for masculine identity can translate into an unwillingness to seek behavioral health services and/or treatment among men (Suicide Prevention Resource Center, 2016). One report found that the most notable cultural belief among men is the belief that it is not “manly” to seek or receive treatment for mental health issues (U.S. Department of Health and Human Services, 2012). “Cultural expectation on gender roles limit males’ options when 8 faced with stress, crisis or loss, thus increasing their risk for self-endangering or self-harming behaviors” (Coleman, Kaplan, & Casey, 2011). Feelings of shame from not meeting gender role expectations can exacerbate the restriction of emotional expression, vulnerability, and help-seeking behaviors (Pollack, 2006). Chronic medical conditions begin developing as individuals enter their 40s and continue to increase with age (Blackwell, Lucas, & Clarke, 2014). In a study examining the association between major physical health issues and suicide, many conditions, such as back pain, sleep disorders, and traumatic brain injury, were all associated with suicide risk, with significantly increased risk in association with multiple chronic health conditions (Ahmedani et al., 2017). According to Schiff et al. (2015), “physical health conditions were one of four risk factors associated with suicides by men…who were not identified as having mental health or substance abuse problems, which provides some evidence that chronic medical conditions can contribute to suicide risk even in the absence of depression.” Research shows that helplessness and hopelessness about pain, more so chronic pain, and the desire to escape from pain are psychological processes that are crucial to understanding the relationship between suicidality and chronic pain (Tang & Crane, 2006). Of the County’s suicide decedents in 2018, 38.5% had reported physical health conditions at the time of their death, with hypertension and pain (e.g., from osteoporosis, arthritis, gout) as the most frequently reported conditions. (Only 13.5% of decedents had no known physical conditions, and 48% were unknown or not included in the death report.) Researchers suggest that higher suicide rates among white older men in the US cannot be attributed solely to adversities associated with aging, such as poor health, poverty, depression, and isolation. The primary rationale is that older men have less exposure to these aging adversities compared with older women, as do European Americans, compared with racial/ethnic minorities. Instead, a cultural perspective on the social meaning and permissibility of suicide has been used to help explain higher suicide rates among older white men. Some studies have shown that European Americans believe that suicide by older adults is more permissible than suicide by younger individuals, and that suicide is more reasonable or socially acceptable when it is a response to physical illness or disability (Canetto, 2020). According to Stice and Canetto (2008), “considering 9 that physical illness is more common among older adults than among young adults, cultural beliefs about the logic of suicide under condition of physical illness may be particularly meaningful and powerful as a prescription for older adults.” In addition, in the US, male suicide is largely viewed as a male act, and older male suicide, in particular, tends to be described as deliberate, if not rational (Canetto, 2020). These norms around suicide contrast with beliefs and norms about aging as being undignified and unmasculine. Canetto also found that among European Americans, male suicide in response to impersonal problems, such as illness, tends to be viewed more positively than suicide as a response to interpersonal problems. Suicide method (men and firearms): According to Harvard Means Matter, firearms are the most lethal and most common method of suicide in the U.S., and more people who die by suicide use a gun than all other methods combined. Among men aged 65 and older in the U.S., guns are the most common method of suicide, accounting for nearly 80% of such deaths (CDC, 2018). In Santa Clara County, the use of a firearm as the means for suicide increases with age, with about 50% of decedents 65 years and older using firearms as the means for suicide. Firearms are also the most common means for suicide among white/Caucasian decedents in the County (used in 40% of white/Caucasian suicides, from 2014-2018), and among male decedents (used in 38% of suicides, from 2007-2016, compared to 11% of female suicides). According to Kaplan, McFarland, and Huguet (2009), the male pattern of suicidality also includes impulsive attempts with lethal means, often while under the influence of a substance. Effect of Deaths with Dignity Statute: Deaths with dignity, or physician-assisted deaths, are not classified as suicides by the Medical Examiner-Coroners’ Office and therefore are not included in the suicide death data provided. City of residence (suicide rate of Los Gatos): In the period of 2007-16, the City of Los Gatos had the highest rate of suicide deaths (21.3 per 100,000) among the County’s cities (although 51% of suicide decedents in this period were from the City of San Jose). Research on the relationship between socioeconomic status and suicide is limited and has produced mixed and inconclusive results. While many studies find a higher risk for suicide among males with a lower education level and 10 occupations requiring lower skill levels, other studies either report the opposite effect or have not found this pattern at all (Fernquist, 1991-1994). However, Los Gatos’s suicide death rate could be attributed to a confluence of risk factors that are associated with the County’s highest number of suicide deaths, as discussed above. The City of Los Gatos has a majority white/Caucasian population (78.6% in 2018, according to the US Census Bureau), the highest percentage of white/Caucasian residents of cities in the County, and a relatively higher percentage of residents 65 years and older (18.8%). In addition, according to 2016 Public Health Department data, Los Gatos is among the five County cities with the highest percentage of adults reporting that they keep firearms in or around the home (23%). While the suicide rate of Los Gatos increased from 2012-15, in 2018, the city’s suicide rate was down to 6.5 per 100,000 (see Figure 3). Suicide data by city of residence was not available for years 2016-17, but the Data Workgroup will continue to track this trend in subsequent years. Figure 3. Suicide rates by city of residence, 2012-15 and 2018 Other cultural groups affected: In its work, the SP Program includes an equity and culturally competent focus on suicide prevention. For example, based on high rates Death Rate per 100,000 Lowest (0.00) Midpoint (10.0) Highest (20.0) Year City 2012 2013 2014 2015 2018 Campbell 7.60 -14.88 9.83 Data for years 2016 and 2017 had rnrious City of Cupertino 8.56 5.08 5.02 4.99 Residence labeled as ··unknown" and therefore could not Gilroy 6.14 14.07 5.91 11.62 8.51 be repo11ed on the heath map. Los Altos 13.73 6.81 3.36 0.00 5.12 Los Gatos 10.16 13.42 13.26 16.45 6.52 Milpitas 2.99 8.86 8.65 5.59 7.46 Monte Sereno 0.00 0.00 0.00 0.00 0. Morgan Hill 13.15 10.30 5.02 14.68 13.29 Mountain View 4.03 6.62 14.33 3.85 8.40 Palo Alto 12.40 13.80 9.09 15.04 7.50 San Jose 6.18 6.71 7.40 6.59 7.86 Santa Clara 10.32 5.94 11.71 6.59 4.63 Saratoga 9.98 6.59 6.53 6.49 13.07 Sunnyvale 12.05 9.07 6.85 6.75 7.18 Scuce US Census BIJeau. 2014-201L Amt. ~Corrw.dllfy Su'Y\.-y .,,.Ye.-L..mates Source. U.S. Census BIJeau, 2011-2015 AmencanCm'WTUlltySl.fvey 5-Year Estmates 15 Source US Census Bt.ftau, 2010-2014 Amencancanm.ntySt.wvty 5-Year Estmates Source U S Census Bt.weau. 2009-2013 5--Yeat Amencan Coom..nrty SUrYey Source. u S Census Bureau, 2006---2012 Amencan COmmu'llty St.wvey 11 of suicide among the Pacific Islander/Native Hawaiian community, despite its relatively smaller numbers in the County, in FY20, the Interventions Workgroup began exploring outreach to this community. In addition, in August 2020, the SP Program, in partnership with Palo Alto University and the Medical Examiner-Coroner’s Office, published a study in Death Studies journal, showing that hanging was the most common method for suicide among youth and non-white racial/ethnic groups in the County. In FY21, the SP Program intends to embark on ligature restriction in addition to its ongoing gun safety work (see Obj. 4). Importantly, different populations are affected by suicide attempts, compared with suicide deaths. More women attempt suicide than men in the County (200.9 visits per 100,000 for females, compared with 156.5 visits per 100,000 for males, in 2014), and youth ages 15-24 and African American residents have the highest rates of emergency department visits for suicide attempts and/or ideation, compared with other age and racial/ethnic groups in the County. See Obj. 3 for a description of the SP Program’s school-based youth suicide prevention partnership. The program is also supporting a number of initiatives specific to the African American population, such as cultural town halls on racial equity and mental health, and a resource on suicide and Black boys. 12 FY20 PROGRESS ON PROGRAM OBJECTIVES Objective 1: Increase early identification and support for people thinking about suicide Community helper trainings (Strategic Plan Strategy One) The SP Program offers eight community helper trainings in suicide prevention (see Figure 5). These trainings’ main goals are to teach participants how to identify the warning signs of suicide or a mental health crisis, and how to support and refer individuals in crisis to seek professional help. From July 2019 through June 2020, the program trained 3,670 community members and/or service providers through community helper trainings. The year’s training numbers were significantly impacted by COVID-19, as all in-person sessions were put on hold after shelter-in-place orders went into effect on March 16, 2020. The SP Program has pivoted its training offerings by providing four of the eight trainings virtually via Zoom. As part of ongoing cultural competency efforts with Palo Alto University (PAU), during FY20, the SP Program and PAU partners continued piloting the original Be Sensitive, Be Brave (BSBB) culturally competent training content. These trainings include introductions to mental health and suicide prevention and are tailored to address the training needs of the County’s diverse community members, as identified by the SP Program. The 11 pilot BSBB trainings hosted in FY20 solicited feedback from participants to support the refining of materials. Audiences included the general community and partners from NAMI FaithNet, Project Safety Net, and the allcove Youth Advisory Group. For FY21, the PAU team will transition from the piloting phase into expanding trainer bandwidth and supporting the growth of training offerings. In aggregate, across all trainings offered, participants reported statistically significant improvements in eight outcome measures related to knowledge, attitudes, and preparedness around being community helpers for suicide prevention (see Figure 4). Four of the outcomes showed an average and statistically significant increase of 0.9 points (on a five-point scale) from pre- to post-training. These outcomes included the following: 13 • I am aware of the resources necessary to refer someone in a suicide crisis; • I have the skills necessary to support or intervene with someone thinking about suicide; and • I feel prepared to help people from diverse cultural backgrounds with their suicidal distress. Figure 4. Change in community suicide prevention helper training measures, July 2019-June 2020 Pre- Training (N=1897- 2283) Post- Training (N=1117- 1206) Variables M SD M SD t-test Cohen’s d Effect size I know the warning signs for suicide. 3.55 .88 4.38 .71 -28.06*** -.90 Large I am able to identify someone who is at risk for making a suicide attempt. 3.36 .91 4.27 .76 -29.64*** -.94 Large I feel prepared to discuss with someone my concern about the signs of suicidal distress they are exhibiting. 3.41 .99 4.27 .76 -25.63*** -.86 Large I am aware of the resources necessary to refer someone in a suicide crisis. 3.34 1.00 4.34 .72 -30.88*** -.98 Large I am confident in my ability to make a referral for someone in a suicide crisis. 3.31 1.01 4.26 .78 -28.28*** -.91 Large I have the skills necessary to support or intervene with someone thinking about suicide. 3.18 1.01 4.17 .78 -29.75*** -.95 Large I understand and can identify a number of ways in which culture affects how suicide is expressed and experienced. 3.29 .96 4.06 .83 -23.56*** -.78 Medium I feel prepared to help people from diverse cultural backgrounds with their suicidal distress. 2.97 .98 3.94 .85 -28.28*** -.93 Large Mean Score, all 8 items 3.30 .76 4.22 .65 -35.57*** -1.08 Large Note. M=Mean. SD=Standard Deviation. Scores: 1=Strongly Disagree, 2=Disagree, 3=Neither disagree or agree; 4=Agree; 5=Strongly Agree. *** p < .001. Note re: interpretation tips: Any t-test value that has *** next to it is showing that there is a change that is more significant than chance. For example, we see that in “1. I know the warning signs for suicide” goes from an average 14 of 3.55 on the pre-survey (most people chose either 3=Neither disagree or agree to 4=Agree) to a 4.38 on the post- survey (most people chose 4=Agree to 5=Strongly agree) with a significant t-test value of -28.06 (meaning the change from 3.55 to 4.38 was significant enough that it is likely NOT due to chance). Note re: Cohen’s d: Small effect size if d .2, medium effect size if d .5, large effect size if d .8 (meaning 1 group scored .8 standard deviations above the other group) Figure 5. FY20 suicide prevention and mental health helper trainings Name Description Group(s) Trained in FY20 Number of Trainings Hosted Question, Persuade, Refer (QPR) Basic helper training teaching the QPR method of asking the suicide Question, Persuading the individual to get help, and Referring the individual to local resources. Law enforcement (CIT), college students (nursing, general education), school personnel, older adults, parks, and recreation staff 40 completed (in- person, virtual) Be Sensitive, Be Brave: Suicide Prevention Participants explore tailored content to define suicide, identify specific warning signs and how to talk about suicide with compassion to account for cultural differences. Youth advisory group (high school students), older adult faith group, general community 5 completed (in- person, virtual) Kognito At-Risk Simulated online conversations in grade-level specific modules on how to address mental health distress with students and parents. Elementary, middle, and high school educators and staff 10 school districts participated (1,612 staff trained) Applied Suicide Intervention Skills Training (ASIST) Two-day training involving intensive work on supporting suicidal individuals, in order for service providers like mental health professionals and nurses to better serve community members and support colleagues. Mental health professionals, school counselors, RNs, faith leaders, hospital staff, general community members 7 completed, 3 cancelled due to COVID-19 (April-June) Suicide to Hope Training is a follow-up to ASIST and focused on supporting clients using a growth and recovery model following suicide attempts. Mental health clinicians (school and community partners) 1 completed, 1 cancelled due to COVID-19 (May) SP201: Suicide Prevention and Clinical Management for Diverse Clientele Participants learn to assess suicide risk, safety plan, case conceptualize, and treatment plan for managing suicide risk in diverse populations. Behavioral Health Services Department clinicians 2 completed (in- person, virtual) Youth Mental Health First Aid Training includes an overview of risk factors and warning signs for common mental health challenges and teaches a 5-step mental health action plan to help youth in both crisis and non-crisis situations. Youth-serving community members, school staff and mental health leads, 4 completed, 2 cancelled due to COVID-19 15 Be Sensitive, Be Brave: Mental Health Participants learn to define mental health, identify signs of mental distress and mental health resources, and how culture and diversity affect mental health. Youth advisory group (high school students), parents, faith community, general community 6 completed (in- person, online) Objective 2: Increase use of mental health services In FY20, the SP Program and Data Workgroup worked to improve the evaluation of this objective in a couple of ways. First, the SP Program completed the contracting process to engage an agency to evaluate annual suicide prevention public awareness campaigns. Second, the Data Workgroup partnered with the PHD on their annual Behavioral Risk Factor Surveillance Survey (BRFSS). The Data Workgroup collaborated with PHD epidemiologists to design the BRFSS Behavioral Health Module, to include questions about knowledge and use of County mental health services, as well as help-seeking behaviors for mental health and suicidality. This survey was conducted at the end of 2019, with 1,030 respondents. The PHD began to analyze the results in January 2020, but these efforts stalled due to COVID-19. The Data Workgroup confirmed with the PHD that BRFSS data could not be transferred to another organization to complete the analysis. Community education and information (Strategic Plan Strategy Two) In FY20, the SP Program’s Communications Workgroup planned, developed, launched, and evaluated a mass media campaign to support suicide prevention among older adults in the County. The campaign’s primary objectives for the older adult population were to improve knowledge of suicide prevention resources; to improve attitudes toward seeking help for suicide; to increase help-seeking behavior through suicide prevention resource utilization; and to increase community awareness of older adults struggling with their mental health and suicide ideation. 16 The campaign ran from July 9, 2019 to October 21, 2019 and was comprised of print materials and radio, digital (online), and social media advertisements. These assets promoted the County Suicide and Crisis Hotline and a campaign-specific web page, www.scchope.org, designed to address the campaign objectives. The campaign’s reach data are included in the table below (see Figure 6). According to US Census Bureau estimates (2018), 116,329 male adults aged 65 and older reside in Santa Clara County. Figure 6. “Benjamin” older adult campaign reach and impressions Medium (Campaign Ad Run Dates) Metric Campaign Website Visits Attributed Digital (7/12 – 10/21) 4,862,357 impressions 2,628 YouTube Ad (7/17 – 9/14) 1,642,509 impressions 3,451 339,937 full video views Facebooka (7/17 – 9/28) 723 individuals reached NT Radio (7/9 – 9/18) 792,200 individuals reached 2,884b Print (7/19 – 8/16) 49,500c individuals reached NT a. Unpaid, organic posts from County account made 1-2 times per week during the campaign b. Determined by the number of visits occurring within an 8-minute time window of the ad airing c. Total weekly readership for print media in which campaign ads appeared NT Not Tracked To assess the impact of the campaign, calls to the Suicide and Crisis Hotline during the campaign months July, August, and September in 2019 were compared to the same months in 2018. This three-month span in 2019 showed a total increase of 268 calls to the hotline, compared to the same period in 2018. Furthermore, the HAVING SUICIDAL THOUGHTS? Let's talk about it. Call the Suicide & Crisis Hotline: 1-855-278-4204 Available 24/7 I Free and confidential I scchope.org 17 share of 2019 hotline calls made by the target audience (age 55 and older) was far greater than the respective proportion in 2018. The percentage of calls to the hotline by adults age 55 and older increased from 22.2% in July 2018 to 30.2% in July 2019; from 16.5% in August 2018 to 28.9% in August 2019; and from 19.7% in September 2018 to 30.0% in September 2019. This increase in hotline utilization indicates a strong campaign impact and increased help-seeking behavior among the target audience. Additionally, from August 1, 2019 to September 26, 2019, the campaign website received 12,693 visits and 13,563 page views, reflecting wide reach and receptivity to seeking help online. In addition to public awareness campaigns, the SP Program offers two trainings: Youth Mental Health First Aid and Be Sensitive, Be Brave: Mental Health (see Figure 5), both designed to educate and reduce stigma about mental health. In FY20, the SP Program trained 157 community members and providers in these two trainings. Community outreach in FY20 focused on reaching transitional-aged youth (16-25), middle- aged adults (45-55), and older adults (65+). Activities included tabling (photo, left), resource fairs, partnership-building with community-based organizations and colleges, and expanding the volunteer program. Due to COVID-19, several tabling events were cancelled, as well as the second annual Santa Clara County Suicide Prevention Conference, scheduled for May 2020. The SP Program pivoted its community outreach efforts by transitioning to virtual events and outreach phone calls. ● 30 tabling events attended ● 1,281 people reached with resources through tabling events ● 1 mental health resource fair hosted at Eastridge Mall in September 2019, for Suicide Prevention Month ● 5 volunteers recruited and onboarded to support community outreach efforts (bringing the SP Program’s volunteer base to 11 individuals) ● Outreach materials updated and translated: 18 ○ Mental health guide for immigrants brochure, (see Attachment 1) ○ Handout on LGBTQ+ mental health and suicide prevention resources (see Attachment 2) ● 54 outreach phone calls made to local skilled nursing facilities, offering suicide prevention resources and trainings ● 11 virtual town halls held with different cultural communities, on the topic of mental health and COVID-19, during May’s Mental Health Awareness Month. The town halls reached at least 470 individuals live and the recordings have had more than 2,200 views on the Behavioral Health Services Department’s Facebook page. Cultural groups reached include Chinese, Korean, Nepali, Hispanic/Latinx, Vietnamese, Indian, and the LGBTQ+ and youth communities. Suicide and crisis services (Strategic Plan Strategy One) Crisis Text Line (CTL): The County BHSD partners with CTL, a free crisis intervention service via SMS message, where roughly 75% of users nationally are under age 25 (crisistrends.org). Community members may text RENEW to the national CTL number, 741741, to access trained volunteer crisis counselors via text message (free, 24/7, anonymous). In FY20, 795 text conversations by 630 texters took place under the County’s CTL. Large increases in CTL usage were seen in August 2019, when the shooting at the Gilroy Garlic Festival occurred (173 conversations), and in March 2020, when the COVID-19 shelter-in- place order initially took effect (171 conversations, see Figure 7). The increases in usage lowered but remained higher-than-average in April through June 2020 (76, 68, and 61 conversations, respectively). 19 Figure 7. FY20 volume of Crisis Text Line conversations, by month The top issues discussed on the County CTL were anxiety/stress, relationships, depression/sadness, school, and COVID-19 (see Figure 8). The CTL reaches a larger percentage of cultural minorities compared with their representation in the County. For example, in FY20, 47.4% of texters reported being of Hispanic, Latinx, or Spanish origin; 55.3% reported being LGBTQ+; and 23.8% reported having Attention Deficit Disorder (ADD) or Attention Deficit Hyperactivity Disorder (ADHD). In terms of age, 32.5% of texters reported being age 17 or younger, while 47.5% reported being age 18-34. Figure 8. Top issues discussed on County Crisis Text Line, in FY20 Issue % of conversations Issue % of conversations Anxiety/Stress 44.1% Sexual Assault(*) 3.6% Relationship 33.8% Grief 3.2% Depression/Sadness 28.0% Bullying 2.5% School(*) 26.0% Abuse, physical 2.1% COVID-19 24.7% Social Media(*) 1.9% Isolation/Loneliness 18.9% Abuse, sexual 1.1% Suicide 15.2% Eating Body Image 0.5% 3rd Party 5.1% Gender Sexual Identity 0.5% Self Harm 5.1% Deaf/Hard of hearing 0.0% Vo lume: By Month 180 160 140 ~ 2 120 X ~ ---100 Vl C ~ ro 80 Vl L.. "' > C 60 0 u 40 20 0 Jul ·19 Sep ·19 Nov"19 • Conversations • Active Rescues Jan ·20 Mar"20 May "20 1.2 0.8 )> ~ :c· Cl) 0.6 ;u Cl) 0.4 0.2 -0 "' n C Cl) "' 20 Finances(*) 5.0% Abuse, unspecified 0.0% Abuse, emotional 4.6% Military(*) 0.0% Substance Abuse 3.9% As a response to COVID-19 and the increase in CTL conversations, the Communications Workgroup executed a social media campaign promoting CTL. The campaign targeted County youth and young adults who had family members who were healthcare workers; who had lost relatives due to COVID-19; and/or who had suffered economic hardship. Airing from June 12 to July 10, 2020, the social media campaign (ads, below) created 3.1 million impressions through mobile banner ads, Facebook, Instagram, Snapchat, and YouTube. Suicide and Crisis Hotline (Strategic Plan Strategy One) Run by Suicide and Crisis Services (SACS), the Suicide and Crisis Hotline received a total of 32,451 calls from July 1, 2019-June 30, 2020 (see Figure 9). This number represents a 29.5% increase from the 25,067 calls received in FY19. The increase is attributed to increased staffing on the hotline. The SACS team was able to recruit more volunteers to answer calls on the hotline in FY20; in addition, the state allocated funds to enhance staffing capacity in answering National Suicide Prevention Lifeline calls, which are routed through local hotlines, including Santa Clara County’s. 21 There was no significant change in SACS call volume due to COVID-19. However, many callers expressed high levels of anxiety due to many uncertainties. Most issues and concerns shared during the calls were related to the rapid spread of COVID-19, job loss and financial losses, and relationship issues and uncertainties due to the shelter-in-place order. Figure 9: SACS hotline call volume, FY20 CRISIS CALLS JU L AU G SE P T OC T NO V DE C JA N FE B MA R AP R MA Y JU N TO T A L Suicide in Progress 1 5 3 0 2 1 3 0 2 1 4 3 25 High Risk 18 14 36 20 22 21 39 15 31 16 11 21 264 Medium Risk 123 85 107 126 116 86 111 100 92 87 60 81 1,174 Low Risk 1,338 975 1,150 1,299 1,167 1,031 1,017 1,032 1,175 1,188 1,732 1,566 14,670 NON-CRISIS CALLS JU L AU G SE P T OC T NO V DE C JA N FE B MA R AP R MA Y JU N TO T A L No Risk of Suicide but need Support 1,538 1,080 1,649 1,758 1,632 958 1,412 1,377 1,260 778 1,264 1,135 15,841 Informational (Triage, Misc) 54 45 37 33 37 22 33 32 23 16 75 70 477 Total 3,072 2,204 2,982 3,236 2,976 2,119 2,615 2,556 2,583 2,086 3,146 2,876 32,451 Definitions Suicide in Progress: Caller is engaging in suicidal behavior High Risk: Caller has a past history of a suicide attempt, currently has suicide ideation. He/she is able to describe a plan and access to mean to killing oneself Medium Risk: Caller has a past history of a suicide attempt. Currently not suicidal but is depressed. Low Risk: Caller has no history suicide attempt, currently not suicidal, has a history of mental health treatment/services and needs support No Risk of Suicide but need support: Caller has no history of suicide attempt, currently not suicidal, no history of mental health services but needs support Informational/triage/misc: called for information and referrals to community resources In FY20, 31 unduplicated clients participated in the Survivors of Suicide (SOS) support group, which convenes weekly in San Jose. The last SOS support group 22 was held on March 2, 2020 due to the COVID-19 pandemic. In addition, Suicide and Crisis Services’ (SACS’) Emergency Department (ED) Patient Support Program provides face-to-face contacts with patients who received medical treatment at the ED of Santa Clara Valley Medical Center (VMC) due to self-harm injuries/behaviors or suicide attempts. In FY20, SACS staff made initial contacts and provided follow-up services to 55 individual clients at VMC’s Emergency Department. SACS staff has not been able to see clients at VMC’s Emergency Department since Shelter-in-Place mid-March this year. Objective 3: Strengthen community suicide prevention and response systems Schools for Suicide Prevention (S4SP) partnership (Strategic Plan Strategies One, Four) State policies AB2246 and AB1767 mandate that public schools serving grades K- 12 adopt policies addressing suicide prevention, crisis response, and student mental health. The SP Program launched the first year of the school-based suicide prevention partnership in 2018 as a response to a needs assessment conducted with districts on their progress with implementing these policies. In FY20, the SP Program kicked off the second year of the partnership, named it Schools for Suicide Prevention (S4SP), and expanded district participation to include five additional districts (see Figure 10). Figure 10. School districts participating in S4SP partnership Pilot Year (2018-2019) Year 2 (2019-2020) * new districts • Alum Rock Union • Santa Clara Unified • Mountain View Whisman • Los Gatos-Saratoga High School District • Santa Clara County Office of Education (SCCOE) Alternative Education • Milpitas Unified • Morgan Hill Unified • Santa Clara Unified • Mountain View Whisman • Los Gatos-Saratoga High School District • SCCOE Alternative Education • Milpitas Unified • Morgan Hill Unified • Los Gatos Union * • SCCOE Special Education * • Sunnyvale Elementary * • East Side High School Union (+ Escuela Popular Charter)* • Palo Alto Unified * 23 The S4SP partnership encourages school districts to follow a comprehensive, tiered approach to trainings in suicide prevention and mental health (see Figure 11), also known in the education field as Multi-Tiered Systems of Support (MTSS). This approach ensures that school personnel and mental health professionals (Tiers 2 and 3) are first trained to handle referrals of students who may be struggling with suicide, because student referrals tend to increase after students and families have received training (Tier 1, see Figure 11). As a result, the first two years of S4SP participation emphasize development among school staff of skills to identify and manage warning signs of student mental health crises. Figure 11. Multi-Tiered Systems of Support approach to school-based suicide prevention efforts The SP Program provides trainings appropriate for each tier of work. The main helper training for Tier 2 work is the Kognito online health simulation trainings, which the SP Program offers through a cost-sharing arrangement with the County Office of Education and each participating school district. TIERED APPROACH TO SUICIDE PREVENTION AND MENTAL HEALTH TRAIN INGS Focus of partnership years 1-2 + HEARD Alliance crisis protocol work Tier 3: Crisis Response Mental health professionals/counselors Example trainings: Su icide to Hope, niversal/Preventio arents and students ASIST m Youth Mental Health Fir "d, ore than Sad, Break Free from Depression 24 In the 2019-20 academic year, more than 1,600 school staff were trained in online Kognito modules. Completed simulations included the Kognito “At Risk” and “Trauma-Informed Practices” (screenshot, left) modules, which allow users to practice simulated conversations about mental health with students and parents. In two years of the partnership, nearly 4,000 teachers and staff have been trained in Kognito, in 12 County school districts. Pre-, post-, and follow-up training survey results from the Kognito At-Risk online training indicated statistically significant differences in respondents’ preparedness to support students with psychological distress (see Figure 12). School staff who took the training reported more preparedness and confidence to recognize signs of psychological distress, and to support the student through discussion and referral to mental health services. Figure 12. Mean preparedness and self-efficacy measures reported by users of Kognito At-Risk online training (for elementary, middle, high school educators) Combined preparedness measures Mean Std. Deviation F-value Post hoc tests Pre 3.23 .69 34.99*** All are significantly different from each other Post 4.08 .61 Follow Up 3.75 .71 Notes. 5-point scale. Combined 5 measures. Sample measures: How would you rate your preparedness to: Recognize when a student is showing signs of psychological distress; Discuss with a student your concern about the signs of psychological distress they are exhibiting; Recommend mental health support services to a student exhibiting signs of psychological distress Combined self-efficacy measures Mean Std. Deviation F-value Post hoc tests Pre 3.01 .59 6.99** Pre and post are significantly different Post 3.36 .54 Follow Up 3.16 .44 Dialogue Options Coaching Feedback Engagement Meter 25 Notes. 4-point scale. Combined 5 measures. Sample measures: I feel confident in my ability to: Discuss my concern with a student exhibiting signs of psychological distress; Recommend mental health support services to a student exhibiting signs of psychological distress; Help a suicidal student seek help Pre-, post-, and follow-up training survey results from the Kognito Trauma- informed online training indicated statistically significant differences in respondents’ confidence in supporting students with psychological trauma or distress (see Figure 13). School staff who took the training reported more confidence in their ability to recognize signs of psychological trauma or distress; to support the student through discussion and referral to mental health services; and to implement trauma-informed approaches in their teaching. Figure 13. Self-efficacy measures reported by users of Kognito Trauma-informed online training Pre-Test Mean (SD) Post-Test Mean (SD) Follow -Up Mean (SD) ANOVA F-test Post hoc Self-Efficacy: I feel confident… I feel confident in my ability to recognize when a student is showing signs of psychological trauma or distress 3.54 (.92) 4.03 (.69) 3.98 (.70) 16.20*** Pre is sig diff than post and follow up I feel confident in my ability to discuss with a student my concern about the signs of psychological trauma or distress they are exhibiting 3.44 (.81) 4.00 (.71) 3.92 (.72) 21.95*** Pre is sig diff than post and follow up I feel confident in my ability to motivate students exhibiting signs of psychological trauma or distress to seek help 3.48 (.81) 4.01 (.68) 3.88 (.77) 15.95*** Pre is sig diff than post and follow up I feel confident in my ability to use communication strategies to help a student exhibiting signs of psychological trauma or distress feel safe 3.51 (.78) 4.00 (.69) 3.86 (.73) 14.70*** Pre is sig diff than post and follow up I feel confident in my ability to teach students activities to manage their stress and emotions 3.43 (.91) 3.81 (.79) 3.72 (.81) 7.85** Pre is sig diff than post and follow up 26 I feel confident in my ability to implement trauma informed approaches in teaching 3.23 (.89) 3.83 (.79) 3.55 (.83) 17.48*** All sig diff Composite Self-Efficacy 3.44 (.74) 3.95 (.65) 3.82 (.68) 24.25*** Pre is sig diff than post and follow up Note. Items were on a 4-point scale. * p < .05, ** p < .01*** p < .001 Post hoc tests were conducted with a Bonferroni adjustment. N=64-65 While rolling out a variety of mental health trainings, districts also focus on aligning suicide and crisis response forms and protocols, with technical support from Stanford University’s HEARD Alliance. Districts must complete this crisis response work before moving on to Tier 1 prevention measures, and crisis response work may require more than one school year to fulfill. In FY20, ongoing assistance from the HEARD Alliance included reviewing existing protocols and procedures, advising on the formation of crisis response teams at each school site, and piloting parent education on mental health and suicide prevention. In FY20, the HEARD Alliance team completed more than 30 consultations with administrators and staff from all 11 participating districts. District progress on the partnership goals is summarized below (see Figure 14). Figure 14. School district progress on S4SP goals/tasks District goals/tasks, Year 1 of partnership Intervention: Establish a crisis response system Number of districts completed or status  Train all teachers and staff in the Kognito “At Risk” module 3 of 5 new districts; extension provided for 1 district  Identify and put together Crisis Response Teams (CRT) 9 of 11 districts As a result of its work with the HEARD Alliance under the S4SP partnership, Los Gatos Union School District developed the “Blue Folder Initiative,” a quick-reference compendium of mental health protocols and resources for district staff. 27  Send CRT members/mental health staff to ASIST Ongoing participation by district staff and administrators  Review crisis response protocol forms against K-12 Toolkit forms 10 of 11 districts  Revise/adapt/develop crisis response protocol forms 9 of 11  Train CRT members and all mental health staff in crisis response protocol forms 5 of 11 districts; others in progress  Begin using updated protocol forms in live situations with students 4 of 11 districts; others pending protocol training in FY21 District goals/tasks, Year 2 of partnership Mental Health Promotion: Integrate upstream and/or Tier 1 (parent/student) trainings Number of districts completed or status  Train any new teachers and staff in Kognito “At Risk” 5 of 6 continuing districts  Ensure Year 1 tasks are completed and any new mental health staff are trained in new protocol forms 5 of 6 continuing districts engaged with rollover work from Year 1 tasks  Train all teachers/staff in upstream Kognito training (e.g., Trauma-Informed Practices) 5 of 6 continuing districts  Integrate student Kognito training (e.g., Friend 2 Friend) Extension provided for 2 districts  Develop/introduce parent education series in mental health and suicide prevention (e.g., BSBB Mental Health, Youth Mental Health First Aid, workshops, panels) 1 district The SP Program’s conference abstract proposal titled “Preventing Youth Suicides: A multi-sector school-based partnership” was accepted for a workshop at the American Association of Suicidology’s 2020 Annual Conference in Portland, OR. Due to COVID-19, the conference presentation took place virtually to more than 60 participants in April 2020. The presentation highlighted steps to developing the S4SP partnership and tips to support the advancement of public/private partnerships to address youth suicide prevention. Engaging with health systems (Strategic Plan Strategy One) Conducted in FY19, a process evaluation of the SP Program included a recommendation to expand the SP Program’s work “downstream” to include an additional focus on clinical interventions for suicide. Health care and behavioral health systems play an important role in suicide prevention, both in terms of identifying and treating individuals at risk. Older adults, in particular, may not have mental health providers but are likely to be seeing doctors for physical health conditions on a regular basis. Among older adults who die by suicide, approximately 77% see a primary care provider within their last year of life, and 58% do so within their last month of life (Luoma, Martin & Pearson, 2002). 28 Furthermore, The Joint Commission adopted a National Patient Safety Goal on Suicide Prevention in Healthcare Settings, effective July 1, 2019. In FY20, the SP Program began to engage with the Santa Clara County Health and Hospital System on suicide prevention efforts. In partnership with PAU, the SP Program piloted the clinical training, “Suicide Prevention 201: Advancing Suicide Prevention and Clinical Management for Diverse Clientele” with 98 BHSD clinicians and managers. In addition, the SP Program took initial meetings with primary care staff at Valley Medical Center (VMC) to discuss the best ways to engage with VMC clinics on suicide prevention efforts. City-level collaborations (Strategic Plan Strategy Four) San Jose: In FY19-20, the SP Policy Workgroup continued to advocate for the passage of a suicide prevention policy by the City of San Jose. City Council unanimously passed the policy on March 3, 2020 (photo, left). The policy was intended to resemble a similar policy from the City of Palo Alto, as well as the County's Suicide Prevention Strategic Plan. Under the new policy, the City of San Jose will: • inform its current and former employees of prevention and identification methods; • ensure that public safety response protocols to suicide attempts on City facilities are updated; • collaborate with the County of Santa Clara to promote suicide awareness and prevention events and resources; and • coordinate with outside agencies to increase awareness of and reduce deaths by suicide. San Jose joins six other cities in the County—Morgan Hill, Sunnyvale, Milpitas, Palo Alto, Mountain View, and Los Gatos—that have adopted suicide prevention policies, all with the support of the SP Policy Workgroup. 29 Milpitas: Following the passage of a city suicide prevention policy in 2018, the city of Milpitas established a suicide prevention task force called HOPE (Helping Others Process Emotions) and began offering suicide prevention trainings for Milpitas city staff and residents. The task force, which meets monthly, includes Milpitas community members, local faith community leaders, the Milpitas Vice Mayor, various city officials, and representatives from Milpitas Unified School District, National Alliance on Mental Illness (NAMI), Counseling and Support Services for Youth (CASSY), Kaiser Permanente, and Child Advocates of Silicon Valley, as well as a Coordinator from the SP Program. In the reporting period, the task force expanded its suicide prevention efforts through increased community outreach and event promotion, in addition to its continued offering of suicide prevention gatekeeper trainings. The task force’s FY20 accomplishments are as follows: • Established task force goals to guide concrete prevention efforts; • Held gatekeeper trainings for the local Milpitas community; • Created a tentative marketing plan to effectively target quarterly prevention work to specific city populations based on suicide death data; • Reviewed suicide data and selected target populations for the work: Populations chosen were veterans and first responders, teens and young adults, seniors and those bereaved by suicide, and LGBTQ+ and cultural minorities; • Proposed specific activities in each quarter to address each respective population selected, and drafted marketing language to promote prevention activities for each quarter; • Established and sustained strong social media presence through promoting its prevention efforts along with other County efforts; • Evaluated Milpitas city protocols on communication with family and next- of-kin of suicide decedent in order to better support those affected by a suicide death; • Engaged with County partners to find new task force members, particularly from the LGBTQ+ community, to ensure cultural competency in its work. Palo Alto: The SP Program supports and collaborates with Project Safety Net (PSN) on youth suicide prevention efforts in Palo Alto. The SP Program 30 participates on PSN’s Leadership Team, and PSN’s Executive Director participates on the County’s Suicide Prevention Oversight Committee. In FY20, the SP Program collaborated with PSN and Palo Alto partners on outreach and helper trainings. South County: The South County Suicide Prevention Workgroup formed in September 2017 in response to the EpiAid report on youth suicides, which found that Morgan Hill had the second-highest rate of youth suicides in the County. In FY20, the workgroup was co-chaired by the Suicide Prevention Manager and Morgan Hill Police Chief (MHPD) (until April 2020). The departure of MHPD Chief Swing led to a transition in roles within the workgroup. His replacement is Community Solutions Division Director Marianne Marafino, with continued co- chairing support from the Suicide Prevention Manager and Coordinator. Examples of the workgroup’s FY20 accomplishments follow: ● Held gatekeeper trainings for youth-serving organizations in South County (e.g., Community Solutions, Morgan Hill Unified, Morgan Hill Community Services); ● Continued improvements to mental health continuum of care for youth: Supported Morgan Hill Unified in strengthening suicide crisis response system through Kognito/HEARD Alliance partnership; ● Gathered and reviewed multiple sources of data to identify risk and protective factors for suicide and guide workgroup’s strategies (e.g., EpiAid, Project Cornerstone Developmental Assets, 5150 trend reports from Community Solutions and Morgan Hill PD); ● To address Coroner data identifying middle-aged men as a high-risk population, a subgroup was formed to engage the faith community as the entry point for mental health conversations. With the goal of promoting mental health discussions and stigma reduction, the faith subgroup created talking points to support interfaith leaders. Representation in the subgroup included members from County Suicide Prevention, Morgan Hill Police Department, Community Solutions, NAMI Faithnet, Morgan Hill Bible, and West Hills Community Church; ● Morgan Hill and Gilroy Police Departments met with law enforcement liaisons and Mobile Crisis Response Team manager(s) to discuss aligning 31 protocols when seeking support during mental health crises and opportunities to test how this strategy looks during a call; ● In response to shelter-in-place, the workgroup pivoted from a review of all local services and developed a time-sensitive COVID-19 Resources and Services one-pager. Objective 4: Reduce access to lethal means Gun safety (Strategic Plan Strategies Two, Four) Firearms are the second most used means for suicide in the County and the most lethal means overall. The SP Program participates in the County’s Gun Safety and Violence Prevention (GSVP) team, which is a workgroup of the Public Health Department’s (PHD’s) PEACE Partnership for violence prevention and community safety in East San Jose. Other GSVP participating agencies include the District Attorney’s Office, PHD, and the City of San Jose. The GSVP team stopped meeting in early 2020 as the PEACE Partnership and PHD focused its work entirely on the COVID-19 pandemic. In the first half of FY20, the SP Program supported gun safety efforts in the following ways: ● Gave out gun safety brochure at outreach events and trainings; ● Incorporated information about the Gun Violence Restraining Order at community suicide prevention trainings; ● With the GSVP team, distributed approximately 500 suicide prevention outreach materials and free gun locks at two gun buyback events in Gilroy (December 2019) and in Sunnyvale (February 2019); ● With the Communications Workgroup, designed focus groups with gun owners to gather information to develop a gun safety/safe storage public awareness campaign in FY21. Ligature restriction (Strategic Plan Strategy One) Since 2018, hanging has exceeded firearms as the most common method of suicide in the County, representing 38.5% of suicides in 2018 and 29.6% in 2019. Hanging is also the most common method for suicide among youth and non-white racial/ethnic minorities in the County. The SP Data Workgroup and Oversight 32 Committee’s recommendations from the 2018 data report include adding a focus on ligature restriction, which is an area of suicide prevention that is not well- researched or understood, particularly with regard to community interventions. The SP Program will embark on this effort in FY21. Objective 5: Improve messaging about suicide in the media (Strategic Plan Strategy 3) The volume and content of media coverage on suicides can influence suicidal behavior, depending on how well the media adheres to safe messaging guidelines for reporting on suicide. These guidelines were created by national suicide prevention and media groups to help inform reporters on how to safely report on suicide. The SP Communications Workgroup takes on a range of efforts to monitor and improve safe messaging in the media, described in the below sections. To evaluate the progress of these efforts, since 2018, the SP Program has been developing a safe messaging assessment tool that rates articles and publications on their adherence to the safe messaging guidelines. In 2018, the SP Program used the assessment tool to conduct a baseline media analysis study, which evaluated how well local and national media adhered to the safe messaging guidelines in the wake of two high-profile celebrity suicides. In FY20, the SP Program formed a partnership with Stanford University’s Center for Youth Mental Health and Wellbeing and Palo Alto University to revise and strengthen the safe messaging assessment tool, as well as publish the tool and disseminate it in various formats with the media and suicide prevention fields. The results of this collaboration will allow for more targeted work with the media by the Communications Workgroup; drive more accurate evaluation of the SP Program’s work with the media; and ~ COVID-1 'J's mental health crisis: Bay Area ... COVID-19's mental health crisis: Bay Area residents feel growing psychological toll 0 0 .. ~ Social isolation.job losses.civil unrest.an uncertain future: People around the region are reporting increasing anxiety and depression Oo .. ~ 33 allow other media and suicide prevention professionals to clearly assess the media and evaluate their own efforts with safe messaging. News media monitoring and response In 2019, the SP Program continued to systematically track and respond to local media coverage on suicide, working with the Communications Workgroup as a Media Response Team. Through weekly monitoring of the media, in FY20, the SP Program reviewed 90 local articles on suicide and responded to reporters of 17 of these articles, either reminding them about the safe messaging guidelines (example, left) or thanking them for following the guidelines. Media education and relationship-building The SP Program works directly with the media by providing trainings and education about safe messaging, and by providing safe content on suicide prevention through interviews and press releases about the program’s work. In the reporting period, Communications Workgroup members conducted interviews and/or provided information about mental health or suicide prevention for 18 local media stories. In 2019, the SP Program’s Communications Workgroup opted to begin making presentations to individual newsrooms about safe messaging, instead of holding annual trainings, which were a larger investment and traditionally not well- attended by media staff. In FY20, as a result of the City of San Jose’s passage of a suicide prevention policy, a safe messaging meeting/training was arranged with San Jose City Public Information Officers. The meeting was postponed due to the onset of the COVID-19 pandemic. Discussions to virtually conduct this meeting began again in FY21. HOME > STANFORD > Stanford says employee who killed himself hadn't been fired Stanford says employee who killed himself hadn't been fired 0 December 9, 2019 7:00 am 34 CONCLUSION AND RECOMMENDATIONS During the reporting period, the SP Program grew in the six strategic areas that were proposed in the 2017 and 2018 annual reports. The six areas are listed below, along with recommendations/goals to progress further in each of the areas in FY21. a) Grow and strengthen the program to be able to better and more comprehensively serve the population across the lifespan. • Deepen efforts with older adults, for example, by working with primary care providers and faith-based organizations. • In response to rising rates, explore ways to engage with middle-aged adults in suicide prevention. b) Continue to support efforts to strengthen services and the continuum of care as related to suicide. • Increase the number of clinicians trained to provide grief support following suicide loss. • Engage with clinicians in suicide prevention through trainings and consultations, particularly within the County’s Health System. c) Increase primary prevention efforts by incorporating upstream, public health strategies that focus on building resilience factors and on improving environmental factors. • Build upon the school-based suicide prevention partnership by engaging with school districts on implementing social-emotional learning. • Add promoting social connectedness as an outcome objective (plus related activities) in the SP Program’s logic model. • Explore ligature means restriction for hangings, which are the top means used for suicide in the County. d) Focus on sustainability of efforts, namely through capacity-building for SP. • Continue building the SP Program volunteer base and stakeholder participation in Workgroups in order to increase community participation in suicide prevention. 35 • Continue and expand online training and training-of-trainer efforts. • Support cities in implementing suicide prevention efforts, particularly once cities have passed suicide prevention policies. e) Ensure all SP efforts are culturally competent in order to better serve the diverse communities in the County. • Continue incorporating cultural competency concepts into trainings, communications campaigns, and research/evaluation. • Respond to cultural data analyses and engage with cultural populations that are inequitably affected by suicide, e.g., Black boys and the LGBTQ+ community. f) Move towards regular/continuous program monitoring and improvement by increasing and streamlining evaluation of program activities, and by building a data and evaluation system for suicide data and SP efforts in the County. • Incorporate consistent evaluation measures for activities under all program objectives, with a focus on outcome measures. • Increase gathering of evaluation data in all SP Program efforts. • Continue working with the Data Workgroup to identify and advocate for further data collection and analysis to inform suicide prevention efforts. 36 ACKNOWLEDGEMENTS Toni Tullys, MPA SPOC Co-Chair Director, Santa Clara County Behavioral Health Services Department (BHSD) (until April 2020) Victor Ojakian Co-Chair, SPOC Co-Chair, Policy/Advocacy Workgroup Behavioral Health Board National Alliance on Mental Illness Survivor of Suicide Loss Sherri Terao, Ed.D. Director, Santa Clara County BHSD (from May 2020) Joy Alexiou Communications Workgroup Co- Chair HHS Public Information Officer Mary Gloner, MPH, MBA Project Safety Net Mary Ojakian, RN HEARD Alliance Survivor of Suicide Loss Sandra Hernandez, LCSW Adult/Older Adult Special Projects and Whole Person Care, BHSD Mandeep Baath, MPH Public Health Department Shashank Joshi, MD Lucille Packard Children’s Hospital Stanford University/HEARD Alliance Joan Baran, PhD Children’s Health Council Linda Lenoir, RN, MSN, CNS HEARD Alliance Kris Bifulco, MPH Interventions Workgroup Co-Chair LGBTQ Wellness (until March 2020) Leif Erickson Youth Community Services Betty Ramirez City of San Jose John Macon Recreation Services, City of Milpitas Joyce Chu, PhD Data Workgroup Co-Chair Palo Alto University Lan Nguyen, MA Suicide and Crisis Services, BHSD 37 Jennifer Del Bono Santa Clara County Office of Education Kathy Forward National Alliance on Mental Illness Chris Miller Interventions Workgroup Co-Chair (from April 2020) Paul Muller Data Workgroup Co-Chair BHSD Administrative Oversight Director: Toni Tullys, MPA (until April 2020) Director: Sherri Terao, Ed.D. (from May 2020) Director, Alcohol, Drug, and Access Services: Bruce Copley, MA Mental Health Services Act Senior Manager: Evelyn Castillo Tirumalai, MPH Suicide Prevention (SP) Program Staff Manager: Mego Lien, MPH, MIA Coordinators: Jasmine Lopez, MA; John Donoghue, MPH Community Outreach Specialist: Evelyn Quintanilla Associate: Claudia Espino Romero Suicide and Crisis Services (SACS) Staff Manager: Lan Nguyen, MA Volunteer Supervisor: Eddie Subega, LMFT Thank You Santa Clara County Board of Supervisors Members of the Data Workgroup Members of the Interventions Workgroup Members of the Communications Workgroup Members of the South County Suicide Prevention Workgroup SACS and SP Volunteers 38 ATTACHMENTS Attachment 1. Mental health for immigrants brochure (Vietnamese) Quy vi co dang lo Hing cho nguai than quen co the dang bi khung hoang tam tri khong? 1-13.y lam nbUng difu sau d!liy: 0 NOi chuy~ rl~ngvol 1)9 vi cbo blElvl saoquf v! lo l.1ng. Oft nh1lngd.u bol cOtinh~I mtYdidlu tri I/JI kh6ng tht chi la "co' ho!< "kh6og•. Sau do hay cbU f l.ing nghe. 0 Dlngh! glU:p d6'V3m0 th~m by ''(;mg h61 ph~c. Cho h9 blEt 13 v1~ ch6ng ch9I ,UI ~h t!tm tri alng cit ph6 blio,~ hf~ooo obl!u ngu6nglopdft. 0 Chia 5eciC ngu6n h6 tNJ. Cho b~ ck th6ng tin vE nhilng nol CO thi tn;,' glUp. 0 TIEp t1_1c theo dbL HOI xem h9 mu6n dttgc gll1p nhd thE tl8o ,-A 18m theo 89"1 y cUa h]. HUONG DAN vf sue KHOE TAM TRf CHO NGu'o1 NHP cu COUl'ftT OF SANTA Q.AAA Behavloral Health ServlcH e 39 Attachment 2. LGBTQ+ resource (English and Spanish) Wellbeing & Suicide Prevention Resources for the LGBTQ+ Community Get Services The Q Corner Offers peer services to support LGBTO+ community members and allies to access resources, referrals, social and community bu1~ing actMties, mentonng, and trammg. (408) 977-8800, TheQCorner@hhs.sccgov.org sccbhsd Ofg/theQComer 1075 E. Santa Clara Street, San Jose Serves: All ages LGBTQ Wellness Supports the mental health of LGBTO community members and allies by pmvKting outreach, education and advocacy services (408) 841-4300 452 S. 1st Street, San Jose lgbtqweU.ocg Serves: Adults The LGBTQ Youth Space A community drop-in center and mental health program for LGBTO+ and ally youth and young adults who live 1n Santa Clara County (408) 343-7940 452 S. 1st Street, San Jose youthspace org Serves: Ages 13-25 Bill Wilson Center LGBTQ Connections Provides a safe drop in space, support groups, and services to connect to housing, educatton, and mental health resources (408) 925--0233 693 S. 2nd Street, San Jose bilt-Nilsoncenter. org/services/alll1gbtq--0utreach .html Serves: Ages 18-25 Outlet, Adolescent Counseling Services Outlet empowers LGBTQ-+ youth through support services, leadership training, community educabon and advocacy (650) 424--0852 x107 590 W. El Camino Real, Mountain View acs-teens.orglwhat-we-doloutletf Serves:Ages 13--18 Billy DeFrank LGBTQ+ Community Center Provides community, leadership, advocacy, seMces and support to the Silicon Valley's LGBTO People and the1r Nlies (408) 293-3040 938 The Alameda, San Jose defrankcenter_org Serves: Adults Avenidas LGBTO Seniors Initiative New programs and services 111 the areas of Socializabon and Health Educatton/ Cultural Competency through strategic partnerships with LGBTO organizations (650) 289-5417, tk1ngery@avenidas org avenidas.org/programsJlgbtq-seniofs--initiahve/ Serves: Older adults Social Services Agency: Department of Family and Children's Services LGBTQ Soctal Wcrler who provides support, advocacy, education, and resources related to LGBTQ youth involved in the child welfare system (408) 501-6889, lgbtq@ssasccgov.o,g Serves: Students and famibes Sexual and Gender Identities Clinic -The Gronowski Center Affordable and affirming psychological services fOf individuais who identify as LGBTQ as well as those questioning their sexual orientation Of gender identity. (650) 961-9300 5150 El Camino Real, Building C, Surt.e 15, Los Altos paloaltou_edu/gronowskl--center/sexual-gender-identihes-cimc Serves: Youth and adults Talk to Someone Crisis Text line Crisis Text Line is free, 24fl support for those in crtSis. Text from anywhere in the US to access a tramed Cns1s Counselor. Text LGBTQ to 741741 Serves: Youth & Adults SAGE National LGBT Elder Hotline The SAGE LGBT Bder Hot~ne 1s available 24 hours a day. 7 days a week, m Enghsh and Spanish, with translation in 180 languages. (877) 360-LGBT (5428) Serves: Older Adults ~ (;OVJ,ITY OF SAJffA (;U.AA ~ Behavioral Health Services Recursos para la Prevencion del Suicidio en la Comunidad LGBTQ+ Para Obtener Servicios "Gaylesta", La Asociaci6n de Psicoterapeutas para la Diversidad Sexual y de Genera Servicio de referenda con proveedores de una amplia gama de capacitad6n y experiencia especializados en la comunidad LGBT. gay/esta.org Para: Todos "Outlet", Servicios de Consejeria para Adolescentes NOutlet" empodera al LGBTQ+ a traves de servtCios de apoyo, capacitad6n sobre lidera:zgo, educaci6n comunitaria e intercesi6n. (650) 424-0852, extensi6n 105 590 W. El (amino Real, Mountain View projectoutlet.or9 Para: edades de 13 a 18 aiios LGBTQ Youth Space (Espacio Juvenil LGBTQ) "Youth Space" es un centro comunitario y programa de salud mental para LGBTQ + y aliados de j6venes y adultos j6venes que vivan en el condado de Santa Clara. (408) 343-7940 452 S. 1st Street, San Jose yourhspace.org Para: edades de 13 a 25 aiios Centro Comunitario "Billy Defrank" para Lesbianas y Gays Brinda una comunidad, liderazgo, intercesi6n, servicios y apoyo a Bienestar LGBTQ Apoya la salud mental de los miembros y aliados de la comunidad LGBTQ al propordonar servicios de divulgaci6n, educaci6n e intercesi6n. (408) 343-7944 452 S. t•Street, San Jose Lgbtqwell.org Para: Adultos Para Obtener Mas informaci6n Recurses LGBTQ Acceso a una lista de rerursos com pi ados por los Servicios de Salud Mental de) Condado de Santa Clara. sccbhsd.org/lgbrq Para: }6venes y Adultos "It Gets Better'' (Todo Mejora) El Proyecto "It Gets Better'" es una campaiia que comparte historias para mostrar a las persona5 j6venes LGBT, la felicidad y el potencial que sus vidas pueden alcanzar. itgersbetter.org Para: Adolescentes Centro Nacional de Ayuda LGBT Sirviendo al lGBTQal brindar apoyo local gratuito y confidencial, asi como recursos locales. LCBThotline.org Para: }6venes y Adulros Centro Nacional de Recurses sabre el 40 REFERENCES Ahmedani BK, Peterson EL, Hu Y, et al. Major Physical Health Conditions and Risk of Suicide. Am J Prev Med. 2017;53(3):308–315. doi:10.1016/j.amepre.2017.04.001 Ahmedani BK, Simon GE, Stewart C, Beck A, Waitzfelder BE, Rossom R, et al. Health care contacts in the year before suicide death. J Gen Intern Med. 2014;29(6):870–877. doi: 10.1007/s11606-014-2767-3. Beautrais AL. Further suicidal behavior among medically serious suicide attempters. Suicide Life Threat Behav. 2004;34(1):1–11. Blackwell, DL, Lucas, JW, & Clarke, TC. (2014, February). Summary health statistics for U.S. adults: National Health Interview Sur-vey. Vital Health Statistics, 10(260). Canetto, SS. (2020). Suicide: Why are older “White” men so vulnerable? [PowerPoint slides]. American Association of Suicidology. Centers for Disease Control and Prevention. (2013). Suicide - United States, 2005- 2009. Morbidity and Mortality Weekly Report, 62(03), 179-183. Centers for Disease Control and Prevention. (2018). Web-based Injury Statistics Query and Reporting System (WISQARS): Fatal injury data visualization. Retrieved from https://wisqars-viz.cdc.gov:8006/explore-data/home Coleman, D., Kaplan, MS, & Casey, JT. (2011). The social nature of male suicide: A new analytic model. International Journal of Men’s Health, 10(3), 240–252. Fernquist, RM. Education, race/ethnicity, age, sex, and suicide: individual-level data in the United States, 1991–1994. Current Research in Social Psychology 2001;6:277–90. Harvard School of Public Health. Means Matter Basics. Means Matter. Retrieved September 11, 2020, from https://www.hsph.harvard.edu/means-matter/ Kaplan, MS, McFarland, BH, & Huguet, N. (2009). Firearm suicide among veterans in the general population: Findings from the National Violent Death Reporting System. The Journal of Trauma, 67, 503-507. 41 Luoma JB, Martin CE, Pearson JL. (2002). Contact with mental health and primary care providers before suicide: A review of the evidence. American Journal of Psychiatry, 159(6):909-916. Pollack, WS. (2006). The ‘war’ for boys: Hearing ‘real boys’’ voices, healing their pain. Professional Research and Practice, 37, 190-195. Rand Corporation. (2018). The Relationship between Firearm Availability and Suicide. Retrieved from https://www.rand.org/research/gun- policy/analysis/essays/firearm-availability-suicide.html Suicide Prevention Resource Center. (2016). Preventing suicide among men in the middle years: Recommendations for suicide prevention programs. Waltham, MA: Education Development Center, Inc. Tang, NKY, & Crane, C. (2006). Suicidality in chronic pain: A review of the prevalence, risk factors and psychological links. Psychological Medicine, 36(5), 575–586. United States Census Bureau. (2015). Population by age and sex: 2015. 2015 Census Briefs. Retrieved from https://www.census.gov/data/tables/2015/demo/age-and-sex/2015-older- population.html United States Department of Health and Human Services (HHS), Office of the Surgeon General, & National Action Alliance for Suicide Prevention. (2012). 2012 National strategy for suicide prevention: Goals and objectives for action. Washington, DC: HHS. Retrieved from http://actionallianceforsuicideprevention.org/national-strategy-suicide- prevention-0 Yin, S. 2006. Elder White Men Afflicted by High Suicide Rates. Washington, DC: Population Reference Bureau. Recipient:Palo Alto City Council Letter:Greetings, Save Palo Alto's Youth and Children Programs! Join us in asking Palo Alto City Council to reject the cuts being proposed in the 2021-22 city budget for children and youth programs that protect their emotional, mental and physical health and wellness. According to the Palo Alto Weekly, a number of community services would suffer because of these cuts. A few of these cuts include- Performing Arts: our beloved Children's Theatre would lose staffing and risk the full closure of the theatre in the more drastic "Tier 2" strategy that would be undertaken if the revenues plummet even further than expected. Libraries: Children's library, which is the oldest children’s library in the country. Downtown and College Terrace libraries would also be closed to the public. Teen programming: Elimination of funding teen programs including the free Family Day programs at the Rinconada Park institution and Youth Community Service's mental health wellness program- Youth Connectedness Initiative.  Community building: Eliminate the Cultural Kaleidoscope, a bridge-building curriculum connecting our elementary students to artists in the neighboring communities in East Palo Alto and Menlo Park. Arts:  Palo Alto Art Center would lose all city support for its exhibition programs for the first time in its 50-year history. Make your voice heard! sign this petition and if you can, join the City Council Meetings and the Council Finance Committee to express your concern. We know cuts may be needed, but our children and youth should not be sacrificed, especially this year when the COVID19 pandemic has taken a huge toll on our children and youth. change.org Details available at- <a href="https://www.cityofpaloalto.org/Departments/City-Clerk/City-Council-Agendas-and-Minutes" rel="nofollow">https://www.cityofpaloalto.org/Departments/City-Clerk/City-Council-Agendas-and-Minutes</a> Comments Name Location Date Comment Rebecca Eisenberg Palo Alto, CA 2021-05-03 "Our city leaders must do their job - require huge corporate donors to pay their fare share, and fund resources essential for the rest of us!!" Bob Miyahara Menlo Park, CA 2021-05-04 "Cutting funding for youth programs when our children have been isolated for so long only exacerbates the impact of the pandemic. Please continue to fund these critical programs." Jennifer Gonsalves Palo Alto, CA 2021-05-04 "These are very valuable programs!" KATHRYN AKATIFF Palo Alto, CA 2021-05-04 "This is an unique and treasured institution that has meant so much to the children of this town. Cut your own salaries before you touch Children's Theater, the Children's Library and the Cross Culture programs. Don't buy more public art. Don't put in round-a-bouts. Don't put dips in the street for rainwater. Stop the expensive corner curb reconstructions when they are already ramped. There ARE things you can do to save these programs." Brandon Savage US 2021-05-04 "The programs and friends at PACT meant so much to me as a child and I hope we can preserve this unique and wonderful institution for generations to come." Haley Carter Palo Alto, CA 2021-05-04 "Palo Alto is the amazing town that it is because of the children and young families who live there. Keep city programming at library’s and public spaces open for children especially. At risk youth and young children depend on these resources to learn and grow. Close these and watch Palo Altos youth drug use rate will spike." Laurie Walls Columbia City, IN 2021-05-04 "You need to invest in children's futures, not take away valuable resources like libraries and the performing arts. These places and services are vital to a healthy community!" Rena Kim Los Altos, CA 2021-05-04 "The places they plan on cutting are essential to the youths in Palo Alto. These places are cultivating dreams and the council plans to cut these programs for the sake of money." Ruchi Goyal Stanford, CA 2021-05-04 "Post-covid, our kids need access to programs like PACT, which is an extremely inclusive community to channel their feelings in a creative way. The Palo Alto Children's Theatre is essential to the community, which is why I was horrified when I learned that there were proposed cuts in the upcoming budget plan." Rachaell Mondino Mountain View, CA 2021-05-04 "I’m signing because my kids deserve better. I work hard to be able to pay my property taxes to give my kids a chance at the same childhood I had. People have invested in this community for decades and it’s time to make big business do the same." Hiral Parekh Palo Alto, CA 2021-05-04 "We chose to live in Palo Alto because of these types of programs. This community has a history of enrichment for children and youth. In addition, the Children's library is a treasure. Palo Alto is a special place and we should work harder to keep these intact. Other cities Name Location Date Comment across the country have dug deep during these difficult times. Please consider every option before cutting these programs." Mark Fussell Palo Alto, CA 2021-05-04 "So the 2022 number is $6.5 million. Or less than the waste on the roundabouts and messed up bike flow control ($9mm). There should be enough in the capital buffer for that (“The FY 2021 Budget Stabilization Reserve (BSR) is anticipated to be $35.8 million“) or a minor loan to cover it. Why isn’t the BSR being used for what it is intended to handle?Why is the number suddenly doubled? “to balance the FY 2022 $13 million gap”. This does not change the points above but is quite curious. —MarkFrom the budget (p 55) :RESERVESThe City’s general reserve is referred to as the Budget Stabilization Reserve (BSR). By policy, the City main- tains a reserve level of 15.0-20.0 percent of the General Fund operating budget, with a targeted goal of 18.5 percent. City Council approval is required prior to setting reserves lower than 15.0 percent.Seems an obvious source for a one-year extension to give the council time to come up with a better revenue stream" Julia Asher Palo Alto, CA 2021-05-04 "We need the arts now more than ever. Especially in the Bay Area technology and stem has always been prioritized, sidelining arts programming. As an artist from Palo Alto, the arts saved me and I firmly believe they will save future kids from getting lost in the overwhelming stem world." Tammy Kwan Palo Alto, CA 2021-05-04 "The Children’s Theatre has been such a magical place for my daughter and the youths of our community. Please don’t cut it when they now need it the most." R Rasmussen Altadena, CA 2021-05-04 "I grew up at PACT. It had a profound influence on who I became as an adult and how I conduct myself in my career as a professional theatre artist." anna hurty oakland, CA 2021-05-04 "One of our sons found his "purpose" at the children's theatre. He was engaged, proud, learning every day. These programs are critical for the youth of the Peninsula." Анастасия Волкова Los Angeles, CA 2021-05-04 "The Palo Alto Children's Theatre and Children's Library were fundamental to my growth and future career path. I gained valuable insights, knowledge, and experiences, and it would be such a loss to the community to not have this programming. Please keep these institutions around and affordable for all local kids!" Kimberley Wong Palo Alto, CA 2021-05-04 "Growing up in Palo Alto, then experiencing them as a mom, I cherish each individual library... it is what sets Palo Alto apart from all the other cities. Plus, having a neighborhood library helps cut traffic around town if there was only one to go to. It promotes community!!" Kiran Khanna Palo Alto, CA 2021-05-04 "I love Palo Alto children’s theater - they are a treasure" Dror Sneh Palo Alto, CA 2021-05-04 "I have 4 boys who went through these various programs, which complement our great school district, and I’m greatful for all the skills and confidence they acquired, for all the mental strength they built, and for all the lifelong friends they made in them. You cannot put a price on that." Name Location Date Comment sandy eggers san leandro, CA 2021-05-04 "PACT is a treasure for the children who have participated over many years. Generations to come need the same opportunity to be involved in this very important institution!" Tanya Mehta Palo Alto, CA 2021-05-04 "The PA Children's Theater and its exemplary staff have provided a magical place for so many kids in our community. Please continue to invest in our youth. Our kids need these programs now more than ever." Sarah Wilson Redwood City, CA 2021-05-04 "I grew up participating in all aspects of the Palo Alto Children's Theatre -- outreach shows in the elementary schools, main stage productions during the school year, conservatory program in the summer and Wingspread. It was truly a home away from home for me and I made many lasting friendships there in my youth! I also sent my stepchildren to the same programs during the summertime and they loved it. Please don't cut the arts any further." Ari Consul Seattle, US 2021-05-04 "There's no good reason not to fund these programs next budget year." Gina Silverman San Francisco, CA 2021-05-05 "Cutting the Children’s Theatre and children’s library would be horrendous. These are things that make Palo Alto so special." Kirsten Luehrs Palo Alto, CA 2021-05-05 "Our community needs these programs. There must be a way to raise or shift funds to keep them going." Kirti Rao San Francisco, CA 2021-05-05 "Kirti rao" Aarti Johri Los Altos, CA 2021-05-05 "My children went to Palo Alto schools and the community thrives because of these programs. We need to get more creative to help the programs survive. Shutting the beloved library, theatre and the art center and their programs? Not a solution for a thriving community . In a pandemic these bring us together. Let’s not remove another tool of social engagement ." Ananya Das Palo Alto, CA 2021-05-05 "I appreciate living in a city that cares about raising well rounded, caring citizens. Let’s keep Palo Alto special and forward-thinking!" Maria Brown Palo Alto, CA 2021-05-05 "We love living in Palo Alto because of all the beautiful programs that are offered." Kristan Green Palo Alto, CA 2021-05-05 "Cutting youth programs will be extremely detrimental to our youth! These programs are so valuable and our youth need them!" Shana Segal Palo Alto, CA 2021-05-05 "I grew up in Palo Alto and participated in Children’s Theater and took my kids to every story time and hotdog production before covid hit. It’s a gem and brings together the community." Eileen Stolee Palo Alto, CA 2021-05-05 "I'm signing this petition because both of my children grew up here going to the children's library, plays at the children's theatre, and our beloved College Terrace Library. These programs are the heartbeat of our city!" Penelope Van Tuyl San Francisco, CA 2021-05-05 "PACT was my home and vibrant community between ages 8 and 15. It was such a special, safe place for kids to have freedom and Name Location Date Comment independence, bonding over collective constructive activities, while safe and supervised. We need more of this in today’s world, not less. It should remain funded!" Katie Christman Palo Alto, CA 2021-05-05 "Palo Alto was a great place to grow up poor.It has been a great place for my kids to grow up NOT poor.We mix our kids here, in schools and in community programs which are free but so great, rich kids want in. If you cut these programs you will fracture our town. No amount of ‘savings’ is worth that." Kimberley Wong Palo Alto, CA 2021-05-05 "My family, mother, me and my kids, all products of the Palo Alto school system, we collectively cherish the Children’s library, the Palo Alto children’s theater and the many programs it has offered many of the young people of Palo Alto. To lose these would to lose the heart and soul of what makes Palo Alto so special and so unique! Please save these valuable resources fir generations to come!" Jennifer Goltz-Taylor Ann Arbor, MI 2021-05-05 "PACT had a huge, hugely positively impact on my life. I participated as a kid and then taught and directed as a young adult. I learned skills within and outside the bounds of theater -- skills I continue to use and depend on to make my living as a musician and educator to this day. PACT is a unique and special organization that is one of the best things about life in Palo Alto. Don't let it die on your watch." Elaine Jek Palo Alto, CA 2021-05-05 "Elaine Jek" Susan Meade Palo Alto, CA 2021-05-05 "Palo Alto Art Center and the Children’s Theatre are integral reasons for living in Palo Alto. The Art Center is the heart of our artistic community. Between Project Look, rotating exhibits, displays of youth art, hosting of teen events, and the many many studio art classes available, I can’t imagine the Art Center having to operate on a shoestring budget. The Children’s Theatre where my children have attended performances, and my actress daughter has performed in the Playhouse series, is a Gem. Please do what you can to save these vital programs for the Palo Alto community." Gurmeet Lamba Cupertino, CA 2021-05-06 "We need to keep the philanthropic nature of the Palo Alto Art Center and not just a pay for classes commercial establishment." Marsha Smilovitz Palo Alto, CA 2021-05-06 "This program and facility are incredibly important to our community and the ongoing development and showcase of talent. Art is already cut from normal school programs." Mayra Azanza Palo Alto, CA 2021-05-06 "We moved to Palo Alto in part because of the many opportunities these programs presented to our children. All these programs that are threatened are key for keeping of a close-knit community, one that we really want for our kids and we as a community need after such devastating year. Do reconsider, eliminating them will create a larger problem." Rebecca Griner Palo Alto CA 94303, CA 2021-05-06 "Keep it running!! More!" Amy Lee Palo Alto, CA 2021-05-06 "Our kids need these youth programs." Name Location Date Comment deidre silverman san rafael, CA 2021-05-06 "Performing Arts is a wonderful, character-building experience for young people. Please maintain." Quinn Russell Olympia, WA 2021-05-06 "Youth programming, community gathering spaces and accessible resources in the arts are vital to a healthy community. Defunding libraries, sports and children’s theatre would cut out the heart of what makes Palo Alto a vibrant place for children and families. From a mental health and equity perspective these cuts would be devastating." Laurie Levy Palo Alto, CA 2021-05-06 "I can't imagine a world without access to libraries, hot dog summer theater, Cultural Kaleidoscope (which is so powerful if you get to see how children benefit), and an Art Center where I can take my students." Jonna Hunter Menlo Park, CA 2021-05-06 "These community resources punch above their weight in quality. They simply make our community fabric richer and stronger." Boaz Maor US 2021-05-06 "These youth programs are fundamental to the livelihood of our kids and should be prioritized over and above other budget items" Patricia Kinney Palo Alto, CA 2021-05-07 "We need to continue to invest in emotional and mental well-being for our children and youth." Michele Sharkey Los Altos, CA 2021-05-07 "After a year of distance learning, our students need youth programs more than ever to support their mental health." Roberta Lamanda Palo Alto, CA 2021-05-07 "our Youth Connectedness Initiative (YCI) program which helps adolescents (ages 11-18) develop social-emotional learning as a suicide prevention tool, it’s and amazing program. The pandemic is very hard to our kids.This is the time to strongly support programs like this. Please think wisely." Marguerite Fletcher Palo alto, CA 2021-05-07 "PALO ALTO’s programs and provisions for children in education and the arts should not be sacrificed, particularly during this time of privation and isolation." Zhi Zhang Cupertino, CA 2021-05-07 "Please keep the art center! It is crucial to youth art programs!" Assaf Cohen Los Angeles, CA 2021-05-07 "Palo Alto Children’s Theatre changed my life. I would not be a professional actor, arts advocate and some of my deepest held values were it not for PACT." Mark Saleh Palo Alto, CA 2021-05-07 "The Children’s Theatre provided an incredibly enriching experience for our kids and plays a valuable role for our community, which is needed now more than ever." Rev. Amy Zucker Morgenstern San Francisco, CA 2021-05-07 "Children's libraries, programs that support teens' mental health, theater . . . these are services most communities would love to have. For Palo Alto, one of the richest cities in California, even to be considering scrapping them, is an embarrassment." suzi manbeck Palo Alto, CA 2021-05-07 "I concur very strongly that the children of Palo Alto need to have access to all of the programming they had prior to the pandemic. It would be a shame to lose library access, access to the arts Name Location Date Comment and theatre. All the things that help enrich them to be more well rounded humans." Jennifer liu Palo Alto, CA 2021-05-07 "Art is important for PA residents" Sunny Zhai Palo Alto, CA 2021-05-07 "My kids miss taking the pottery and drawing classes and the exhibition there in the art center. We love this place so much." Riki Morita Palo Alto, CA 2021-05-07 "Please don’t cut these valuable programs!" Charlotte Fu Palo Alto, CA 2021-05-07 "Our community needs art especially during the difficult times. Our kids have enjoyed going to the Palo Alto art center since they were very in the preschools. Our community loves this art center. Please keep it alive for the community! Thank you!" Alli Gilden Washington, DC 2021-05-07 "The arts are an essential part of the community, particularly when it comes to programming for children." Laurel Fleck San Jose, CA 2021-05-07 "My children benefitted greatly from all the wonderful programs Palo Alto offered to youth. Any program offering mental health services to children is vital to the community. Please do not end these programs/services." Victoria Quertermous stanford, CA 2021-05-07 "I value our children and their futures." Julie O’Grady Palo Alto, CA 2021-05-07 "The Children's Theatre must stay. It's Palo Alto history and use is immeasurable!" Shela Fisk Palo Alto, CA 2021-05-07 "It is a valuable recourse for children and definitely helps improve self esteem. I am a psychologist/psychoanalyst" Aley Even Santa Ana, CA 2021-05-07 "I was the exhibitions intern at the Palo Alto Art Center during the summer of 2019. I saw first hand how wonderful and vital art is to a community. Palo Alto is fortunate enough to have a beautiful art center where children and adults have the opportunity to learn and create, and there is absolutely no reason why that should change." Dianne Suiter Dayton, OH 2021-05-08 "I deeply understand the power of the arts to support, educate, and heal all youth." Kathleen Kerry Palo Alto, CA 2021-05-08 "My children enjoyed the Thester so much in the mid-80’s. Michael threatened to install a bed for one son! My six grandchildren don’t live in Palo Alto or they would have been there, too. We need to save this treasure!" DD Feng Palo Alto, CA 2021-05-08 "My kids grew up with these art programs, which brought our family a lot of joy and made our living in the city unique. Please keep these programs especially during this difficult time." Mridula Shukla Dearborn, US 2021-05-08 "To, Palo Alto City Council,Please reject the cuts being proposed in the 2021-22 city budget for children and youth programs that protect their emotional, mental and physical health and wellness.ThanksMridula" jennifer ott Palo Alto, CA 2021-05-08 "This is a wealthy city that can choose to support the arts" Name Location Date Comment Martha Sakellariou Palo Alto, CA 2021-05-08 "We can't afford to lose these programs especially after enduring a year of isolation and lack of creative outlets. These are essential for our communities growth and wellbeing." Deborah La Puma Placentia, CA 2021-05-08 "Theatre and the arts are vital to heal the wounds of the past year. Bring joy and community building back to the children of Palo Alto!" Andrew DeMartini Sunnyvale, CA 2021-05-08 "My kids love the Children's Theatre performances." Reshma Singh Palo Alto, CA 2021-05-08 "The theater was a great part of my children’s life, giving them the confidence to speak and be themselves. I would like every child in Palo Alto and beyond to have the same gift. Especially given these crazy times when youth mental health is tanking. Thanks- Reshma" Jules Sherman Palo Alto, CA 2021-05-08 "I care about kids" Hairong Zou Palo Alto, CA 2021-05-08 "It is a very important part of the community for our next generation." Isma Khan Palo Alto, CA 2021-05-08 "These programs are so important for the youth even more so in the current times!" Jian Shi San Jose, CA 2021-05-08 "We should give our children more opportunities" Adam Tobin Stanford, CA 2021-05-08 "Libraries and performing arts are the lifeblood of a city." Ami O California 2021-05-08 "Our children need the arts to thrive!!" Tad Lebeck Palo Alto, CA 2021-05-08 "I am signing because the Children’s Theater is such an important part of our community. Our children love studying there and we love the productions" Mandy Guo Palo Alto, CA 2021-05-08 "My family benefited from the youth programs." Toni Ouradnik East Palo Alto, CA 2021-05-08 "As a teacher and parent, my children and students have benefited in innumerable ways from the Art Center and Project Look field trips. In this past year of distance learning, the digital field trip with Project Look was the only one that was a true success. This organization is an integral part of my curriculum. There is so much money in Palo Alto and our youth deserve the support, especially after the past 14 months they've had. Please save this!" Yara Sellin Stanford, CA 2021-05-08 "The library, Art. Enter,The library, Art Center, children’s programs all make Palo Alto a great place to live. My family members all use and value Palo Alto’s precious community resources." Lee Zulman Palo Alto, CA 2021-05-08 "I believe that an overhaul of the Planning Dept. would generate revenue and save 100s of thousands of dollars. Antiquated rules are mobilized to delay building. It took me 7 months to get a teeny galley kitchen put in my ADU, for example. There are many illicit rentals that are overlooked, and revenue goes uncollected through lack of efficiency. The 5-million dollar house, near my house, that was demolished to make way for a new house ($$ for the City) leaves and empty lot in Edgewood for over 5 years. The process is inefficient and does not befit a city a like Palo Alto. Instead you Name Location Date Comment cut community Gardens and a theatre that for years has engaged children productively and happily for years!" Thomas Buch Menlo Park, CA 2021-05-08 "We always took our grandchildren to the Children's theater. They gained so much from experiencing live theater. Please keep this vital theater experience going forward. The pandemic has done enough damage to young children. Let's not make it worse!" Morgan Guzman Alameda, CA 2021-05-08 "I grew up hanging out at the theater and that experience has shaped so much of who I am. Palo Alto needs the Children’s Theater!" Sue Klapholz Stanford, CA 2021-05-08 "The arts are critical to a thriving culture. Children need the arts and the library in their lives." Rebecca Thompson Palo Alto, CA 2021-05-09 "Especially for children who are neither athletes nor mathletes, the theater and the arts programs provide invaluable opportunities for learning, connecting, growing, finding friends, and feeling a valuable part of the community. Don’t shut them down or cut them back. Find another way." Igor Makasyuk pppp, CA 2021-05-09 "Tax the business, do not deprive children of programs." Brittany Gardner Palo Alto, CA 2021-05-09 "I’m signing because Palo Alto Children’s Theatre helped make me who I am today." Alison Biggs Los Altos, CA 2021-05-09 "We’re in neighbouring Los Altos but have enjoyed so many wonderful times at the Junior zoo, library, etc. I always felt so encouraged by all Palo Alto did for its children, so many lovely little unique experiences that EVERYONE could enjoy. There have to be solutions that don’t involve taking these institutions away." Gene Warren Palo Alto, CA 2021-05-09 "These institutions are an amazing resource for community familes and a key part of what makes growing up here unique" Lori Gicklhorn Issaquah, WA 2021-05-09 "I grew up in Palo Alto, and hate to imagine a childhood bereft of the programs that are being proposed to be cut. The arts bring children so much benefit to mental and physical health! In a year when we are all faced with a lack of social and community opportunities, to cut these programs would be a tragedy and set back the youth and students of the city for years to come. Generations have benefited from PACT, the Children’s Library, and so much more! Fight to keep these powerhouses for the city to bloom back better!!" Colleen Uhran Arroyo Grande, CA 2021-05-09 "The Art Center is a place that put a smile on my face when I was a child." Elinor Taussig Palo Alto, CA 2021-05-09 "The children’s theatre has been one of my favorite things for kids in Palo Alto! You have to save it!" Jennifer Newton valley village, CA 2021-05-09 "The arts matter" Ashley Suhr Seattle, WA 2021-05-09 "As a young boy I enjoyed many beautiful productions at this theater. By cutting support for vital programs in the arts we stand to lose so much of value. Please consider the future of our children Name Location Date Comment when you make this decision, and keep this amazing program intact." Norm Picker East Palo Alto, CA 2021-05-09 "Please prioritize the children’s programs, theatre and library." Basab Pradhan Palo Alto, CA 2021-05-09 "Arts programs should be protected." Benjamin Hill Mountain View, CA 2021-05-09 "My kid loves the theater classes" Mimm Patterson Palo Alto, CA 2021-05-09 "We live in challenging times. Still, our children and our youth should be our priority and cutting the budgets of these programs will be a negative impact on their lives not only today but in the years to come." Kristen Van Fleet Palo Alto, CA 2021-05-09 "Art programs are important to our Palo Alto community. A city that is one of the wealthiest places in the world can figure out how to keep these programs going! Not every thing in life needs to turn a profit. Some experiences are more valuable than anything money can buy." Laura Bajuk Palo Alto, CA 2021-05-10 "Everything we do that makes a child’s life brighter makes for a better world for us all. (And the opposite is true - reduce the quality of life and we darken the world, adding crime, abuse and more.) Be the light!" Ashwinee Khaladkar Palo Alto, CA 2021-05-10 "Palo Alto art museum is such great facility for the community the community to participate, learn, develop and admire local talent." Zack Pace Rohnert Park, CA 2021-05-10 "Art is the heart beat of life. Keep the creativity flowing." Kathy Aoki Santa Clara, CA 2021-05-10 "The Palo Alto Arts Center exhibition program is a hallmark of Palo Alto's commitment to the visual arts. The exhibitions are excellent in caliber and thought provoking for all-aged community members and beyond. Local artists are often showcased along side nationally recognized artists. Interns from Santa Clara University and other institutions start their professional careers here working on the visual arts programming. Artists-in-residence engage directly with the community. Save the Art Center's existence by maintaining its FY21 budget in FY22." Swati Goel Palo Alto, CA 2021-05-11 "The PACT and the wonderful mentors who work there have a tremendous impact on the lives of generations of young Palo Altons. In general, in Palo Alto, I feel a lack of community organization especially one that spans age, class, gender, race, and personality. The PACT and the collaborative art it teaches, are so uniquely vital to our community. It's form so many of us who grew up performing on that stage when we heard our first applause, felt our first sense of pride in something we did. It warmed the hearts of we who sat with our neighbors tasted the buttermelt of popcorn on a summer night and see our favorite stories brought to light by our siblings, our students, and our co-worker's kids. A Pandemic, where we've all been isolated from our community is the worst conceivable time to weaken our beloved Palo Alto institution." Kathy Chen Palo Alto, CA 2021-05-11 "As a loyal participant in Palo Alto arts and children's programming with our three daughters for the last 12 years, our experience Name Location Date Comment of Palo Alto would be far different without the richness these programs provide. We make innumerable trips to libraries, art and theater performances throughout the year. Our regular practice is to check out the maximum (which is 80 books at a time) so that we always have fresh and interesting things popping for not only our kids, but parents alike. I continually learn and relearn lessons by reading to our kids, with our kids --and being shown lessons from our kids. Their love of music and theater started with performances before they could even be on stage themselves here in Palo Alto. Please reconsider how funding cuts can be distributed in ways that make sense for all." Lesley Tsina Los Angeles, CA 2021-05-11 "I am an alum of PACHT. Working in the costume shop was my first job as a teenager and the shop was my main hangout. I doubt I’d be working in film and television without that experience. Please keep the costume shop and supervisor position open. It’s a great and rare experience to get to do that as a kid." jeannie duisenberg palo alto, CA 2021-05-11 "It's the people programs----the uniqueness of Palo Alto--- that these proposed budget cuts disproportionately affect. These programs bring donations, volunteers, and immense community benefit. Eg. at the Art Center, the proposed additional cut of $208, 000. (a total 44% budget cut!!) will strip bare the programs and thus the annual contribution of $750,000 garnered through the non-profit friends group, the Art Center Foundation. What sense does that make? Use the City emergency funds and the Federal funds now!" Kirsten Luehrs Palo Alto, CA 2021-05-12 "The city needs to hire someone to fundraise. These programs cannot be cut or there will be nothing valuable left of Palo Alto." Caitlin Savage San Carlos, CA 2021-05-12 "PACT is near and dear to my heart. I would not be where I am or who I am without the valuable skills and friendships I made growing up at the theater. It is a second home and a safe harbor to so many youth." Stephanie King San Francisco, CA 2021-05-12 "The Children’s Library was one of my favorite places as a child and I enjoyed going to shows at the children’s theater as well. Support the arts and literacy!" Ella Wilsher Palo Alto, CA 2021-05-12 "PA city council, hands off these programs" Curt Kinsky Palo Alto, CA 2021-05-12 "Children should be our primary concern coming out of COVID." Haley Carter Palo Alto, CA 2021-05-13 "Cut the Palo Alto City Managers insane Fortune 100 level salary before you touch these amazing children’s programs that are so important to our youth - especially at-risk youth." Neha Y Cupertino, CA 2021-05-13 "It is amazing for the kids!" Darrell Benatar Palo Alto, CA 2021-05-14 "Our community of friends come together every year at the art center to do art together and people love the art center." Mara Wallace Palo Alto, CA 2021-05-15 "I believe the PAAC is a vital resource in our community and beyond. It serves all ages in a myriad of ways, brings people together, fuels creativity and compassion, and educates us all. Especially in this time when we are so in need of comfort, connectedness, and Name Location Date Comment creativity, the arts are vitally important to the health and vibrance of our community. Please continue to support the PAAC!" Aparna Seetharaman Menlo Park, CA 2021-05-16 "I think the Children's Theater is doing wonderful work and their staff is exceptional." Melanie Grondel Palo Alto, CA 2021-05-17 "These programs are the treasures of our community and for our community and by the volunteers of our community. City Council members, please do not cut your contributions to these treasures that support our youth now and influence their life in the future so that they may continue these precious traditions in the future. Once lost these resources cannot be restored and will be gone forever." Recipient:Palo Alto City Council Letter:Greetings, Save Palo Alto's Youth and Children Programs! Join us in asking Palo Alto City Council to reject the cuts being proposed in the 2021-22 city budget for children and youth programs that protect their emotional, mental and physical health and wellness. According to the Palo Alto Weekly, a number of community services would suffer because of these cuts. A few of these cuts include- Performing Arts: our beloved Children's Theatre would lose staffing and risk the full closure of the theatre in the more drastic "Tier 2" strategy that would be undertaken if the revenues plummet even further than expected. Libraries: Children's library, which is the oldest children’s library in the country. Downtown and College Terrace libraries would also be closed to the public. Teen programming: Elimination of funding teen programs including the free Family Day programs at the Rinconada Park institution and Youth Community Service's mental health wellness program- Youth Connectedness Initiative.  Community building: Eliminate the Cultural Kaleidoscope, a bridge-building curriculum connecting our elementary students to artists in the neighboring communities in East Palo Alto and Menlo Park. Arts:  Palo Alto Art Center would lose all city support for its exhibition programs for the first time in its 50-year history. Make your voice heard! sign this petition and if you can, join the City Council Meetings and the Council Finance Committee to express your concern. We know cuts may be needed, but our children and youth should not be sacrificed, especially this year when the COVID19 pandemic has taken a huge toll on our children and youth. change.org Details available at- <a href="https://www.cityofpaloalto.org/Departments/City-Clerk/City-Council-Agendas-and-Minutes" rel="nofollow">https://www.cityofpaloalto.org/Departments/City-Clerk/City-Council-Agendas-and-Minutes</a> Signatures Name Location Date Mora Oommen Palo Alto, CA 2021-05-03 Leif Erickson Palo Alto, CA 2021-05-03 Chiara Vernari Palo Alto, CA 2021-05-03 Mindi St Peter Palo Alto, CA 2021-05-03 Rebecca Eisenberg Palo Alto, CA 2021-05-03 Christine Boehm Palo Alto, CA 2021-05-03 Leena Gill Palo Alto, CA 2021-05-03 Raven Malone Palo Alto, CA 2021-05-03 Soumaya Arfi Palo Alto, CA 2021-05-03 Claire Kirner Palo Alto, CA 2021-05-03 Kanthi Nagaraj Palo Alto, CA 2021-05-03 Kim Lemmer Palo Alto, CA 2021-05-03 Marina D’Arrigo Stanford, CA 2021-05-03 Samyuktha Aswadhati East Palo Alto, CA 2021-05-03 Yuri Chang Palo Alto, CA 2021-05-03 Sejzane rrahmani Hartford, US 2021-05-03 Nalini Kartha Palo Alto, CA 2021-05-03 mikasa ackermaam Annapolis, US 2021-05-03 Yudy Deng Palo Alto, CA 2021-05-03 Christine Dahl Stanford, CA 2021-05-03 Name Location Date Veronica Saleh Palo Alto, CA 2021-05-03 Valerie Stinger Menlo Park, CA 2021-05-03 Catherine Adcock Palo Alto, CA 2021-05-03 Melissa Baten Caswell Palo Alto, CA 2021-05-03 Eimear Picardo Palo Alto, CA 2021-05-03 Kristen Podulka Menlo Park, CA 2021-05-04 Dana Douglas Surprise, AZ 2021-05-04 Joslyn Leve Palo Alto, CA 2021-05-04 Valentina Zamarian Cupertino, CA 2021-05-04 Janna Maria Van Ringelestijn Palo Alto, CA 2021-05-04 linda lenoir Mountain View, CA 2021-05-04 Sally Bemus Palo Alto, CA 2021-05-04 Vivian Li Cromwell Palo Alto, CA 2021-05-04 Bob Miyahara Menlo Park, CA 2021-05-04 Monica Frassa Palo Alto, CA 2021-05-04 Christina Hood Palo Alto, CA 2021-05-04 Amy Brown Palo Alto, CA 2021-05-04 Christina Schmidt US 2021-05-04 Sarah Dellenbach Palo Alto, CA 2021-05-04 Federica Armstrong Palo Alto, CA 2021-05-04 Kiran Gaind Palo Alto, CA 2021-05-04 Irina Krupnik Palo Alto, CA 2021-05-04 Name Location Date Judy Leahy Palo Alto, CA 2021-05-04 Mary Burke Atherton, CA 2021-05-04 Kim Thacker Redwood City, CA 2021-05-04 Sonika Singal Palo Alto, CA 2021-05-04 Nancy Felch Palo Alto, CA 2021-05-04 Lindsay Vanderbeek Mountain View, CA 2021-05-04 Laura Prentiss US 2021-05-04 Richard Curtis Mountain View, CA 2021-05-04 Greg Hood San Ramon, CA 2021-05-04 Carolina Abbassi Los Angeles, CA 2021-05-04 jean-marc mommessin Sunnyvale, CA 2021-05-04 Manali Doshi Menlo Park, CA 2021-05-04 Jennifer Gonsalves Palo Alto, CA 2021-05-04 Mary akatiff Palo Alto, CA 2021-05-04 Katherine Murdock Greenland, AR 2021-05-04 Anna Bian Menlo Park, CA 2021-05-04 Jen Moxley Oakland, CA 2021-05-04 Jennifer Lang Sunnyvale, CA 2021-05-04 Elizabeth Sramek Medford, OR 2021-05-04 KATHRYN AKATIFF Palo Alto, CA 2021-05-04 Bobi Adle Palo Alto, CA 2021-05-04 Ellen Stromberg Palo Alto, CA 2021-05-04 Name Location Date Jill Asher Palo Alto, CA 2021-05-04 Laila Adle Aptos, CA 2021-05-04 Diana Adle Palo alto, CA 2021-05-04 Hiral Parekh Palo Alto, CA 2021-05-04 Carmela Abraham Palo Alto, CA 2021-05-04 Christopher Ritter Las Vegas, NV 2021-05-04 Anne-Sophie Mayos Palo Alto, CA 2021-05-04 Dayle Schweninger palo alto, CA 2021-05-04 Emika Abe Washington, DC 2021-05-04 Swati Solanki India 2021-05-04 Brandon Savage US 2021-05-04 Helena Katunaric San Jose, CA 2021-05-04 Marcy Shands-Brown Huntington Beach, CA 2021-05-04 Laurie Beyer Palo Alto, CA 2021-05-04 Karen Kwan Palo Alto, CA 2021-05-04 Paul Lazazzera Sacramento, CA 2021-05-04 Haley Carter Palo Alto, CA 2021-05-04 Christianna Kienitz Palo Alto, CA 2021-05-04 Laurie Walls Columbia City, IN 2021-05-04 Quinn Russell Olympia, WA 2021-05-04 Anju Chugh San jose, CA 2021-05-04 Jennifer Rodriguez East Palo Alto, CA 2021-05-04 Name Location Date patti Regehr Palo Alto Redwood City, CA 2021-05-04 Amara Holstein Palo Alto, CA 2021-05-04 Trish Jemison Palo Alto, CA 2021-05-04 Abby Lang Sunnyvale, CA 2021-05-04 shira l Buffalo Grove, IL 2021-05-04 Wendy Chou Palo Alto, CA 2021-05-04 Sierra Hill College Station, TX 2021-05-04 Annie Chan Palo Alto, CA 2021-05-04 Asawari Agrawal Palo Alto, CA 2021-05-04 Monmi Dutta Menlo Park, CA 2021-05-04 Marcela Millan Palo Alto, CA 2021-05-04 Jennifer Lee Thuresson Palo Alto, CA 2021-05-04 Christy Rice Palo Alto, CA 2021-05-04 Nirmala Patni Palo Alto, CA 2021-05-04 Adara Louis Palo Alto, CA 2021-05-04 Rena Kim Los Altos, CA 2021-05-04 Heather Gaillard Palo Alto, CA 2021-05-04 Lubia Chamo Palo Alto, CA 2021-05-04 Leah Russin Palo Alto, CA 2021-05-04 Ruchi Goyal Stanford, CA 2021-05-04 Lisa Barkin Oakland, CA 2021-05-04 Virginia Noh Palo Alto, CA 2021-05-04 Name Location Date Karen Dsouza Palo Alto, CA 2021-05-04 Chris Colohan Palo Alto, CA 2021-05-04 Priya Satia Stanford, CA 2021-05-04 Kusum Pandey Palo Alto, CA 2021-05-04 Raluca Perkins Palo Alto, CA 2021-05-04 Samara Meir-Levi Mountain View, CA 2021-05-04 Nicole Ardoin Stanford, CA 2021-05-04 Ashu Agrawal Palo Alto, CA 2021-05-04 Van Nguyen Palo Alto, CA 2021-05-04 Kristi Van Redwood City, CA 2021-05-04 Rachaell Mondino Mountain View, CA 2021-05-04 Joan Van Palo Alto, CA 2021-05-04 Mauro Mondino Palo Alto, CA 2021-05-04 Jonake Bose Palo Alto, CA 2021-05-04 Oindrila Ray Menlo Park, CA 2021-05-04 Tawni Escudero Palo Alto, CA 2021-05-04 Heidi Haukioja Palo Alto, CA 2021-05-04 Jane Gee Menlo Park, CA 2021-05-04 Karen Walker Sunnyvale, CA 2021-05-04 Kristen Haloski Palo Alto, CA 2021-05-04 Robin Walker Palo Alto, CA 2021-05-04 Agata Barczynska Palo Alto, CA 2021-05-04 Name Location Date Max Rosenblum New York, CA 2021-05-04 Brenda Dampier Palo Alto, CA 2021-05-04 Harish Ramadas Palo Alto, CA 2021-05-04 Pamela Weiss Palo Alto, CA 2021-05-04 Maya Blumenfeld Palo Alto, CA 2021-05-04 Marianna Shcherbelis Palo Alto, CA 2021-05-04 Jill Paldi Palo Alto, CA 2021-05-04 Tali Pilip San Francisco, CA 2021-05-04 Jacki Silber Foster City, CA 2021-05-04 Katherine Gipsh Sunnyvale, CA 2021-05-04 Shweta Goyal Los Altos, CA 2021-05-04 Mary Jane Marcus Palo Alto, CA 2021-05-04 Tamara Gracon Palo Alto, CA 2021-05-04 Nazy Attarzadeh Los Altos Hills, CA 2021-05-04 Cole Godvin Palo Alto, CA 2021-05-04 Natalia Smirnova Sunnyvale, CA 2021-05-04 Munazzah Hussain Palo Alto, CA 2021-05-04 Ashika Balani Redwood City, CA 2021-05-04 Varun Katta Palo Alto, CA 2021-05-04 Sarah Young Palo Alto, CA 2021-05-04 Julie Lin Palo Alto, CA 2021-05-04 Mark Fussell Palo Alto, CA 2021-05-04 Name Location Date Brian Carter Cherry Hill, NJ 2021-05-04 Megan Francis Muscatine, IA 2021-05-04 Andrew Arrow New York, NY 2021-05-04 Keli Gaines Los Angeles, CA 2021-05-04 Melissa sanders Palo Alto, CA 2021-05-04 Gabe Bauriedel Philadelphia, PA 2021-05-04 Sharon Clark Palo Alto, CA 2021-05-04 Diane Williams Sunnyvale, CA 2021-05-04 Karen Kesner Palo Alto, CA 2021-05-04 Julia Asher Palo Alto, CA 2021-05-04 Pamela Hornik Bronx, NY 2021-05-04 Purvi Kapafia Palo Alto, CA 2021-05-04 Annette Ross Palo Alto, CA 2021-05-04 Oriana Anholt Austin, TX 2021-05-04 Montana Griffin Los Altos Hills, CA 2021-05-04 Derek Wood Los Angeles, CA 2021-05-04 Bill Ross Palo Alto, CA 2021-05-04 Shailo Rao Palo Alto, CA 2021-05-04 Kavitha Tupelly Palo Alto, CA 2021-05-04 Lara Ephron Palo Alto, CA 2021-05-04 Amanda Stewart Morris Granite Bay, CA 2021-05-04 Laure Letelier Redwood City, CA 2021-05-04 Name Location Date Ashley Yee-Mazawa Mountain View, CA 2021-05-04 Patrik Westin Palo Alto, CA 2021-05-04 Sarah Lauing Redwood City, CA 2021-05-04 Sonia Gupta Belmont, CA 2021-05-04 Ritu Upreti Palo Alto, CA 2021-05-04 Kiran Joshi Palo Alto, CA 2021-05-04 Tammy Kwan Palo Alto, CA 2021-05-04 Shuchi Sarkar Palo Alto, CA 2021-05-04 Dylan Reinhardt San Francisco, CA 2021-05-04 Ratna Mirchandani California 2021-05-04 Ye Ding Palo Alto, CA 2021-05-04 Neerja Khaneja Palo Alto, CA 2021-05-04 R Rasmussen Altadena, CA 2021-05-04 Hemla Makan-Dullabh Palo Alto, CA 2021-05-04 Esteban Zacarias Palo Alto, CA 2021-05-04 Jillian Stirling Dar Es Salaam, Tanzania 2021-05-04 Hong-Cheol Kim Palo Alto, CA 2021-05-04 henny bhushan palo alto, CA 2021-05-04 Krishna Mehra Palo Alto, CA 2021-05-04 Prass Seth Palo Alto, CA 2021-05-04 Maura Tarnoff Palo Alto, CA 2021-05-04 Ashley Cupples-Lee Palo Alto, CA 2021-05-04 Name Location Date Ivana Maric Stanford, CA 2021-05-04 Kim Hill Campbell, CA 2021-05-04 Michele Wang Palo Alto, CA 2021-05-04 Shaheen Jamil San Francisco, CA 2021-05-04 Clea Sarnquist Palo Alto, CA 2021-05-04 Wati Grossman Palo Alto, CA 2021-05-04 Bridget Bradley Gray Bethesda, MD 2021-05-04 Jeanette Bahn Palo Alto, CA 2021-05-04 anna hurty oakland, CA 2021-05-04 Juan Aguirre San Jose, CA 2021-05-04 Elizabeth Schmidt Los Angeles, CA 2021-05-04 Laura Wingard Palo Alto, CA 2021-05-04 Vish Ponnampalam Portola Valley, CA 2021-05-04 Kimberley Wong Palo Alto, CA 2021-05-04 Mallary Alcheck Palo Alto, CA 2021-05-04 Boni Alvarez Los Angeles, CA 2021-05-04 Rebecca Beacom Palo Alto, CA 2021-05-04 Van Le Palo Alto, CA 2021-05-04 Kiran Khanna Palo Alto, CA 2021-05-04 Sandrine Clouin Palo Alto, CA 2021-05-04 Kyla Farrell Palo Alto, CA 2021-05-04 Caroline Roth Corte Madera, CA 2021-05-04 Name Location Date Teresa Kelleher Palo Alto, CA 2021-05-04 Barbara Peters, M.D.Palo Alto, CA 2021-05-04 Darrow Hornik Union City, CA 2021-05-04 Abbie McCoy Palo Alto, CA 2021-05-04 Kritika Jhalani Alameda, CA 2021-05-04 Christopher Smith Los Angeles, CA 2021-05-04 DeAnn Figley West Des Moines, US 2021-05-04 Maria Philbin Palo Alto, CA 2021-05-04 Olivia Wolfe Menlo Park, CA 2021-05-04 Iva Reid Palo Alto, CA 2021-05-04 Tom Dickinson Greer, SC 2021-05-04 Sati Banerjee Palo Alto, CA 2021-05-04 Caitlin Meyer China 2021-05-04 Ravi Kohli Fremont, CA 2021-05-04 Erin Brady Palo Alto, CA 2021-05-04 Sophia Vostrejs Palo Alto, CA 2021-05-04 Eloise Dumas Palo Alto, CA 2021-05-04 Mattia Brembilla Palo Alto, CA 2021-05-04 Katel Fong Palo Alto, CA 2021-05-04 Philipp Blume Champaign, IL 2021-05-04 Tanya Mehta Palo Alto, CA 2021-05-04 Rebecca Helft Palo Alto, CA 2021-05-04 Name Location Date Dror Sneh Palo Alto, CA 2021-05-04 sandy eggers san leandro, CA 2021-05-04 Kash Kapadia Palo Alto, CA 2021-05-04 Stephanie Compton Palo Alto, CA 2021-05-04 Jennifer Wang Palo Alto, CA 2021-05-04 Carrie Madsen Los Angeles, CA 2021-05-04 Laurel Robinson Palo Alto, CA 2021-05-04 TING AN LIN Palo Alto, CA 2021-05-04 Sarah Wilson San Mateo, CA 2021-05-04 Laurie Garcia Sunnyvale, CA 2021-05-04 Pallavi Tibrewal Palo Alto, CA 2021-05-04 Rishtha Alam Ashburn, US 2021-05-04 Karen Valeri Leominster, US 2021-05-04 Ngan Do Palo Alto, CA 2021-05-04 Sarah Curtis Palo Alto, CA 2021-05-04 Michael Abraham Palo Alto, CA 2021-05-04 Orphee Martin Palo Alto, CA 2021-05-04 Sabrina Wilensky Palo Alto, CA 2021-05-04 Sara Stojković Palo Alto, CA 2021-05-04 L Trovato Washington, DC 2021-05-04 Charu Gupta PALO ALTO, CA 2021-05-04 Ari Consul Seattle, US 2021-05-04 Name Location Date Melissa Roybal Palo Alto, CA 2021-05-04 Gill Ward Palo Alto, CA 2021-05-04 Heidi Emberling Palo Alto, CA 2021-05-04 Liz Smith Currrie Portland, OR 2021-05-04 Lisa Young Hallenbeck Palo Alto, CA 2021-05-04 Sylvana Habdank-Kolaczkowska Mountain View, CA 2021-05-05 Gina Silverman San Francisco, CA 2021-05-05 Rachel Sheridan Palo Alto, CA 2021-05-05 Lauren Sheridan Napa, CA 2021-05-05 Emily Morse Monrovia, CA 2021-05-05 Christine schlenker Palo Alto, CA 2021-05-05 Erica Lewis Palo Alto, CA 2021-05-05 Kirsten Luehrs Palo Alto, CA 2021-05-05 Nanda Garber Palo Alto, CA 2021-05-05 Nancy Berghold Redwood City, CA 2021-05-05 Sarahi Espinoza Palo Alto, CA 2021-05-05 melissa browne Las colinas, TX 2021-05-05 Martha Acosta Oertel Clifton Park, NY 2021-05-05 Dionne Zijlstra Palo Alto, CA 2021-05-05 Leilani Yau Palo Alto, CA 2021-05-05 Jennifer Chu Palo Alto, CA 2021-05-05 Name Location Date Priya Raghavan Palo Alto, CA 2021-05-05 Kirti Rao San Francisco, CA 2021-05-05 Aarti Johri Los Altos, CA 2021-05-05 Ananya Das Palo Alto, CA 2021-05-05 Lakshmi Muralidharan Palo Alto, CA 2021-05-05 Serena Bruckman Menlo Park, CA 2021-05-05 Laura Yu Palo Alto, CA 2021-05-05 Cynthia Costell Palo Alto, CA 2021-05-05 Stephanie Bradley US 2021-05-05 Aditee Kumthekar Menlo Park, CA 2021-05-05 Ruchita Parat Palo Alto, CA 2021-05-05 Emily Tucker Lafayette, CA 2021-05-05 Anupam Joshi Palo Alto, CA 2021-05-05 susan chamberlain palo alto, CA 2021-05-05 Maria Brown Menlo Park, CA 2021-05-05 Monica Ponce Santa Clara, CA 2021-05-05 Schwark Satyavolu Palo Alto, CA 2021-05-05 Lenore Delgado Palo Alto, CA 2021-05-05 Doree Tschudy Palo Alto, CA 2021-05-05 Arundhati Kotwal Palo Alto, CA 2021-05-05 Ann Ming Yeh Palo Alto, CA 2021-05-05 Jan Schachter Portola Valley, CA 2021-05-05 Name Location Date Hadassah Wurman Palo Alto, CA 2021-05-05 Sarah Greenberg Alameda, CA 2021-05-05 Kristan Green Palo Alto, CA 2021-05-05 Aleksandra Dudukovic Palo Alto, CA 2021-05-05 Pooja Mittal Palo Alto, CA 2021-05-05 Venky Karnam Palo Alto, CA 2021-05-05 Vikas Gupta Palo Alto, CA 2021-05-05 PRITI AGGARWAL Palo Alto, CA 2021-05-05 Saudamini Damarla Palo Alto, CA 2021-05-05 Maggie Ma Palo Alto, CA 2021-05-05 Kelly Chang Palo Alto, CA 2021-05-05 Colby Ranger Palo Alto, CA 2021-05-05 Adriana Rodriguez Menlo Park, CA 2021-05-05 merav arditi palo alto, CA 2021-05-05 Shruti Avasarala Palo Alto, CA 2021-05-05 Katherine Causey Palo Alto, CA 2021-05-05 Sri Yella Palo Alto, CA 2021-05-05 Maria Abilock Palo Alto, CA 2021-05-05 Amy Darling Palo Alto, CA 2021-05-05 sarabjit khanuja palo alto, CA 2021-05-05 Terry Jacobs Menlo Park, CA 2021-05-05 Ivana Madrigal Menlo Park, CA 2021-05-05 Name Location Date Kshama Jirage Sunnyvale, CA 2021-05-05 Sowmiya Parakalan Palo Alto, CA 2021-05-05 Donald Bauch New York, US 2021-05-05 Shana Segal Palo Alto, CA 2021-05-05 Gil Arditi Palo Alto, CA 2021-05-05 janiyah riggs Flower Mound, US 2021-05-05 Atul Kumar Palo Alto, CA 2021-05-05 Sunita Sarin Palo Alto, CA 2021-05-05 Eileen Stolee Palo Alto, CA 2021-05-05 Michelle Matson Palo Alto, CA 2021-05-05 Jessica Overton Palo Alto, CA 2021-05-05 Jaqueline Estrada Chicago, US 2021-05-05 Pam Chee Palo Alto, CA 2021-05-05 Penelope Van Tuyl San Francisco, CA 2021-05-05 CAROL KENYON Palo Alto, CA 2021-05-05 Marian Seah Palo Alto, CA 2021-05-05 Judith Content Palo Alto, CA 2021-05-05 Bryna Chang Palo Alto, CA 2021-05-05 Kathy Harrington Palo Alto, CA 2021-05-05 Sherry Heller Palo Alto, CA 2021-05-05 Sandra Robles Palo Alto, CA 2021-05-05 Diana Alvarez Kaba Palo Alto, CA 2021-05-05 Name Location Date Katie Christman Palo Alto, CA 2021-05-05 Svetlana Kazantseva Mountain View, CA 2021-05-05 Michelle Arden Menlo Park, CA 2021-05-05 Tali Klinger Palo Alto, CA 2021-05-05 Phillip Farrell Palo Alto, CA 2021-05-05 Luke Bell Port Angeles, US 2021-05-05 Selora Albin Palo Alto, CA 2021-05-05 Alison McNall Menlo Park, CA 2021-05-05 Francesca Milone Palo Alto, CA 2021-05-05 Eric Smith Palo Alto, CA 2021-05-05 Sue Yee Palo Alto, CA 2021-05-05 Joy Ku Palo Alto, CA 2021-05-05 Karin Garblik Palo Alto, CA 2021-05-05 Jane Lau Cupertino, CA 2021-05-05 Mandi Lin Menlo Park, CA 2021-05-05 Waverley Aufmuth Palo Alto, CA 2021-05-05 Chris Chen Palo Alto, CA 2021-05-05 Daniel Garblik Palo Alto, CA 2021-05-05 Yungning Teng Palo Alto, CA 2021-05-05 Jim Hugo Palo Alto, CA 2021-05-05 Jennifer Goltz-Taylor Ann Arbor, MI 2021-05-05 Vince Calson Fremont, CA 2021-05-05 Name Location Date Kathy Hsu Palo Alto, CA 2021-05-05 Cory Lee Palo atlo, CA 2021-05-05 Sam Wu Palo Alto, CA 2021-05-05 Verdi Kuo Palo Alto, CA 2021-05-05 Lydia Lee Palo Alto, CA 2021-05-05 Eric Rosenblum Palo Alto, CA 2021-05-05 Elaine Jek Palo Alto, CA 2021-05-05 Merav Berger Sunnyvale, CA 2021-05-05 Rebecca Ackroyd Woodside, CA 2021-05-05 Fei Luo Palo Alto, CA 2021-05-05 Susan Choquette Palo Alto, CA 2021-05-05 Christine Hmelar Palo Alto, CA 2021-05-05 Kim Randall Palo Alto, CA 2021-05-05 Brian Christman Palo Alto, CA 2021-05-05 Ilia Bortsov-Shrago Pacifica, CA 2021-05-05 Molly Christman Menlo Park, CA 2021-05-05 Susan Meade Palo Alto, CA 2021-05-05 Kinde Taye Washington, DC 2021-05-05 Carolyn Snow Yarmouth, ME 2021-05-05 Christine duval Menlo Park, CA 2021-05-05 Alisa Felise San Jose, CA 2021-05-05 Chris Gebert Parikh Palo Alto, CA 2021-05-05 Name Location Date Julie Kearney Palo Alto, CA 2021-05-05 Mathew Woodall Novato, CA 2021-05-05 Aaliyah Weidner Gulfport, US 2021-05-06 Jie Zhang Oak Park, CA 2021-05-06 Paulina Bozek Palo Alto, CA 2021-05-06 Gurmeet Lamba Saratoga, CA 2021-05-06 Jeanese Snyder Palo alto, CA 2021-05-06 Howard Kushlan Palo Alto, CA 2021-05-06 Alejandra Resendez Palo Alto, CA 2021-05-06 Sara Tune Toronto, Ontario, Canada 2021-05-06 Laura Van Los Angeles, CA 2021-05-06 Senem Akbas Palo Alto, CA 2021-05-06 Tiffany Shih Palo Alto, CA 2021-05-06 Marsha Smilovitz Palo Alto, CA 2021-05-06 susan stephens Tucson, AZ 2021-05-06 Cynthia Kocialski Palo Alto, CA 2021-05-06 Kayla Couillard Minneapolis, US 2021-05-06 Michelle Higgins Palo Alto, CA 2021-05-06 Prerana Jayakumar Palo Alto, CA 2021-05-06 Mayra Azanza Palo Alto, CA 2021-05-06 Phoenix Artifex Fremont, CA 2021-05-06 Patyy Cheng Palo Alto, CA 2021-05-06 Name Location Date Jenny hernandez National city, US 2021-05-06 Rebecca Mathew Palo alto, CA 2021-05-06 DARREN KAROPCZYC Redwood City, CA 2021-05-06 Kevin McCarty Cupertino, CA 2021-05-06 Jessie Becker Palo Alto, CA 2021-05-06 Katy Au Palo Alto, CA 2021-05-06 I Hate This App Atlanta, US 2021-05-06 Glenna Murillo San Jose, CA 2021-05-06 Jonathan Dickinson Middletown, CT 2021-05-06 Kaitlyn Nguyen Palo Alto, CA 2021-05-06 Janice Chan Palo Alto, CA 2021-05-06 Kerry Feinberg Palo Alto, CA 2021-05-06 Alex G Phoenix, US 2021-05-06 Melissa Graney Palo Alto, CA 2021-05-06 Heather Howard Palo Alto, CA 2021-05-06 Tanya Ghosh Palo Alto, CA 2021-05-06 Jessica Resmini Palo Alto, CA 2021-05-06 Sunitha Velpula Palo Alto, CA 2021-05-06 Rebecca Griner Palo Alto CA 94303, CA 2021-05-06 Wesley Barton Mountain View, CA 2021-05-06 Jessica Cox Redwood City, CA 2021-05-06 Sonia Orduna Lancaster, US 2021-05-06 Name Location Date Anne Orme Palo Alto, CA 2021-05-06 Soo Ooo Chicago, US 2021-05-06 Parul Sharma Palo Alto, CA 2021-05-06 Marjorie Gonzalez Arlington, US 2021-05-06 Jailed Reyes-Rivera Libertyville, US 2021-05-06 Siejen Yin-Stevenson Chicago, IL 2021-05-06 Viviriana Guerra Houston, US 2021-05-06 Dionne Warm Palo Alto, CA 2021-05-06 Kate Spain Gulfport, MS 2021-05-06 Vanesa Barrera Austin, US 2021-05-06 Ashley Keyes Mount Vernon, US 2021-05-06 Hitomi Medinas San Francisco, US 2021-05-06 Woosan’s Child Reno, US 2021-05-06 Erhyu Yuan Palo Alto, CA 2021-05-06 Jenny Truong Palo Alto, CA 2021-05-06 Amy Keohane Palo Alto, CA 2021-05-06 Daxue Xu Stanford, CA 2021-05-06 Sean Mccarty San Francisco, CA 2021-05-06 Sue Chan Santa Clara, CA 2021-05-06 Bunny Bornstein Mountain View, CA 2021-05-06 Gary Wetzel Palo Alto, CA 2021-05-06 Tammy Truher Palo Alto, CA 2021-05-06 Name Location Date Audrey-Anne Green Palo Alto, CA 2021-05-06 Melinda Christopherson Palo Alto, CA 2021-05-06 Warren Durrett Palo Alto, CA 2021-05-06 T Fong Palo Alto, CA 2021-05-06 Mayma Raphael Palo Alto, CA 2021-05-06 Carol Leonard Palo Alto, CA 2021-05-06 Leon Kaplan Little Rock, AR 2021-05-06 Teresa Lunt Palo Alto, CA 2021-05-06 Christine Jeffers Santa Clara, CA 2021-05-06 Diana Fong Palo Alto, CA 2021-05-06 Ebony Owens Holmdel, US 2021-05-06 Jane Smith Palo Alto, CA 2021-05-06 Yoko Yanagisawa Palo Alto, CA 2021-05-06 Amy Lee Palo Alto, CA 2021-05-06 Ilanit Gal Menlo Park, CA 2021-05-06 Susie Idzik Redwood City, CA 2021-05-06 Isabelle Goodlow Lebanon, US 2021-05-06 Aisha Zakariya Palo Alto, CA 2021-05-06 Amy Wright Palo Alto, CA 2021-05-06 Elizabeth Adamo Palo Alto, CA 2021-05-06 Lydia Callaghan Palo Alto, CA 2021-05-06 Mary Ann Gee Palo Alto, CA 2021-05-06 Name Location Date Wendie Karel Palo Alto, CA 2021-05-06 Cindy Hess Los Angeles, CA 2021-05-06 Adam Kaluba Burleson, US 2021-05-06 deidre silverman san rafael, CA 2021-05-06 Gale Heringer-Brock Palo Alto, CA 2021-05-06 Jason Heil Spring Valley, CA 2021-05-06 Amy Kacher Palo Alto, CA 2021-05-06 Kirstin Sego Palo Alto, CA 2021-05-06 Jennifer Lee Palo Alto, CA 2021-05-06 Maria Mangiavellano San Diego, CA 2021-05-06 Elli Kaplan Redwood City, CA 2021-05-06 Katharine Saunders Palo Alto, CA 2021-05-06 Nathaniel Johnson Mountain View, CA 2021-05-06 Susan Woodman Palo Alto, CA 2021-05-06 Patrick Rabita Palo Alto, CA 2021-05-06 Jeff Chamberlin Truckee, CA 2021-05-06 Andrea Helft Palo Alto, CA 2021-05-06 Anna Fankhauser Santa Clara, CA 2021-05-06 Jyoti Sahdev Mountain View, CA 2021-05-06 Susie Levine Palo Alto, CA 2021-05-06 Missy Reller Palo Alto, CA 2021-05-06 Edjozane Cirne Palo Alto, CA 2021-05-06 Name Location Date Cheryl Gallegos OR, US 2021-05-06 Lucy Berman Palo Alto, CA 2021-05-06 Cecilia Gyllenram Palo Alto, CA 2021-05-06 Karrie Huang Palo Alto, CA 2021-05-06 Melissa V.Union City, US 2021-05-06 Margaux Millman Mountain View, CA 2021-05-06 Maggie Choy Palo Alto, CA 2021-05-06 Carol Uyeno Palo Alto, CA 2021-05-06 Peter Stansky Burlingame, CA 2021-05-06 Catherine Enos Palo Alto, CA 2021-05-06 Ariel Echevarria Philadelphia, US 2021-05-06 Charlotte Cutkosky Palo Alto, CA 2021-05-06 Ingrid Donahue Kirkwood, US 2021-05-06 McHale Newport-Berra Palo Alto, CA 2021-05-06 Peter Rothschild Oakland, CA 2021-05-06 Anne Corning Kirkland, WA 2021-05-06 Yasuko Koide コスタメサ, US 2021-05-06 Adrienne Haynes Jamaica, US 2021-05-06 lannie weng palo alto, CA 2021-05-06 Christine Meyer Palo Alto, CA 2021-05-06 Andrés E. Juliá Yauco, US 2021-05-06 Malaikah Zulfiqar Brooklyn, US 2021-05-06 Name Location Date Debra Cen Sunnyvale, CA 2021-05-06 Michelle Mazzuchi South San Francisco, CA 2021-05-06 hennesey rogel Los Angeles, US 2021-05-06 Rylee Harris Allen, US 2021-05-06 Sean Volavong Fayetteville, AR 2021-05-06 Nathaniel Lang US 2021-05-06 Gloria zhang Palo Alto, CA 2021-05-06 Kim Kohli San Jose, CA 2021-05-06 Mary Lee MacKichan Palo Alto, CA 2021-05-06 Nevaeh W Elgin, US 2021-05-06 Sasha Chriss Portola Valley, CA 2021-05-06 Judith Wasserman Palo Alto, CA 2021-05-06 olivia hennessy Orlando, US 2021-05-06 judy blair San Diego, CA 2021-05-06 Laurie Levy Palo Alto, CA 2021-05-06 Carol Kumer Palo Alto, CA 2021-05-06 Katrin Beauchaud Sunnyvale, CA 2021-05-06 Cynthia Roberts Menlo Park, CA 2021-05-06 Kathryn Kobza Menlo Park, CA 2021-05-06 Vidya Rangaswamy Palo Alto, CA 2021-05-06 Lauren Briskin Pali Alto, CA 2021-05-06 Barbara Collins Palo Alto, CA 2021-05-06 Name Location Date Hahsh Dhdhdhd Jacksonville, US 2021-05-06 Isabel Caldera Costa Mesa, US 2021-05-06 Helena Cirne Palo Alto, CA 2021-05-06 Mrudula Penta Dallas, TX 2021-05-06 Mounir Ramzi West Haven, US 2021-05-06 Giovanni Munoz San Francisco, US 2021-05-06 Haley Hanson Lakeside, US 2021-05-06 Shivanie Sukdeo South Richmond Hill, US 2021-05-06 Victoria Venegas Detroit, US 2021-05-06 Kathryn Cole Hinsdale, US 2021-05-06 Isabelly Marini Kissimmee, US 2021-05-06 Frida Marmolejo Chula Vista, US 2021-05-06 Jo Brumfield Harrisonburg, US 2021-05-06 Sarah Payne Palo Alto, CA 2021-05-06 Carol Smith Pleasanton, CA 2021-05-06 Evariste Deprey Menlo Park, CA 2021-05-06 Ying Zhu Palo Alto, CA 2021-05-06 Melissa Domingo Spring Valley, US 2021-05-06 Sylvia Gartner Palo Alto, CA 2021-05-06 Bailey Luck Dothan, US 2021-05-06 Olgalydia Winegar Redwood City, CA 2021-05-06 Priscilla Cruz-Rincon Pasadena, US 2021-05-06 Name Location Date Kessiah Taylor Chester, US 2021-05-06 Linda Filo Palo Alto, CA 2021-05-06 Susan Bush Palo Alto, CA 2021-05-06 Ninel Kushchenko Palo Alto, CA 2021-05-06 Maya Adam San Francisco, CA 2021-05-06 Ariana Birchler Conway, US 2021-05-06 Melanie Norall Palo Alto, CA 2021-05-06 Harriet Stern Palo Alto, CA 2021-05-06 James Kephart Tallahasse, US 2021-05-06 Laura Sturino Menlo Park, CA 2021-05-06 Maya Mazor-Hoofien Palo Alto, CA 2021-05-06 Jennifer Walsh Oakland, CA 2021-05-06 Karyssa Laing Bradenton, US 2021-05-06 Jonna Hunter Menlo Park, CA 2021-05-06 kenya gomez Los Angeles, US 2021-05-06 Sarai Lopez Pomona, US 2021-05-06 Queenie Huang Palo Alto, CA 2021-05-06 Angela Evans Incline Village, NV 2021-05-06 Karina Cruz Grand Prairie, US 2021-05-06 Leah Mejia El Paso, US 2021-05-06 Hailey Truman Des Moines, US 2021-05-06 Linda Mills Atherton, CA 2021-05-06 Name Location Date Joyce Liang Palo Alto, CA 2021-05-06 Jeno Garcia Lancaster, US 2021-05-06 Linda Craighead Santa Cruz, CA 2021-05-06 Thomas Mazzuchi South San Francisco, CA 2021-05-06 jayda sims Plaquemine, US 2021-05-06 Anke Delingat San Francisco, CA 2021-05-06 Salma Alba Santa Ana, US 2021-05-06 Jasmin Villalba Davis, US 2021-05-06 Nayeli Gonzalez Miami, US 2021-05-06 Lauren Altemare Hilliard, US 2021-05-06 Edgar Serna Tyler, US 2021-05-06 Ana Maria Lasala Menlo Park, CA 2021-05-06 Dale Taylor Vancouver, US 2021-05-06 Arturo vaquero Clifton, US 2021-05-06 Sam Sing Palo Alto, CA 2021-05-06 Maddie LastName Jacksonville, US 2021-05-06 Teresa Sierra Mountain View, CA 2021-05-06 Leisa McNeese Palo Alto, CA 2021-05-06 Sebastian Garzon Elizabeth, US 2021-05-06 Jongmin Sung Palo Alto, CA 2021-05-06 Cassie Low Toms River, US 2021-05-06 Jackson Aldrich Los Altos, CA 2021-05-06 Name Location Date Samantha Callaghan Sydney, Australia 2021-05-06 Karen Perone Redwood City, CA 2021-05-06 liz price Palo Alto, CA 2021-05-06 darius english Hephzibah, US 2021-05-06 Isabelle Camarillo Elk Grobe, US 2021-05-06 Rogan Joe YoMama, US 2021-05-06 Ayse Aba Palo Alto, CA 2021-05-06 Lillian Chen Palo Alto, CA 2021-05-06 Tina Chang Palo Alto, CA 2021-05-06 Anne Taylor Palo Alto, CA 2021-05-06 Lara Cardamone Palo Alto, CA 2021-05-06 Fernanda Cabrera Magnolia, US 2021-05-06 Amit Costa Palo Alto, CA 2021-05-06 David Hong Houston, US 2021-05-06 Shae McLaws Oakland, US 2021-05-06 Michelle Lee Philadelphia, US 2021-05-06 Boaz Maor US 2021-05-06 Annemarie Lekkerkerker Palo Alto, CA 2021-05-06 Juliet Halder Loma Linda, US 2021-05-06 Nayely Galvez Dallas, US 2021-05-06 Tina Puga Mundelein, US 2021-05-07 Reecha Tandon Cupertino, CA 2021-05-07 Name Location Date Isabela Benavides Bloomington, US 2021-05-07 Landen Morrow Lewistown, US 2021-05-07 Bella Figueroa Dallas, US 2021-05-07 Rocio Hernandez Pomona, US 2021-05-07 Lily Chiu Palo Alto, CA 2021-05-07 Julisa Reyes Aurora, US 2021-05-07 Leslie Mathis Aurora, US 2021-05-07 Simon Firth Palo Alto, CA 2021-05-07 Patricia Kinney Palo Alto, CA 2021-05-07 areeba iqbal Brooklyn, US 2021-05-07 Ella Walsh Deptford, US 2021-05-07 Aniya Ross Oakland, CA 2021-05-07 William Rivera Norcross, US 2021-05-07 Vincent Barletta Palo Alto, CA 2021-05-07 Eva Antonio Stanford, CA 2021-05-07 Brinda Govindan Menlo Park, CA 2021-05-07 Jesse Ladomirak Palo Alto, CA 2021-05-07 Michele Sharkey Los Altos, CA 2021-05-07 Taylor Bennett Las Vegas, US 2021-05-07 Marissa Mendoza Odessa, US 2021-05-07 Hugh Janus Seattle, US 2021-05-07 Medha Nanal Palo Alto, CA 2021-05-07 Name Location Date Dawn Herian Lockport, US 2021-05-07 richard weber Corona, US 2021-05-07 Jamal Lawson Cincinnati, US 2021-05-07 Nancy Canter Cupertino, CA 2021-05-07 brianna paredes Levittown, US 2021-05-07 Syed Ahmed Floral Park, US 2021-05-07 Yitsel Garcia Santa Maria, US 2021-05-07 Melissa Amoss Ellicott City, US 2021-05-07 Roberta Lamanda Palo Alto, CA 2021-05-07 Christopher Dunlap Palo Alto, CA 2021-05-07 JoAnn and Ken Edwards Palo Alto, CA 2021-05-07 Stacia Sarna Santa Clara, CA 2021-05-07 Nancy Krop Palo Alto, CA 2021-05-07 Keri Wagner Palo Alto, CA 2021-05-07 Sarah Cornwell Palo Alto, CA 2021-05-07 Erin Tylutki Bellevue, US 2021-05-07 Delaney Hampton Chicago, US 2021-05-07 Alan Yang Palo Alto, CA 2021-05-07 Lisa Fremont Palo Alto, CA 2021-05-07 Gene Lee South Hamilton, US 2021-05-07 Marguerite Fletcher Palo alto, CA 2021-05-07 Lina Sosa Temecula, US 2021-05-07 Name Location Date Kimberly Klikoff Palo Alto, CA 2021-05-07 Elizabeth Hammerman Palo Alto, CA 2021-05-07 Darlyn Estevez Perth Amboy, US 2021-05-07 Madigan Primmer Maple Grove, US 2021-05-07 Rosita Newman Redwood City, CA 2021-05-07 Laura Mendez-Ortiz Sacramento, CA 2021-05-07 Bonnie Jaffey Palo Alto, CA 2021-05-07 Aubrey Packard Medford, US 2021-05-07 Smriti K Palo Alto, CA 2021-05-07 Kalli Devaraj Palo alto, CA 2021-05-07 Briquelle Rich Magna, US 2021-05-07 Bob Rodriguez Winnetka, US 2021-05-07 Suman Gupta Menlo Park, CA 2021-05-07 Carol Rogers Palo Alto, CA 2021-05-07 Alexa P.Watsonville, US 2021-05-07 Alexis Enriquez Los Angeles, US 2021-05-07 Prisha Gupta Euless, US 2021-05-07 Dan St. Peter Alliston, Ontario, Canada 2021-05-07 Monica Lozano Azle, US 2021-05-07 Neela Kulkarni Palo Alto, CA 2021-05-07 Jason Curley Bethesda, US 2021-05-07 Rui Guo San Jose, CA 2021-05-07 Name Location Date Nohemi Page La Puente, US 2021-05-07 Athena Ly Aurora, US 2021-05-07 bailee cassidy Fayetteville, US 2021-05-07 June Wang Palo Alto, CA 2021-05-07 Zhi Zhang Cupertino, CA 2021-05-07 Alexis Velazquez Houston, US 2021-05-07 lupita flores Sacramento, US 2021-05-07 Catherine Ying Palo Alto, CA 2021-05-07 Assaf Cohen Los Angeles, CA 2021-05-07 Cassandra Waters San Antonio, US 2021-05-07 Lohatany Argueta Aurora, US 2021-05-07 Yang Han Palo Alto, CA 2021-05-07 Tamar Salant Acton, US 2021-05-07 laurie Jackler Stanford, CA 2021-05-07 Kassidy Tucker Brooklyn, US 2021-05-07 Casey Withers Ashland City, US 2021-05-07 Mahima Gauchan Chandler, US 2021-05-07 Hannah Garcia Duncanville, US 2021-05-07 Kimberly Gavenman Los Altos, CA 2021-05-07 Angelica Garcia Indianapolis, US 2021-05-07 Lynn Grant Palo Alto, CA 2021-05-07 Jacqueline Wahl Gary, US 2021-05-07 Name Location Date Elysha Rivera Margate, US 2021-05-07 Paula Collins Menlo Park, CA 2021-05-07 audra hay Perkins, US 2021-05-07 Ann Mendenhall Palo Alto, CA 2021-05-07 Alyssa Gutierrez Austin, US 2021-05-07 Natalie Guerrero Austin, US 2021-05-07 Mark Saleh Palo Alto, CA 2021-05-07 Joan Phelan Palo Alto, CA 2021-05-07 Evgeniia Sukhodolskaia San Ramon, US 2021-05-07 Ashlyn Campbell Walled lake, US 2021-05-07 Rev. Amy Zucker Morgenstern San Francisco, CA 2021-05-07 Sylvia Seibert Palo Alto, CA 2021-05-07 Why Not Selinsgrove, US 2021-05-07 elaine suh Coppell, US 2021-05-07 Aulbany Tuttle Copperas Cove, US 2021-05-07 Gaby DiMuro Redwood City, CA 2021-05-07 Sara Johnson Lodi, US 2021-05-07 Michael Ester Chicago, US 2021-05-07 S Vora Palo Alto, CA 2021-05-07 Cecile Limborg Palo Alto, CA 2021-05-07 Daisy Troche Arlington, US 2021-05-07 brooke duncan Clarendon, US 2021-05-07 Name Location Date JUSTIN FROST Phoenix, US 2021-05-07 isabel viramontes Van Nuys, US 2021-05-07 zo m Nashville, US 2021-05-07 Aarohi Shah Palo Alto, CA 2021-05-07 Anthony Kienitz Palo Alto, CA 2021-05-07 Amanda Salisbury Mountain View, CA 2021-05-07 Mia Nam Palo Alto, CA 2021-05-07 Benigne Deprey Palo Alto, CA 2021-05-07 Jasmine Fan Palo Alto, CA 2021-05-07 Monica Williams Greenville, US 2021-05-07 justice arca Wesley Chapel, US 2021-05-07 saulo mora chicago, US 2021-05-07 Jessica Zhangerz Ithaca, US 2021-05-07 Anita Tran Menlo Park, CA 2021-05-07 Katherine Avila Palo Alto, CA 2021-05-07 Alonzo Capers Exmore, US 2021-05-07 Nicole Berry Palo Alto, CA 2021-05-07 Wendy Liu Palo Alto, CA 2021-05-07 Xin Li Palo Alto, CA 2021-05-07 Avroh Shah Palo Alto, CA 2021-05-07 Sophie He Palo Alto, CA 2021-05-07 Jaiveer Dalal Palo Alto, CA 2021-05-07 Name Location Date Hart Walsh Palo Alto, CA 2021-05-07 Meredith Vostrejs Redwood City, CA 2021-05-07 Myranda Shepard Arlington, US 2021-05-07 suzi manbeck Palo Alto, CA 2021-05-07 Jennifer Halligan Pioneer, US 2021-05-07 geraldine chan Menlo Park, CA 2021-05-07 Anant Singh Palo Alto, CA 2021-05-07 Valerie Leonard monroe, US 2021-05-07 Heidy Garay Silver Spring, US 2021-05-07 Krishna Dick Arlington, US 2021-05-07 Audrey Schwarz Kutztown, US 2021-05-07 DIana Avez Forest Hills, US 2021-05-07 Frank Fan Palo Alto, CA 2021-05-07 Frances Perry Menlo Park, CA 2021-05-07 Ranya Boussaha Dayton, US 2021-05-07 Rhiannon Dorough Franklin, US 2021-05-07 Romina Reyes Covington, US 2021-05-07 Ming Zhao Palo Alto, CA 2021-05-07 Robin Ronci Phoenix, US 2021-05-07 Gina Marin Joliet, US 2021-05-07 Heng Zhang Castro Valley, CA 2021-05-07 Alexis Christian Bakersfield, US 2021-05-07 Name Location Date Robert Primous Brooklyn, NY 2021-05-07 Amanda Sheldon Stanford, CA 2021-05-07 Sheridan Harville Westmoreland, US 2021-05-07 Zhongjue Tang San Francisco, CA 2021-05-07 Susan Moskowitz Palo Alto, CA 2021-05-07 Stacey Wissmann Milford, US 2021-05-07 Sharon Robinson Palo Alto, CA 2021-05-07 Marc Finot Palo Alto, CA 2021-05-07 Kate Denson Edwardsville, US 2021-05-07 Pooja Oysgelt Palo Alto, CA 2021-05-07 David Ephron Menlo Park, CA 2021-05-07 Treecraft idk New York, US 2021-05-07 Nicki Moffat Palo Alto, CA 2021-05-07 Aleks Oysgelt Palo Alto, CA 2021-05-07 Madeline Benitez Denton, US 2021-05-07 Kristin Stout Redwood City, CA 2021-05-07 Tssneem Shehadeh Mount Vernon, US 2021-05-07 Barb Jaarsma Palo Alto, CA 2021-05-07 Indira S Palo Alto, CA 2021-05-07 Jonny Thaw Palo Alto, CA 2021-05-07 Kenya Segura Chicago, US 2021-05-07 Herma Jh Palo Alto, CA 2021-05-07 Name Location Date Fernanda Chavarria Springfield, US 2021-05-07 Beiguang Zhang Palo Alto, CA 2021-05-07 Darshana Greenfield Menlo Park, CA 2021-05-07 Betty M Dallas, US 2021-05-07 Hayley Netzel Sewickley, US 2021-05-07 Wendy Fong Palo Alto, CA 2021-05-07 Leslie Silva Fort Worth, US 2021-05-07 Lydia Hwang Palo Alto, CA 2021-05-07 Jennifer liu Palo Alto, CA 2021-05-07 Stacy Kunnassery Mountain View, CA 2021-05-07 Ina Lee SANTA CRUZ, US 2021-05-07 Sunny Zhai Palo Alto, CA 2021-05-07 Emily Alicea Orlando, US 2021-05-07 Yiru Wu Palo Alto, CA 2021-05-07 Jeiri Payano Sicklerville, US 2021-05-07 Michelle Nguyen Santa Clara, CA 2021-05-07 Jun Wang Palo Alto, CA 2021-05-07 Ian Teter Gilroy, CA 2021-05-07 Michelle Coyle Palo Alto, CA 2021-05-07 Joanna Gao Palo Alto, CA 2021-05-07 Arely Flores Worthington, US 2021-05-07 Emigdio Lua La Quinta, US 2021-05-07 Name Location Date Riki Morita Palo Alto, CA 2021-05-07 Bin He Palo Alto, CA 2021-05-07 Teresa Chen Palo Alto, CA 2021-05-07 jie liu san jose, CA 2021-05-07 Jasmin Pacheco Windsor, US 2021-05-07 Charlotte Fu Palo Alto, CA 2021-05-07 Robert Wilson Palo Alto, CA 2021-05-07 Madison Warren Arlington, US 2021-05-07 Stanley Wong Palo Alto, CA 2021-05-07 Ruby Lopez Phoenix, US 2021-05-07 David Callaghan Sydney, Australia 2021-05-07 Ann McCown Menlo Park, CA 2021-05-07 Coreen Riley Palo Alto, CA 2021-05-07 Jennifer Medeiros Sunnyvale, CA 2021-05-07 Susan Bradley palo alto, CA 2021-05-07 marian slattery Palo Alto, CA 2021-05-07 Deborah Dauber San Francisco, CA 2021-05-07 Guillaume du Pontavice Palo Alto, CA 2021-05-07 Chris Brusseau Longview, WA 2021-05-07 Courtney Sanchez San Diego, CA 2021-05-07 Dylan Jones Medford, US 2021-05-07 Tom O Connor Palo Alto, CA 2021-05-07 Name Location Date Adam Louchahi Boston, US 2021-05-07 Jeff Alexander Dulzura, CA 2021-05-07 Mark Zappia Victorville, CA 2021-05-07 Mia Han Allen, US 2021-05-07 Rona Yang Menlo Park, CA 2021-05-07 Soumya Krishnamoorthy Palo Alto, CA 2021-05-07 Mridula Parikh Palo Alto, CA 2021-05-07 Laurence Pichot Palo Alto, CA 2021-05-07 Rosalie Taimuty Palo Alto, CA 2021-05-07 Julie Ustin Solana Beach, CA 2021-05-07 Kristin Dudley Tifton, US 2021-05-07 Qiong Mao Palo alto, CA 2021-05-07 Shoshana Leeder Palo Alto, CA 2021-05-07 Patrick Molina San Antonio, US 2021-05-07 Heather Silverman Palo Alto, CA 2021-05-07 Dari Lawrence Nashville, US 2021-05-07 Carol Lynn Palo Alto, CA 2021-05-07 Seth Gonzales Houston, US 2021-05-07 David Minor Koloa, HI 2021-05-07 Nisma Ali New hyde park, US 2021-05-07 Carolyn Vozzo Brooklyn, NY 2021-05-07 Richard Dixon Jamaica, US 2021-05-07 Name Location Date jasarah durga Bowling Green, US 2021-05-07 James Lin San Mateo, CA 2021-05-07 Lisa Austin Palo Alto, CA 2021-05-07 Kathleen Hennerty Brooklyn, NY 2021-05-07 Tina Li Palo Alto, CA 2021-05-07 Julius Rosser Oxford, US 2021-05-07 Harley Windsor Lusby, US 2021-05-07 Kelly Q Oakland, US 2021-05-07 Cy Ashley Webb Boxborough, MA 2021-05-07 Brookelynn Lawrence Athol, US 2021-05-07 Juleeanna Willems Purcell, US 2021-05-07 Charli Lootens Clearfield, US 2021-05-07 Alexia Logan Mount Vernon, US 2021-05-07 Carrie Riggins Palo Alto, CA 2021-05-07 Robert Fletcher Palo Alto, CA 2021-05-07 Bhagyalaxmi Bethala Palo Alto, CA 2021-05-07 Liisi Esse Palo Alto, CA 2021-05-07 Patama Gur Palo Alto, CA 2021-05-07 Leslie Braun Palo Alto, CA 2021-05-07 Alli Gilden Washington, DC 2021-05-07 Kim Veatch Columbus, US 2021-05-07 Anshu Khurana Palo Alto, CA 2021-05-07 Name Location Date Hila Martonovich Oakland, CA 2021-05-07 Christopher Lewis Miami, FL 2021-05-07 Shanacea Hankins Indiana, US 2021-05-07 Janiyah Rodriguez North Port, US 2021-05-07 Edonis Islami Snellville, US 2021-05-07 Tina Semba Palo Alto, CA 2021-05-07 Halisha Casimir Brooklyn, US 2021-05-07 Olee P Riverside, CA 2021-05-07 Rebecca Wolpinsky Oakland, CA 2021-05-07 Anne DiPasquale Palo Alto, CA 2021-05-07 GBEH 1 US 2021-05-07 Aaron Blumenkranz Newport Beach, CA 2021-05-07 Laurel Fleck San Jose, CA 2021-05-07 David Collins Palo Alto, CA 2021-05-07 Kevin Torres Brooklyn, US 2021-05-07 Jaylin Ortega Flushing, US 2021-05-07 Nahomie Gelin Palm Bay, US 2021-05-07 Camila Lucia Winston-salem, US 2021-05-07 laeani perreault Lakeville, US 2021-05-07 Christine Logan Palo Alto, CA 2021-05-07 jennifer basiji los altos hills, CA 2021-05-07 Carolyn Tucher Palo Alto, CA 2021-05-07 Name Location Date hfsdufjhds eetgewyew Buffalo, US 2021-05-07 Jennifer Pastran Palo Alto, CA 2021-05-07 yuet berry Palo Alto, CA 2021-05-07 Anna Anderson US 2021-05-07 Reed Newman Barstow, CA 2021-05-07 Elisa Steele Mountain View, CA 2021-05-07 Gordon Craig Menlo Park, CA 2021-05-07 jamie Case Tampa, US 2021-05-07 Spencer Benda Pasadena, CA 2021-05-07 Thomas Kudasz O Fallon, IL 2021-05-07 Victoria Quertermous stanford, CA 2021-05-07 Anya Vargas Bridgewater, US 2021-05-07 Clarissa Shen Palo Alto, CA 2021-05-07 Ester Salinas The colony, US 2021-05-07 Pam Richman Northridge, CA 2021-05-07 Christiane Haase Menlo Park, CA 2021-05-07 Diana Darcy Palo Alto, CA 2021-05-07 James Watson San Jose, CA 2021-05-07 Natalia Simanovskaia Palo Alto, CA 2021-05-07 Rebecca Gruwell Layton, US 2021-05-07 Karen Sachs Canoga Park, CA 2021-05-07 Dorothy SAXE Menlo Park, CA 2021-05-07 Name Location Date Tahmina Bhuiyan Brooklyn, US 2021-05-07 Crystal Mcdavid New Bern, US 2021-05-07 Anders Klemmer Menlo Park, CA 2021-05-07 Ryota Ogura Menlo Park, CA 2021-05-07 Nora Matta Palo Alto, CA 2021-05-07 lucero garcia chicago, US 2021-05-07 Dora Pang Menlo Park, CA 2021-05-07 syed hasan Palo Alto, CA 2021-05-07 Jose Heredia East Palo Alto, CA 2021-05-07 Sandra Wallace Canyon Country, CA 2021-05-07 Linda Dooley Palo Alto, CA 2021-05-07 Judy Horst Menlo Park, CA 2021-05-07 Parisa Safa Sunnyvale, CA 2021-05-07 Vered Hermannoff-Kranz Palo Alto, CA 2021-05-07 Emilie Hung Palo Alto, CA 2021-05-07 Dorothy Shrager Stanford, CA 2021-05-07 Bobby duncan Rex, US 2021-05-07 Mary Huynh San Francisco, US 2021-05-07 SYTHA MCCRAY El Sobrante, US 2021-05-07 RiveR Pearson Grand Junction, US 2021-05-07 Barbara Heneveld Paso Robles, CA 2021-05-07 Heather Dischler Palo Alto, CA 2021-05-07 Name Location Date Jerry Dischler Palo Alto, CA 2021-05-07 Lawrence Garwin Palo Alto, CA 2021-05-07 Elliott Cooley Snowshoe, US 2021-05-07 Carolina Sanchez Houston, US 2021-05-07 Ethan Gallacher Austin, US 2021-05-07 Lilly Soska Shalimar, US 2021-05-07 Vanessa Rico Santa Ynez, US 2021-05-07 Julie O'Grady Palo Alto, CA 2021-05-07 Lisa Voge-Levin Palo Alto, CA 2021-05-07 Molly Peterson Chaska, US 2021-05-07 Arleigh Barbour Staunton, US 2021-05-07 Italia Sanchez Odessa, US 2021-05-07 Syloun Renger Lakewood, US 2021-05-07 Elianna Bass Los Angeles, CA 2021-05-07 Hanne Bentz, Ph.D. Bentz Palo Alto, CA 2021-05-07 Keith Southern Palo Alto, CA 2021-05-07 kirsten leimroth Palo Alto, CA 2021-05-07 htiens avils ed Sylva, US 2021-05-07 Angelica Cortez Inglewood, US 2021-05-07 Angelica Estrada Palo Alto, CA 2021-05-07 Karen Neier Palo Alto, CA 2021-05-07 Paige Sweetin US 2021-05-07 Name Location Date Shela Fisk Palo Alto, CA 2021-05-07 Destiny Bartley Blackwood, US 2021-05-07 Casey Mitchell Scottsdale, US 2021-05-07 Nathan Fahrenthold Palo Alto, CA 2021-05-07 Robert Dey Ocala, US 2021-05-07 Jamie Howe Stratford, CA 2021-05-07 Katherine Leyva Wimbledon, UK 2021-05-07 Susan Kaye Palo Alto, CA 2021-05-07 A. Delaney Menlo Park, CA 2021-05-07 Sue Purdy Pelosi PAlo alto, CA 2021-05-07 Thy Flame Mitchell, US 2021-05-07 Aliyah Savage Aurora, US 2021-05-07 Mel Day Palo Alto, Canada 2021-05-07 Priya Venkatesh Palo Alto, CA 2021-05-07 Ethan Rogers Marshall, US 2021-05-07 Sharon Hoffman Palo Alto, CA 2021-05-07 Shirley Klynn Palo Alto, CA 2021-05-07 Barbara Simmonds Palo Alto, CA 2021-05-07 Bethany Willett West Lafayette, IN 2021-05-07 Signe Mayfield Palo Alto, CA 2021-05-07 Parag Patel Palo Alto, CA 2021-05-07 Abigail Alfieri Southington, US 2021-05-07 Name Location Date Rachel Dong Pleasanton, US 2021-05-07 Denise Wong Diamond Bar, US 2021-05-07 Aley Even Santa Ana, CA 2021-05-07 Jo Ann Mandinach Palo Alto, CA 2021-05-07 emma page California, US 2021-05-07 Vivi Mage Irvine, CA 2021-05-07 Joseph Palimeno Kingsland, US 2021-05-07 Angela Chu Palo Alto, CA 2021-05-07 Gabriela DelRio Menlo Park, CA 2021-05-07 Shannon Wittgen Redwood City, CA 2021-05-07 Bonnie Zare Blacksburg, VA 2021-05-07 Kristen Leigh Allen, US 2021-05-07 naomi robertson Norcross, US 2021-05-07 Julian Nesbitt Santa Clara, CA 2021-05-07 Yanqing Guan Palo Alto, CA 2021-05-07 Hala Alhalmi Bronx, US 2021-05-07 KENDALL GILLINGHAM Reston, US 2021-05-07 Mary Altmiller Dahlonega, US 2021-05-07 Alayna Short El Dorado Hills, CA 2021-05-07 Chelsea Stewart Belmont, CA 2021-05-07 Rebecca Carlson Vancouver, WA 2021-05-07 Peri Baloun Sunnyvale, CA 2021-05-07 Name Location Date Maria Ruta San Jose, CA 2021-05-07 Jennifer Chu San Francisco, CA 2021-05-07 Trisha Suvari Annandale, VA 2021-05-07 Priscilla Witherspoon Costa Mesa, CA 2021-05-07 Elana Loeb Palo Alto, CA 2021-05-07 Gabi Gesualdo Levittown, US 2021-05-07 Abby Newman Aurora, US 2021-05-07 sheila gholson Palo Alt, CA 2021-05-07 Danica Willard Federal Way, US 2021-05-07 Yenefer Haile Stone Mountain, US 2021-05-07 Chayra Martinez Fountain, US 2021-05-07 Emely Mercedes Reading, US 2021-05-07 Liliana Rios Houston, US 2021-05-07 Karen Rubin Menlo Park, CA 2021-05-07 Patricia Zahedani Menlo Park, CA 2021-05-07 Sean Meier US 2021-05-07 stephanie grossman palo alto, CA 2021-05-07 Romin Thomson Menlo Park, CA 2021-05-07 Mk Stahl Albany, OR 2021-05-07 Erika Buck Palo Alto, CA 2021-05-08 Elliott Steven Plainfield, US 2021-05-08 nancy. snd Tom Fiene Palo Alto, CA 2021-05-08 Name Location Date Bonnie Durben San Marcos, CA 2021-05-08 James Shaurette El Paso, US 2021-05-08 Prakhar Srivastava Palo Alto, CA 2021-05-08 Brock Lacy Palo Alto, CA 2021-05-08 Msdmsn10@gmail.com Lionel Messi Fresh Meadows, US 2021-05-08 Emma Hall US 2021-05-08 Daniel Tuerk Palo Alto, CA 2021-05-08 Vibha Akkaraju Palo Alto, CA 2021-05-08 Maddison Lawrence Salt Lake City, UT 2021-05-08 Ava Payne Atlanta, GA 2021-05-08 Cayden Shackleford Virginia, US 2021-05-08 Devon Cable Scranton, PA 2021-05-08 Corey Meyers Lakeland, US 2021-05-08 Susan Mizejewski Glens Falls, US 2021-05-08 Elaine Wong San Carlos, CA 2021-05-08 Dianne Suiter Dayton, OH 2021-05-08 Rebecca Goldsmith Hayward, CA 2021-05-08 Hong Zhang Palo Alto, CA 2021-05-08 Rebecca Taylor Troy, OH 2021-05-08 Kathleen Kerry Palo Alto, CA 2021-05-08 Patti Schaffer Palo Alto, CA 2021-05-08 Name Location Date Hannah Fisher Palo Alto, CA 2021-05-08 Roni Kraft Mountain View, CA 2021-05-08 Christine Yow Santa clara, CA 2021-05-08 Catherine Harkness Sunnyvale, CA 2021-05-08 Jenna Rinsky Palo Alto, CA 2021-05-08 Molly Melius Palo Alto, CA 2021-05-08 Noelle Brackett Bowie, US 2021-05-08 Haniyah Strong Hampton, US 2021-05-08 Claudia Marcella Norwalk, US 2021-05-08 Cho Jackson US 2021-05-08 Nishat Iqbal Milwaukee, US 2021-05-08 Kristina Toland Palo Alto, CA 2021-05-08 kimberly lin Palo Alto, CA 2021-05-08 Susan Nicholls Palo Alto, CA 2021-05-08 Julia Zhou Elgin, IL 2021-05-08 Инна Смирнова Palo Alto, CA 2021-05-08 Veronique Long Tyler, US 2021-05-08 Rachel M Menlo Park, CA 2021-05-08 Sherry Frumkin Tarzana, CA 2021-05-08 Xiaochun Liu Palo Alto, CA 2021-05-08 Wei Wang Palo Alto, CA 2021-05-08 Yara Sellin Stanford, CA 2021-05-08 Name Location Date Sandra Even Santa Ana, CA 2021-05-08 Suzanne Leong Menlo Park, CA 2021-05-08 Lina Crane Palo Alto, CA 2021-05-08 Grace-Ann Baker Palo Alto, CA 2021-05-08 Hunter Sprague Fairfield, US 2021-05-08 Robin Villavicencio San Mateo, CA 2021-05-08 Alfred Amonoo-Neizer Laurel, US 2021-05-08 Sheeba G Castro Valley, CA 2021-05-08 Heather Howard Palo Alto, CA 2021-05-08 Julie Hartstein Menlo Park, CA 2021-05-08 Marion Beach Palo Alto, CA 2021-05-08 Kaitlin Karrick Deerfiled, US 2021-05-08 Weiwei Zhu 森尼⻙尔, CA 2021-05-08 jie hu Fremont, CA 2021-05-08 Manhal Mahdi�Salt Lake City, US 2021-05-08 Nancy Olson Palo Alto, CA 2021-05-08 Jonzie Hines Suisun City, US 2021-05-08 Carolyn Bao San mateo, CA 2021-05-08 Ying Cui Palo Alto, CA 2021-05-08 Michelle Shabtai Palo Alto, CA 2021-05-08 Nicole Meyer Palo Alto, CA 2021-05-08 Cheryl Silveira-Reeder Quincy, CA 2021-05-08 Name Location Date Angelina Meassar Humble, US 2021-05-08 Yvette Vo San Jose, CA 2021-05-08 Jada Girtman Gibson, US 2021-05-08 Janine Rocha Palo Alto, CA 2021-05-08 richard perper santa cruz, CA 2021-05-08 Willie Chan Sunnyvale, CA 2021-05-08 Heather Hadlock Menlo Park, CA 2021-05-08 Marisol Herrera San Francisco, CA 2021-05-08 Bibek shrestha Saint Cloud, US 2021-05-08 Izabella Pony Yukon, US 2021-05-08 Ronald Forbes Palo Alto, CA 2021-05-08 Jennie James Palo Alto, CA 2021-05-08 Valerie Laird Menlo Park, CA 2021-05-08 DD Feng Palo Alto, CA 2021-05-08 Matt Emmons Magalia, CA 2021-05-08 Jessica Russell Oakland, CA 2021-05-08 Drew Harwell Palo Alto, CA 2021-05-08 Britta Henkenjohann Santa Clara, CA 2021-05-08 nerija titus Palo Alto, CA 2021-05-08 Taylor Griego Gilbert, US 2021-05-08 Charles Sieloff Palo Alto, CA 2021-05-08 Mridula Shukla Dearborn, US 2021-05-08 Name Location Date Walter Chuck Newport, OR 2021-05-08 Harold Jones Menlo Park, CA 2021-05-08 Haleigh Williams West Valley City, US 2021-05-08 Tabitha Wilkins Prosper, US 2021-05-08 rhonda clark Palo Alto, CA 2021-05-08 Margaret Rickling Palo Alto, CA 2021-05-08 Jen Atkinson Redwood City, CA 2021-05-08 Caroline Small Mountain View, CA 2021-05-08 Liliana Giffen Foster city, CA 2021-05-08 Maggie Du Los Altos Hills, CA 2021-05-08 jennifer ott Palo Alto, CA 2021-05-08 Jeff Lawrence Palo Alto, CA 2021-05-08 Tina Åberg San Jose, CA 2021-05-08 Martha Sakellariou Palo Alto, CA 2021-05-08 Julie Loza-Sullivan San Mateo, CA 2021-05-08 Amitabh Handa Menlo Park, CA 2021-05-08 Malvina Mazin Palo Alto, CA 2021-05-08 Janet Wang Palo Alto, CA 2021-05-08 Wolfe Cardinal Menlo Park, CA 2021-05-08 Sharmistha Chakraborty Fremont, CA 2021-05-08 Lisa Widup Redwood City, CA 2021-05-08 Ekaterina Davydovskaya Palo alto, CA 2021-05-08 Name Location Date Liu Yang Palo Alto, CA 2021-05-08 Malvika Viswanathan Palo Alto, CA 2021-05-08 Catherine Crystal Foster Palo Alto, CA 2021-05-08 Deborah La Puma Placentia, CA 2021-05-08 Celeste Crystal Stanford, CA 2021-05-08 Marina Wiener Redwood City, CA 2021-05-08 D J Palo Alto, CA 2021-05-08 Sonya Rowen San Carlos, CA 2021-05-08 Andreas Raptopoulos Palo Alto, CA 2021-05-08 Julie Tsai Mountain View, CA 2021-05-08 Vivian Choi Palo Alto, CA 2021-05-08 Andrea S San Diego, CA 2021-05-08 Emily Egbert Palo Alto, CA 2021-05-08 Helen Zhong Newark, CA 2021-05-08 Eloisa Nocos Foster City, CA 2021-05-08 Andrew DeMartini Sunnyvale, CA 2021-05-08 Marieke Eggert-Pirk Palo Alto, CA 2021-05-08 Hong Fang Los Altos, CA 2021-05-08 Susan Rogers Palo alto, CA 2021-05-08 Lisa Talbot Palo Alto, CA 2021-05-08 Suishan Huang Palo Alto, CA 2021-05-08 Julia Murphy-Chutorian Palo Alto, CA 2021-05-08 Name Location Date Reshma Singh Palo Alto, CA 2021-05-08 Esther Rubin Palo Alto, CA 2021-05-08 Abigail Ball Palo Alto, CA 2021-05-08 Kylee Dial Palo Alto, CA 2021-05-08 Kelly Lazaro Palo Alto, CA 2021-05-08 Lesley Rappaport Palo Alto, CA 2021-05-08 Caryn McDowell Burlingame, CA 2021-05-08 Eric Lebel Menlo Park, CA 2021-05-08 Pooja Mortl Menlo Park, CA 2021-05-08 Danielle Parish Mountain View, CA 2021-05-08 Hoi Lee Santa Clara, CA 2021-05-08 Svetlana Gous Palo Alto, CA 2021-05-08 Mary Jiang Palo Alto, CA 2021-05-08 Mike Fogel Palo Alto, CA 2021-05-08 Kate Wilson Santa Clara, CA 2021-05-08 Katja Spreckelmeyer Palo Alto, CA 2021-05-08 Dee Ellmann Palo Alto, CA 2021-05-08 Fang Lu Mountain View, CA 2021-05-08 Teena James Palo Alto, CA 2021-05-08 Terry Yep Palo Alto, CA 2021-05-08 Lin Wu Palo Alto, CA 2021-05-08 Zidan Chow Bronx, US 2021-05-08 Name Location Date Cynthia Verbitzky Sacramento, CA 2021-05-08 Tina Ketterer San Jose, CA 2021-05-08 Sarah Hebenstreit San Francisco, CA 2021-05-08 N Dehn Palo Alto, CA 2021-05-08 Shirlie Ho Sunnyvale, CA 2021-05-08 Yael Tygiel Van Nuys, CA 2021-05-08 Priya Sethuraman Palo Alto, CA 2021-05-08 Kim Thaker San Antonio, TX 2021-05-08 Alli Ross San Mateo, CA 2021-05-08 Sara Tomkoria Palo Alto, CA 2021-05-08 Reid Sox-Harris Menlo Park, CA 2021-05-08 Panagiotis Reveliotis San Diego, CA 2021-05-08 Susan Curry Sykes Palo Alto, CA 2021-05-08 Laurie Phillips Palo Alto, CA 2021-05-08 Diane Master Palo Alto, CA 2021-05-08 Min Wei Palo Alto, CA 2021-05-08 Jules Sherman Palo Alto, CA 2021-05-08 Lorraine Brown Palo Alto, CA 2021-05-08 Halina Melnik San Francisco, CA 2021-05-08 Hairong Zou Palo Alto, CA 2021-05-08 bissera pentcheva Palo Alto, CA 2021-05-08 Allison MacQueen San Mateo, CA 2021-05-08 Name Location Date Isma Khan Palo Alto, CA 2021-05-08 Maria Castellanos South Gate, US 2021-05-08 Sampson Shen Palo Alto, CA 2021-05-08 Rachel Mayberry Palo Alto, CA 2021-05-08 Prasanthi Govindarajan Palo Alto, CA 2021-05-08 Marianne Yacobian Palo Alto, CA 2021-05-08 Jian Shi San Jose, CA 2021-05-08 Naysa K Fort Worth, US 2021-05-08 Maria Coburn Menlo Park, CA 2021-05-08 Christine Jojarth Palo Alto, CA 2021-05-08 Daniel Moore Palo Alto, CA 2021-05-08 Annalisa Villani San Jose, CA 2021-05-08 Amy Jojarth Palo Alto, CA 2021-05-08 Armina Badalian Palo Alto, CA 2021-05-08 Anu Tewary Auckland, New Zealand 2021-05-08 Paul McCabe Los Gatos, CA 2021-05-08 Andrew Dauman Campbell, CA 2021-05-08 Adam Fee Palo Alto, CA 2021-05-08 Kloe Maney Jackson, US 2021-05-08 Arman Brar Miami, US 2021-05-08 Angela Carpentieri Menlo Park, CA 2021-05-08 Monica Stemmle San Jose, CA 2021-05-08 Name Location Date Magdalena Dorywalska Redwood City, CA 2021-05-08 Annie Fox Brooklyn, NY 2021-05-08 Adam Tobin Stanford, CA 2021-05-08 Manan Desai Los Altos, CA 2021-05-08 Susan Curran White Bellingham, WA 2021-05-08 Nina Lim Milpitas, CA 2021-05-08 Louise Beattie Palo Alto, CA 2021-05-08 fhfhd jrifb Greer, US 2021-05-08 Patricia Dhillon Palo Alto, CA 2021-05-08 Lindsay Toth Palo Alto, CA 2021-05-08 christy peetz Menlo Park, CA 2021-05-08 Maya Perkash Los Altos, CA 2021-05-08 James Lee Williams Palo Alto, CA 2021-05-08 Jackie Yao Palo Alto, CA 2021-05-08 Donna Zulman Palo Alto, CA 2021-05-08 Gina Flynn Palo Alto, CA 2021-05-08 Tatiana Mejia Mountain View, CA 2021-05-08 Ami O California 2021-05-08 devi ramanan palo alto, CA 2021-05-08 John Mathews Menlo Park, CA 2021-05-08 Joanna Argasinska Palo Alto, CA 2021-05-08 Tad Lebeck Palo Alto, CA 2021-05-08 Name Location Date Larr Katz Palo Alto, CA 2021-05-08 Suju Rajan Palo Alto, CA 2021-05-08 Bernadette Vergara Saratoga, CA 2021-05-08 J. Michael Graglia Palo Alto, CA 2021-05-08 Diana Brzozowski Mountain View, CA 2021-05-08 Anoop Nagar Palo alto, CA 2021-05-08 Julia Foug Palo Alto, CA 2021-05-08 Margo Lowensohn Campbell, CA 2021-05-08 Faith Baker London, US 2021-05-08 Lois Shore Atherton, CA 2021-05-08 Laura Wright Los Altos, CA 2021-05-08 Antara Brahma Mountain View, CA 2021-05-08 Lewam Assefaw Palo Alto, CA 2021-05-08 Tanu Pant Mountain View, CA 2021-05-08 Sharon Woodworth San Jose, CA 2021-05-08 Jill Kaplan Stanford, CA 2021-05-08 Christina Stankovich San Jose, CA 2021-05-08 Caroline Haas Redwood City, CA 2021-05-08 Julie Desai Palo Alto, CA 2021-05-08 Mandy Guo Palo Alto, CA 2021-05-08 Mrugal Patel Mountain View, CA 2021-05-08 Min Wan Menlo Park, CA 2021-05-08 Name Location Date Marta Solsona Menlo Park, CA 2021-05-08 Janel Moses Palo Ato, CA 2021-05-08 Aaron Schwartzbord New York, NY 2021-05-08 Toni Ouradnik East Palo Alto, CA 2021-05-08 Claudia Schweikert Palo Alto, CA 2021-05-08 Erin Brummett Sunnyvale, CA 2021-05-08 Connie Yu Palo alto, CA 2021-05-08 Yogesh Sandhuja Palo Alto, CA 2021-05-08 Pilar Alvarez Long Beach, CA 2021-05-08 Erika Alperin San Francisco, CA 2021-05-08 Lee Zulman Palo Alto, CA 2021-05-08 Jessica Beacom Whittier, US 2021-05-08 Jing Ma Palo Alto, CA 2021-05-08 Lynz Floren Los Angeles, CA 2021-05-08 Shruti Sheorey Mountain View, CA 2021-05-08 Thomas Buch Menlo Park, CA 2021-05-08 Laurence Kancherla Palo Alto, CA 2021-05-08 Rajeshwari Panshikar Menlo Park, CA 2021-05-08 Jill Wickersham San jose, CA 2021-05-08 Aleksandra Hopper Palo Alto, CA 2021-05-08 Reuben Nocos San Jose, CA 2021-05-08 Brian George Palo Alto, CA 2021-05-08 Name Location Date Anna Perone Redwood City, CA 2021-05-08 Anthea Shands-Serret Sonora, CA 2021-05-08 Rachel Bender Palo Alto, CA 2021-05-08 Sean Mahoney Honolulu, HI 2021-05-08 Shawn Hott Palo Alto, CA 2021-05-08 Ray LIN Palo Alto, CA 2021-05-08 Molly Mermelstein New York, NY 2021-05-08 Lei Wang San Jose, CA 2021-05-08 Larnie Fox Benicia, CA 2021-05-08 Julia Baker Menlo Park, CA 2021-05-08 Sophie Yost Palo Alto, CA 2021-05-08 Nancy Bain Palo Alto, CA 2021-05-08 Morgan Guzman Alameda, CA 2021-05-08 Tatyana Ayrapetova Atherton, CA 2021-05-08 Pawan Deshpande Los Altos, CA 2021-05-08 Susannah Greenwood San jose, CA 2021-05-08 Renee Fadiman Menlo Park, CA 2021-05-08 Katie dyer Menlo Park, CA 2021-05-08 Donna Youngberg Palo Alto, CA 2021-05-08 Diana Ungersma San Carlos, CA 2021-05-08 Catherine Stoll Palo Alto, CA 2021-05-08 Stefanie Wauk Palo Alto, CA 2021-05-08 Name Location Date David Hefner Seattle, WA 2021-05-08 Fumiko Habib Palo Alto, CA 2021-05-08 Karen Y Santa Clara, CA 2021-05-08 Andrea Walker San Angelo, US 2021-05-08 Michelle Yee Sunnyvale, CA 2021-05-08 Skie Clark Tom Bean, US 2021-05-08 Diane Schwalbach SF Bay Area, CA 2021-05-08 Harshitha Menon Los Altos, CA 2021-05-08 Jonathan Zeitlin Palo Alto, CA 2021-05-08 Sierra Davis Stanford, CA 2021-05-08 Corinne Reich-Weiser Mountain View, CA 2021-05-08 Emily Fox Stanford, CA 2021-05-08 Dylan Farrell Beaverton, MI 2021-05-08 Julie Brodie Redwood City, CA 2021-05-08 Katie Ma Pinole, US 2021-05-08 Christina Passariello Palo Alto, CA 2021-05-08 xf zhu PALO ALTO, CA 2021-05-08 Aditi Chandra Palo Alto, CA 2021-05-08 Heike Runne Palo Alto, CA 2021-05-08 Joanna Carstens Palo Alto, CA 2021-05-08 Donald Brookman Menlo Park, CA 2021-05-08 Lisa Bertelsen Kivett Palo Alto, CA 2021-05-08 Name Location Date Hellen Martinez Palo Alto, CA 2021-05-08 Riley Etheridge Palmetto, US 2021-05-08 JESSICA BOWMER San carlos, CA 2021-05-08 claudia truesdell Palo Alto, CA 2021-05-08 Shirin Zebarjadi Palo Alto, CA 2021-05-08 Jane Chiang Palo Alto, CA 2021-05-08 Sue Klapholz Stanford, CA 2021-05-08 Virginia Van Kuran Palo Alto, CA 2021-05-08 Sharon Shen Palo Alto, CA 2021-05-08 Ryan Murray Los Angeles, CA 2021-05-08 Reimar Goetze Mountain View, CA 2021-05-09 Emanuela Todaro Palo Alto, CA 2021-05-09 Liu Wang Palo Alto, CA 2021-05-09 Annie Lumerman Stanford, CA 2021-05-09 Autumn Looijen San Francisco, CA 2021-05-09 Nora Kaminsky Pacifica, CA 2021-05-09 Rebecca Thompson Palo Alto, CA 2021-05-09 Mari Ueda-Tao Portola Valley, CA 2021-05-09 Adriana Flores-Ragade Palo Alto, CA 2021-05-09 Charlotte Chevrou Los Altos, CA 2021-05-09 LeAnne Wirtz Barrington, IL 2021-05-09 Mandy Goldman Bend, OR 2021-05-09 Name Location Date Yi-Ting Chen Pittsburg, CA 2021-05-09 Carol Crewdson San Francisco, CA 2021-05-09 Isabella Kruse West Chester, US 2021-05-09 Smita D Los Altos, CA 2021-05-09 Kathy Simpson Middlesboro, US 2021-05-09 Gil Weissman Stanford, CA 2021-05-09 Vita Skoblikov Palo Alto, CA 2021-05-09 Lauren Sparandara Palo Alto, CA 2021-05-09 Fangfang Yin Palo Alto, CA 2021-05-09 Kiana Brown San Diego, CA 2021-05-09 Laura Puras Palo Alto, CA 2021-05-09 Joshua Shipp Laurel, MD 2021-05-09 Natalia Palmerin Rome, US 2021-05-09 Jessica Kuo Sunnyvale, CA 2021-05-09 Igor Makasyuk pppp, CA 2021-05-09 Cristiana Carauta Menlo Park, CA 2021-05-09 Jane Kirk Palo Alto, CA 2021-05-09 Helen Vallaeys Los Altos, CA 2021-05-09 Chand Somaiah Singapore, Singapore 2021-05-09 morgan terrell indiana, US 2021-05-09 Katie Peuvrelle San Jose, CA 2021-05-09 Caitlin Gjerdrum Palo Alto, CA 2021-05-09 Name Location Date Brittany Gardner Palo Alto, CA 2021-05-09 Alison Biggs Los Altos, CA 2021-05-09 Amy Chu Palo Alto, CA 2021-05-09 Magdalena Ramirez Stanford, CA 2021-05-09 Marton Jojarth Palo Alto, CA 2021-05-09 Alex Indigo Palo Alto, CA 2021-05-09 Meng Ear Santa Clara, CA 2021-05-09 Erin Poff Windsor, CA 2021-05-09 Dyanna Nieves Cupertino, CA 2021-05-09 Gene Warren Palo Alto, CA 2021-05-09 Derik Scott Los Angeles, US 2021-05-09 Hilary King Los Altos, CA 2021-05-09 kelly sanders Los Altos, CA 2021-05-09 Bowen Li Menlo Park, CA 2021-05-09 Tracy Tripp Sunnyvale, CA 2021-05-09 Jensen Zhu College Point, US 2021-05-09 Christina Berumen Redwood City, CA 2021-05-09 Mahroo Safaei San Jose, CA 2021-05-09 Jennifer Krikheli Los Altos, CA 2021-05-09 Scott Miron redwood city, CA 2021-05-09 Colexi Brazier Albuquerque, US 2021-05-09 Abby Bradski Palo Alto, CA 2021-05-09 Name Location Date gabi zajacz Medina, US 2021-05-09 Ella Shrum Independence, US 2021-05-09 Jessica Heideman El Dorado Hills, CA 2021-05-09 Lori Gicklhorn Issaquah, WA 2021-05-09 Marysa Avery Cazenovia, US 2021-05-09 Cynthia Wood Palo Alto, CA 2021-05-09 Kaitlyn Nakano Los Altos, CA 2021-05-09 desiree kovalski Indianapolis, US 2021-05-09 Colleen Uhran Arroyo Grande, CA 2021-05-09 Elinor Taussig Palo Alto, CA 2021-05-09 Corinna Mori Palo Alto, CA 2021-05-09 Sairah Naroo Stony Brook, US 2021-05-09 Robin Goka Huynh San Jose, CA 2021-05-09 Jennifer Newton valley village, CA 2021-05-09 Paula Kushlan Palo Alto, CA 2021-05-09 Christine Joseph Redwood City, CA 2021-05-09 Wen Ma Palo Alto, CA 2021-05-09 Robert Peck San Francisco, CA 2021-05-09 Maria Rose Los Altos, CA 2021-05-09 Susan Moody Atlanta, GA 2021-05-09 Camille Tripp Palo Alto, CA 2021-05-09 Erika Noda Torrance, CA 2021-05-09 Name Location Date Maryam Zahedi Redwood City, CA 2021-05-09 Graceann Johnson Menlo Park, CA 2021-05-09 Ashley Suhr Seattle, WA 2021-05-09 Maria Wagenaar Santa Clara, CA 2021-05-09 Susie Lai Palo Alto, CA 2021-05-09 Steven Fu Menlo Park, CA 2021-05-09 Yang Liu Los Altos, CA 2021-05-09 Reina Coburn Mountain View, CA 2021-05-09 Marilyn Gillespie Palo Alto, CA 2021-05-09 Marya Adams Redwood City, CA 2021-05-09 Heidi Yenney Carlsbad, CA 2021-05-09 Michele Wong Palo Alto, CA 2021-05-09 Shannon Sheahan El Dorado Hills, CA 2021-05-09 Andrew Willis-Woodward Hoboken, NJ 2021-05-09 Spenser Levien Bellevue, WA 2021-05-09 Rebecca Siegel Palo Alto, CA 2021-05-09 Aygun Amirali Santa Clara, CA 2021-05-09 Farida Mammadova Mountain View, CA 2021-05-09 Mindy Do Palo Alto, CA 2021-05-09 Kali Lamping Palo Alto, CA 2021-05-09 Chloe Garcia New York, US 2021-05-09 Huiling Gong Palo ALto, CA 2021-05-09 Name Location Date Caroline Dingle Central District, Hong Kong 2021-05-09 Diana Yousefpor San Jose, CA 2021-05-09 Kieran Chavez Palo Alto, CA 2021-05-09 Erica Kellogg Mountain View, CA 2021-05-09 Katja Rault-Wang Palo Alto, CA 2021-05-09 Renata Tong Palo Alto, CA 2021-05-09 Oksanna Kasoyan Palo Alto, CA 2021-05-09 Olga Iakovleva Menlo Park, CA 2021-05-09 Dora Heideman Palo Alto, CA 2021-05-09 Suzanne Jangda Toronto, Canada 2021-05-09 Nene Jawin Auburn, US 2021-05-09 Trina Warren Redwood City, CA 2021-05-09 Philippe Alexis Palo Alto, CA 2021-05-09 Brian Mahoney New York, NY 2021-05-09 Doris Roberts Palo Alto, CA 2021-05-09 Yvette Payne Atlanta, US 2021-05-09 Sunny Paul palo alto, CA 2021-05-09 Elizabeth Silva La Honda, CA 2021-05-09 Emily Fry Carmichael, CA 2021-05-09 Rashely Victoriano New York, US 2021-05-09 Christine Crapps Stanford, CA 2021-05-09 Ross Mayfield Palo Alto, CA 2021-05-09 Name Location Date Kathrysha Toro Clermont, US 2021-05-09 Moises Benavente Denver, US 2021-05-09 Lily Lopez Houston, US 2021-05-09 Julie Griffin Palo Alto, CA 2021-05-09 Ginny Sikri San Jose, CA 2021-05-09 Katy Fluet Redwood City, CA 2021-05-09 Jenni Marks Queens, NY 2021-05-09 Bruce Davis Mountain View, CA 2021-05-09 Jacqueline Lin Menlo Park, CA 2021-05-09 xiaoxia wu Palo Alto, CA 2021-05-09 Cindy Chow Mountain View, CA 2021-05-09 Joy Shih Atherton, CA 2021-05-09 Skye Talavera Redwood City, CA 2021-05-09 Norm Picker Los Altos, CA 2021-05-09 Dominique Vincent Frisco, TX 2021-05-09 Danely Gonzalez San Antonio, US 2021-05-09 Maliha Syed Palo Alto, CA 2021-05-09 Bern Zen San Jose, CA 2021-05-09 Vivian Gerritsen Palo Alto, CA 2021-05-09 Hang Ung PALO ALTO, CA 2021-05-09 Banafsheh Hussain Palo Alto, CA 2021-05-09 Sofia Hussain Palo Alto, CA 2021-05-09 Name Location Date Sofia H Palo Alto, CA 2021-05-09 Tina Liao Palo Alto, CA 2021-05-09 Caroline Peres Palo Alto, CA 2021-05-09 Basab Pradhan Palo Alto, CA 2021-05-09 XIUPING CAO Hayward, CA 2021-05-09 Sophia Dunkin-Hubby Menlo Park, CA 2021-05-09 Mary Gallagher Palo Alto, CA 2021-05-09 Makeda Gershenson Vancouver, WA 2021-05-09 Sabrina Khan Palo Alto, CA 2021-05-09 Xiaofang Chen Palo Alto, CA 2021-05-09 Benjamin Hill Mountain View, CA 2021-05-09 margot neebe Mountain View, CA 2021-05-09 Nidhi Bhutani Stanford, CA 2021-05-09 Mei Miyahara Menlo Park, CA 2021-05-09 Ella Thomson Menlo Park, CA 2021-05-09 Lisew Pinnell Benicia, CA 2021-05-09 Lin Yang Austin, TX 2021-05-09 lisa hwong Palo Alto, CA 2021-05-09 Glara Kang Palo Alto, CA 2021-05-09 Ivan Temes Palo Alto, CA 2021-05-09 Holly Grenke El Dorado Hills, US 2021-05-09 jocelyn torres San Leandro, US 2021-05-09 Name Location Date Lorilee Sugden Menlo Park, CA 2021-05-09 Doris Macoun Menlo Park, CA 2021-05-09 Melissa Gutierrez Sacramento, US 2021-05-09 Rachel Wheeler Stanford, CA 2021-05-09 Elizabeth Berberian Fairfax, VA 2021-05-09 Darlyn Smith Palo Alto, CA 2021-05-09 Anna Lazar San Mateo, CA 2021-05-09 Mercedes Ferrin Bellflower, US 2021-05-09 Cheryl Reich Long Beach, NY 2021-05-09 Taylor McKnight Boca Raton, US 2021-05-09 Christine Seto Palo Alto, CA 2021-05-09 Robin Parker Los Gatos, CA 2021-05-09 Lillian Zhang Menlo Park, CA 2021-05-09 Sara Stover Oklahoma City, US 2021-05-09 Mimm Patterson Palo Alto, CA 2021-05-09 Lilah Chen Menlo Park, CA 2021-05-09 Syd Pack Gilroy, US 2021-05-09 Kristen Van Fleet Palo Alto, CA 2021-05-09 Kevin Ma Palo Alto, US 2021-05-09 Darcy Koch Mountain View, CA 2021-05-09 Amy Zhang Menlo Park, CA 2021-05-09 Elizabeth Moragne Palo Alto, CA 2021-05-10 Name Location Date Steven Ketchpel Belmonst, CA 2021-05-10 Thomas Hicks Powhatan, VA 2021-05-10 Melissa Kraus Palo Alto, CA 2021-05-10 Jena Bloomquist Palo Alto, CA 2021-05-10 Shania Rocha Chaska, US 2021-05-10 Katherine Leng Palo Alto, CA 2021-05-10 Barbara Nelson Calumet Township, MI 2021-05-10 alex hernandez lexington, US 2021-05-10 Rosie Lebel Menlo Park, CA 2021-05-10 Mabel Wei Palo Alto, CA 2021-05-10 Katy Tripp Palo Alto, CA 2021-05-10 Irene McDaniels Underwood, US 2021-05-10 Keri Ghiorso Palo Alto, CA 2021-05-10 James Poppy Palo Alto, CA 2021-05-10 Laura Bajuk Palo Alto, CA 2021-05-10 Kristi McMichael Palo Alto, CA 2021-05-10 Sarah Lesser Stanford, CA 2021-05-10 Kate Bellers Palo Alto, CA 2021-05-10 Monica Defilippi Palo Alto, CA 2021-05-10 Yochai Shavit Stanford, CA 2021-05-10 Emma Van Aarde Lincolnton, US 2021-05-10 Shufung Chen Palo Alto, CA 2021-05-10 Name Location Date Robert Ortiz San Francisco, US 2021-05-10 Lindsay Merrill Stanford, CA 2021-05-10 Pok Man Chu Palo Alto, CA 2021-05-10 Yvonne Ward Kent, WA 2021-05-10 Andrea Reichert Redwood City, CA 2021-05-10 Dijana Pirsljin Palo Alto, CA 2021-05-10 JoAnne Wetzel Palo Alto, CA 2021-05-10 Marianna Tessel Palo Alto, CA 2021-05-10 Tom Brinck Palo Alto, CA 2021-05-10 Christine Cho Palo Alto, CA 2021-05-10 Hanna Kushnireuskaya Palo Alto, CA 2021-05-10 Yoni Schattner Stanford, CA 2021-05-10 angie labrado Boise, ID 2021-05-10 PJ Lents Palo Alto, CA 2021-05-10 Molly Zaninovich New Orleans, LA 2021-05-10 Xanny Handfield Palo Alto, CA 2021-05-10 Gezel Frederick Los Altos, CA 2021-05-10 chasity chang Auburn, US 2021-05-10 Molly Kilburn Berkeley, CA 2021-05-10 Arne Lim Palo Alto, CA 2021-05-10 Leo Marburg Palo Alto, CA 2021-05-10 Mary Hansen Palo Alto, CA 2021-05-10 Name Location Date Marianne Chowning- Dray Palo Alto, CA 2021-05-10 Jean Kim Downey, CA 2021-05-10 BELLA BELTINOFF Stanford, CA 2021-05-10 Anthony Gomez Arlington, US 2021-05-10 Sandra Bardas Palo Alto, CA 2021-05-10 Jordin Brunick Philadelphia, US 2021-05-10 Patrick More Palo Alto, CA 2021-05-10 Niall Patrick Washington, DC 2021-05-10 Nancy Baer Menlo Park, CA 2021-05-10 tania romero Kennett Square, US 2021-05-10 Deepa Lalla Palo Alto, CA 2021-05-10 Daisy Olivas Phoenix, US 2021-05-10 Varsha Bhatia Palo Alto, CA 2021-05-10 Chloe Nelson Sunnyvale, CA 2021-05-10 tam ar Tbilisi, US 2021-05-10 Clea Sarnquist Palo Alto, CA 2021-05-10 Nancy Hamilton Palo Alto, CA 2021-05-10 Ashwinee Khaladkar Palo Alto, CA 2021-05-10 Natalie Zahr Menlo Park, CA 2021-05-10 Lara Mcguffin Frisco, US 2021-05-10 Jazmin Rocha east palo alto, CA 2021-05-10 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US 2021-05-14 Name Location Date Dylan Schamach Petaluma, US 2021-05-14 Orion Klingensmith Orwell, US 2021-05-14 Amy Carpenter Broken Arrow, US 2021-05-14 William Valle Syracuse, US 2021-05-14 Hana Abdelrehim Brooklyn, US 2021-05-14 lexi crump Lenoir, US 2021-05-14 Marcques Rayford Pensacola, US 2021-05-14 Cameron Sunde Palo Alto, CA 2021-05-14 Ally Wilson Wallingford, US 2021-05-14 Skylar Lovett Atlanta, US 2021-05-14 David Rose Jacksonville, US 2021-05-14 Lilly W.Cincinnati, US 2021-05-14 Hanson Wang Norwalk, US 2021-05-14 Abby Asbery Lancaster, US 2021-05-14 Yadira Zecuistl Chicago, US 2021-05-14 hayleigh grassi Boston, US 2021-05-14 Kassidy Perkins Maysville, US 2021-05-14 Kendra Shannon Table Grove, US 2021-05-14 Nate Talbert Arlington, US 2021-05-14 Rebecca Long New Market, US 2021-05-14 Elizabeth Liebe Gibsonia, US 2021-05-14 Isabell Pierce Martinsville, US 2021-05-14 Name Location Date Nicole Godfrey Indian Trail, US 2021-05-14 Jasper Stevenson Columbia, US 2021-05-14 Ed Balls North Royalton, US 2021-05-14 Zack Leclerc Windham, US 2021-05-14 ebunoluwa adelakun Philadelphia, US 2021-05-14 Mackenzie Andrews US 2021-05-14 Allyson Bodell Hooksett, US 2021-05-14 Melanie Mora Detroit, US 2021-05-14 Ee Ee Miami, US 2021-05-14 Tamara Lanting Moreno Valley, US 2021-05-14 Stan Pachter, Ph.D.San Diego, CA 2021-05-14 Brayan Quintero Los Angeles, US 2021-05-14 Hamza Saadiq Des Moines, US 2021-05-14 Sonia Ramirez West Covina, CA 2021-05-14 Marie High Corvallis, US 2021-05-14 Sierra Neafus Corydon, US 2021-05-14 Amiah Brown Las Vegas, US 2021-05-14 Anel Alvarez US 2021-05-14 Nancy Fitzgerald Hayward, CA 2021-05-14 Dave Cando Santee, US 2021-05-14 Alexandra Miller Aurora, US 2021-05-14 Jesey Smith Spencer, US 2021-05-14 Name Location Date jackson connolly Groton, US 2021-05-14 Ashley Meinhold Bethlehem, US 2021-05-14 Britney Schwartz O Fallon, US 2021-05-14 Kayla Owens Huddy, US 2021-05-14 Leah Jessop Newton, US 2021-05-14 Jayden Noggle Augusta, US 2021-05-14 Audrey Tatro Yakima, US 2021-05-14 Wendy Tran San Jose, CA 2021-05-14 Destiny Breedlove Birmingham, US 2021-05-14 Jerrie Sitzes Forrest City, US 2021-05-14 riley belk The Colony, US 2021-05-14 Natalie Wathan Columbia, US 2021-05-14 Dean Reddish Wadsworth, US 2021-05-14 Mary Chacon Palo Alto, CA 2021-05-14 Kahlil Felder Washington, US 2021-05-14 Yasly Reyes Woodbridge, US 2021-05-14 Maybell Smith Atlanta, US 2021-05-14 paige hull jacksonville, US 2021-05-14 Alexandra Niederauer Los Altos Hills, CA 2021-05-14 Brett Atkinson Palo Alto, CA 2021-05-14 Emma Nemec Holland, US 2021-05-14 Maria Kim Anaheim, CA 2021-05-14 Name Location Date Don Cleland Mount Sterling, US 2021-05-14 Hannah Stewart Royal Oak, US 2021-05-14 Janet Kurposka Delmar, NY 2021-05-14 jamisyn lyden windham, US 2021-05-14 Jennifer Tai US 2021-05-14 David Bettencourt San Jose, CA 2021-05-14 Blake Steadman Monroeville, US 2021-05-14 Morgan Crump Whitehouse, US 2021-05-14 Mal Evans Sacramento, US 2021-05-14 Tierra McAfee South Bend, US 2021-05-14 Jorgi Anderson US 2021-05-14 karen squires sanders San Jose, CA 2021-05-14 Sophie Smith Morris, US 2021-05-14 Alyssa Rodriguez Corpus Christi, US 2021-05-14 izzy b scarborough, US 2021-05-14 Amy Miller Brookhaven, US 2021-05-14 Hailee Ulate Inverness, US 2021-05-14 Aida Mohamed New York, NY 2021-05-14 delaynee speakman Chillicothe, US 2021-05-14 Maria Bratke Akron, US 2021-05-14 virginia funk pittsburgh, US 2021-05-14 Carolyn Bradford Eureka, US 2021-05-14 Name Location Date Briana Amos Killeen, US 2021-05-14 Kayla Lewis US 2021-05-14 Elaine Andersen Palo Alto, CA 2021-05-14 Taylor Horn Fayetteville, US 2021-05-14 Emily Sholett Watertown, US 2021-05-14 Jasmine Boggs Bardstown, US 2021-05-14 Allison Molina Manassas, US 2021-05-14 jeff shirley North Richland Hills, US 2021-05-14 Joshua Standiford Lake Zurich, US 2021-05-14 tarun prasad Oakland, US 2021-05-14 Gilllian Melgar Charlotte, US 2021-05-14 Marie Diop New York, US 2021-05-14 Andrew Berry Fishers, US 2021-05-14 Tamiah Arrington Philadelphia, US 2021-05-14 Zack Poindexter Washington, US 2021-05-14 Kaylee Cockeram Lucas, US 2021-05-14 Mick Green Margate, US 2021-05-14 Kevan Carter Brunswick, US 2021-05-14 Chloe Hughes Fallbrook, US 2021-05-14 Nineveh Herrera El Paso, US 2021-05-14 Davis Coopet Framingham, US 2021-05-14 Emma Spencer Bronx, US 2021-05-14 Name Location Date Cassandra Maceri Sterling Heights, US 2021-05-14 theia seaton US 2021-05-14 Kaitlynn dow Hillsdile, US 2021-05-14 Ashton Hurd Panama City, US 2021-05-14 Hyundeok Lee Stanford, CA 2021-05-14 Leslie Bailey Pinehurst, NC 2021-05-14 Jennifer Shaut Lubbock, US 2021-05-14 Nevaeh Martinez Seattle, US 2021-05-14 Sophie Albasini Rockville Centre, US 2021-05-14 Nevaeh Foraker Detroit, US 2021-05-14 Eduardo Martinez Los Angeles, US 2021-05-14 Em Brew Bloomington, US 2021-05-14 Matt Thura Berkeley, CA 2021-05-14 Kam’Ren Parker Scranton, US 2021-05-14 Bayley G Covington, US 2021-05-14 Dad Mom Rancho Cordova, US 2021-05-14 Larry Johnson Humble, US 2021-05-14 Ashlee Riley Gulf Breeze, US 2021-05-14 Oceanna Graham Holly Ridge, US 2021-05-14 Alex R Angier, US 2021-05-14 Yair Espinoza Hayward, US 2021-05-14 Bekka Ward Wapakoneta, US 2021-05-14 Name Location Date no name Massachusetts 2021-05-14 heavenlee guzman southwick, US 2021-05-14 Karma Rafaela Vegshhs, US 2021-05-14 Natalie Cline Johnson City, US 2021-05-14 Deez Nuts League City, US 2021-05-14 Mikah Smith Glendora, US 2021-05-14 Madison Lee Bethlehem, US 2021-05-14 Aileen Castro Newark, US 2021-05-14 Hailey Whynaught Anaheim, US 2021-05-14 Azmir Mohamed Palo Alto, CA 2021-05-14 Tanner Parker Livermore, US 2021-05-14 Yael Trujillo Saint Louis, US 2021-05-14 Jesus Christ Moses lake, US 2021-05-14 Zoe Navarro Hayward, US 2021-05-14 jordan dawson Penfield, US 2021-05-15 Your Mom South Weymouth, US 2021-05-15 Jules Jones San Clemente, US 2021-05-15 Elizabeth Scott Livermore Falls, US 2021-05-15 Emily Moore Cleveland, US 2021-05-15 Jocelyn Medinilla Oxnard, US 2021-05-15 Marlissa Johnsin Rochester, US 2021-05-15 Ashlynn Handrick Pearland, US 2021-05-15 Name Location Date Jessica Qi Menlo Park, US 2021-05-15 JAckson Robinson valley Independence, US 2021-05-15 Ximena Rosales Charlotte, US 2021-05-15 Elysia Shaver Zanesville, US 2021-05-15 Maison Fox Independence, US 2021-05-15 Jacob Buckner Knoxville, US 2021-05-15 Ava Smith Lake Mary, US 2021-05-15 Si Papi Jesse Manriquez Riverside, US 2021-05-15 Mikey Hue El Paso, US 2021-05-15 Maggie Anderson Saratoga Springs, US 2021-05-15 Michelle Chen Castro Valley, US 2021-05-15 Linda Medeiros Fremont, CA 2021-05-15 Maya Greenquist Stillwater, US 2021-05-15 Candice Who Corona, US 2021-05-15 Luke Conway Sanderson, US 2021-05-15 Madalyn Spurling Pittsburgh, US 2021-05-15 April Dunsmuir Cincinnati, US 2021-05-15 Wei Shen Santa Clara, US 2021-05-15 Michael Pulcrano Long Island, US 2021-05-15 Rebecca Kahler Quakertown, US 2021-05-15 Jose Hernandez US 2021-05-15 Bianca Mandujano Lakeland, US 2021-05-15 Name Location Date Julian Grosky Los Angeles, US 2021-05-15 Tristan Khoshyomn Springfield, US 2021-05-15 Makaley Smoot West Lafayette, US 2021-05-15 Isabelle Smith Machesney Park, US 2021-05-15 emily perez apopka, US 2021-05-15 Virginia Rodriguez Bethlehem, US 2021-05-15 Joshua Sinclair Dallas, US 2021-05-15 Paul Maltby Pleasanton, CA 2021-05-15 Caylee Conner Lake Arthur, US 2021-05-15 Merit Covet US 2021-05-15 Jaston Bowen Vinton, US 2021-05-15 Yazmin Acuna West palm beach, US 2021-05-15 Destiny roberts panthersville, US 2021-05-15 Alec Wheeler Howell, US 2021-05-15 T Vasquez Albuquerque, US 2021-05-15 Julia Bloch New York, US 2021-05-15 Zach Troutman Southlake, US 2021-05-15 Sammy Kac Sandusky, US 2021-05-15 Ushasree kode Palo Alto, CA 2021-05-15 Kelly Farrens Sacramento, CA 2021-05-15 Amber Villarreal Orange Grove, US 2021-05-15 landon Poore Huntingtown, US 2021-05-15 Name Location Date Husnain Rattoo Ronkonkoma, US 2021-05-15 Jenessa Diaz Corona, US 2021-05-15 Arely Fabian Santa Ana, US 2021-05-15 Mazzy Carter Houston, US 2021-05-15 Whitney Cross Saint Louis, US 2021-05-15 Lamesha Hawkins Las Vegas, US 2021-05-15 taylor arnold Silver Spring, US 2021-05-15 Omar Beltran Chicago, US 2021-05-15 Bryanna Sutton Erie, US 2021-05-15 Elisa Jeung Fargo, US 2021-05-15 Andrea Barker Marion, US 2021-05-15 Dylon Talaba New London, US 2021-05-15 Christina Morace Vacaville, CA 2021-05-15 Alex Trevizo Pasadena, US 2021-05-15 Camryn Bursiaga Hanford, US 2021-05-15 I dont Even go here but whatever it's cool Hamilton, US 2021-05-15 Ahmed Kamara Philadelphia, US 2021-05-15 Nate Couey Chicago, US 2021-05-15 Michael Mok Sunnyvale, CA 2021-05-15 Amber U Fontana, CA 2021-05-15 Selena Duran Battle Creek, US 2021-05-15 Name Location Date Lindsey Riley La Porte, US 2021-05-15 Zeena Benjamin Hayward, CA 2021-05-15 Sophie Foster-Canfield Bow, US 2021-05-15 Havana Rutherford Marietta, US 2021-05-15 Edgard Jayee US 2021-05-15 Emery Daly Santa Maria, US 2021-05-15 Lilly Latham Jacksonville, US 2021-05-15 Megan Quintanilla Escondido, US 2021-05-15 Sarah Dunn Turlock, US 2021-05-15 Maddy Dixon Mooresville, US 2021-05-15 AJ Wilson Austell, US 2021-05-15 Braden Cookmeyer Kenner, US 2021-05-15 Andrew Reed Muskegon, US 2021-05-15 kacie knudson Eagle Mountain, US 2021-05-15 Mara Wallace Palo Alto, CA 2021-05-15 Utkarsh Contractor Fremont, CA 2021-05-15 Jessycka Rodriguez Harlingen, US 2021-05-15 Briana Ortiz Lebanon, US 2021-05-15 Lauren Kuba Land O Lakes, US 2021-05-15 Paige Parenti Palo Alto, CA 2021-05-15 Sara B Akron, US 2021-05-15 Richard Nuno Valencia, CA 2021-05-15 Name Location Date kenzie sherrell Brazil, US 2021-05-15 Lexie Lopez Salt Lake City, US 2021-05-15 jonathan hoefert thornton, US 2021-05-15 Janyah Rosario Reading, US 2021-05-15 Daniel greenspan Wantagh, US 2021-05-15 Jermayne Long Grand Rapids, US 2021-05-15 Jolie Dupuy Luling, US 2021-05-15 Baylee Leroy kansas, US 2021-05-15 Angie Romualdo Lake Worth, US 2021-05-15 Vivian Eve Park Avenue, US 2021-05-15 Victoria M Campbell, CA 2021-05-16 Meredith Lucy Charlotte, US 2021-05-16 Leslie Luis Paterson, US 2021-05-16 Isabella Fedel Hagerstown, US 2021-05-16 Sarabeth Dunkley Murrieta, CA 2021-05-16 Elana Lian Palo Alto, CA 2021-05-16 Montana Pittman Jasper, US 2021-05-16 Anissa Tse Palo Alto, CA 2021-05-16 News and Gameplay US 2021-05-16 Lauren Sgro Chandler, US 2021-05-16 Coby White Saraland, US 2021-05-16 Victoria Schofield-Nguyen Roseville, US 2021-05-16 Name Location Date Janeea Hill-metz Lebanon, US 2021-05-16 Aparna Seetharaman Menlo Park, CA 2021-05-16 Billy Hoff Egg Harbor Township, US 2021-05-16 Alexa Thompson Stillwater, US 2021-05-16 Christina Hao Palo Alto, CA 2021-05-16 S Gleit San Mateo, CA 2021-05-16 Cheryl Cook San Pablo, CA 2021-05-16 Jaida Sieu Alameda, US 2021-05-16 Raquayya Towler Wildwood, US 2021-05-16 angel chavez Renton, US 2021-05-16 Erin Reis Newark, CA 2021-05-16 Kelsey Flores Fort Lauderdale, US 2021-05-16 Stephen Robles New York City, US 2021-05-16 Emma Mitchell Lake Park, US 2021-05-16 Roberta Pinheiro Palo Alto, CA 2021-05-16 Helen Kim Enumclaw, US 2021-05-16 Paige Madura Saint Louis, US 2021-05-16 Keri Garcia Cape Coral, US 2021-05-16 Amy Mayhue Ada, OK 2021-05-16 Sarah Laughton Santa Cruz, CA 2021-05-16 Pamela Moller Coppell, US 2021-05-16 Arjundip Singh Grand Forks, ND 2021-05-16 Name Location Date Mohamed Bakkar Cairo, US 2021-05-16 Andrew Coleman Glassboro, US 2021-05-16 Maya Moore Riverdale, US 2021-05-16 Roxanne Reeves Palo Alto, CA 2021-05-16 Jamie Miller Akron, US 2021-05-16 Hailey Goble Marion, US 2021-05-16 Neima Nour Burlington, US 2021-05-16 Melissa Hopkins Palo Alto, CA 2021-05-16 Antonio Vazquez Bayamón, US 2021-05-16 Isabel Norris Prairieville, US 2021-05-16 karen lópez bay area, US 2021-05-16 Allison G Levittown, US 2021-05-16 Matt Long Nashville, US 2021-05-16 Carla George Arcadia, US 2021-05-16 Melissa Kirven-Brooks Palo Alto, CA 2021-05-16 Gary Wells Chesapeake, US 2021-05-16 Daniel Coxson Olney, US 2021-05-16 John Ragno Portland, OR 2021-05-17 Jessica Brooks Somerville, MA 2021-05-17 Darice Koo Palo Alto, CA 2021-05-17 Nynx Rosario Killeen, US 2021-05-17 Al Brooks New York, NY 2021-05-17 Name Location Date Venu Gurijala Clinton, MA 2021-05-17 Roger Brooks Palo Alto, CA 2021-05-17 Naitoka Yuri Goleta, US 2021-05-17 Angel Malvarez South Elgin, US 2021-05-17 Oscar Martinez Westchester, US 2021-05-17 Monica Wang Cupertino, CA 2021-05-17 alijah brandao Chesapeake, US 2021-05-17 Marcella Rennert Carpentersville, US 2021-05-17 Abby Valle Neptune, US 2021-05-17 Joy Sleizer Palo Alto, CA 2021-05-17 Kelli Chavez Lewisburg, US 2021-05-17 Mary Lauritzen Sikeston, US 2021-05-17 Denise Weiss Walnut Creek, CA 2021-05-17 Chloe Reynolds Grayslake, US 2021-05-17 jyneth demesa Hilo, US 2021-05-17 Nadia Gomez Toledo, US 2021-05-17 Brandi Garcia Billings, US 2021-05-17 Philip Yang Sunnyvale, US 2021-05-17 Kennedy Snyder US 2021-05-17 Jacqueline D Stockton, US 2021-05-17 Kenadie Banks Norborne, US 2021-05-17 Devren Breaux San Jose, CA 2021-05-17 Name Location Date Tristan Hall US 2021-05-17 Jessica Garcia Riverside, US 2021-05-17 Giuseppe Serritella Westmont, US 2021-05-17 mlk edw Canton, US 2021-05-17 Mikel Pierce Commerce City, US 2021-05-17 Joy Rose Redwood City, CA 2021-05-17 Venusian Neon Vendredi, US 2021-05-17 George Orozco Moreno Valley, US 2021-05-17 Elizabeth Reyher Brownsburg, US 2021-05-17 Melanie Grondel Palo Alto, CA 2021-05-17 701-32 DOCUMENTS IN THIS PACKET INCLUDE: LETTERS FROM CITIZENS TO THE MAYOR OR CITY COUNCIL RESPONSES FROM STAFF TO LETTERS FROM CITIZENS ITEMS FROM MAYOR AND COUNCIL MEMBERS ITEMS FROM OTHER COMMITTEES AND AGENCIES ITEMS FROM CITY, COUNTY, STATE, AND REGIONAL AGENCIES Prepared for: 06/01/2021 Document dates: 05/12/2021 – 05/19/2021 Set 3 Note: Documents for every category may not have been received for packet reproduction in a given week. 1 Baumb, Nelly From:William Reller <wereller@664gilman.com> Sent:Thursday, May 13, 2021 2:58 PM To:Council, City Cc:J Martin O'Malley; Sims Lauren (Jackson and Colton); Dr. & Mrs. Feldman Dan & Sandy; Hanna John & Barbara Subject:Fwd: Police Department budget CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  I am in agreement with Martin O’malley’s expressed opinion as indicated below.   It is good that the Finance Committee’s recommendations are in line with his thinking on the matter of police  reductions.  Thank you.  William Reller wereller@664gilman.com       Begin forwarded message:    From: J Martin O'Malley <omalley@fertitta.com>  Subject: Police Department budget  Date: May 12, 2021 at 4:19:23 PM PDT  To: city.council@cityofpaloalto.org    Dear Palo Alto City Council Members,  Please adjust the FY 2022 Budget to avoid eliminating 5 police officers.  Palo Alto employed 50 police officers in FY 2020, budgeted 39 in FY 2021 and proposes to budget 34 in  FY 2022.  We must have an adequate number of police officers to ensure public safety.  Sincerely,   Martin O’Malley  40 Crescent Drive  Palo Alto             2 Baumb, Nelly From:Adi Greif <adi.griffon@gmail.com> Sent:Friday, May 14, 2021 4:47 PM To:Council, City Subject:Idea - use tickets to hide who can and can't pay for PA Junior Museum and Zoo while encouraging payment CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.   Dear City Council,   Thank you so much for reducing the fee to something more reasonable for family visits. There are families for whom this  will be a hardship, while at the same time there are families that can definitely afford to pay but won't if it's seen as just  optional to pay. (I've had people tease me for donating!) Perhaps there are ideas for how to get the best of both worlds ‐  for example, have a ticket you print out ahead of time/barcode on your phone that has an option for "It's a hardship for  me to pay". I think most people who can pay won't click on that button and will pay. And that way, nobody has to know  at the door who paid and who didn't, which protects those who can't afford it.     Also, I'm certain many Palo Alto residents would be happy to help with specific fundraising drives, even when just "we  generally have a deficit" doesn't lead to more donations. If it's possible for the city council to estimate based on past  visit data how much might need to be raised in funds (including some sort of estimate for those who could have paid but  didn't?) then I and others I'm sure would be happy to help with fundraising.    Thank you for helping brainstorm options,  Adi Greif  (faculty spouse, lived at Stanford since age 5, grew up loving the museum and I now love taking my kids there!)  3 Baumb, Nelly From:michelle <michelle@arden.org> Sent:Thursday, May 13, 2021 11:55 AM To:Council, City Subject:Please maintain verbatim transcripts of all City board and commission meetings CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  I am alarmed to hear that the city manager is proposing termination of the generation and posting of verbatim transcripts of city board and commission meetings    This move would dramatically reduce transparency to the city’s residents. We are due a full reporting of all city meetings, and not through the lens of the city manager and his team.    Sincerely,    Michelle Arden  405 Lincoln Ave.  Palo Alto  4 Baumb, Nelly From:Victor Zilinskas <vzilinskas@sbcglobal.net> Sent:Thursday, May 13, 2021 11:26 AM To:Council, City Subject:Other Reasons Not to Defund the Police CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council Members, Some other reasons not to defund the police are if residents fell less safe they will have no choice but to take other measures to protect themselves. One option residents may take is to buy firearms to protect themselves. This is a 2nd Amendment Right to Own firearms for protection. There are some people that do not own guns, but will be incentivized to do so if the police cannot be relied upon. That will be an unintended consequence of defunding the police. I would rather have "Trained Professionals" providing protection. Others with more resources may even hire private security. That's what some politicians did after they pushed for defunding the police, and THEIR safety was threatened. Other possibilities could be to work with existing law enforcement on salary and benefit reductions, so the number of personnel can be maintained or brought to a level that provides the safety and response times for Palo Alto residents. Many of us have worked in High Tech and other industries that have implemented salary and benefit cuts when there was an economic downturn. You could do it for say 1 or 2 years if needed then relook the budget at the end of that period. Any funding we do must have the training and support the police need to do their jobs safely and effectively. Its a conversation, a process to come to a workable solution. Finally, Palo Alto as a community MUST SUPPORT our Police Force. Every Palo Alto officer I have met has been approachable and polite. Studies show that police presence reduces crime. Most of the time its just knowing the police are around that deters trouble makers. The police can be called on to make a life or death decision to protect innocent people from violence. We are relying on their skills to make difficult decisions. They deserve our respect as they serve us. We pay their compensation through OUR taxes. We are in this together. Sincerely, Victor J. Zilinskas 524 Patricia Lane Palo Alto, CA 94303 5 Baumb, Nelly From:Christina Schmidt PTAC <president@paloaltopta.org> Sent:Wednesday, May 12, 2021 2:35 PM To:Council, City; City Mgr Cc:Jennifer DiBrienza; Shounak Dharap; Don Austin Subject:Palo Alto City Council Budget and School Crossing Guards Attachments:PTAC Letter to City Council May12.2021_encrypted_.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council and City Manager,     Attached, please find the Palo Alto Council of PTAs letter regarding the City Budget Cuts and School Crossing Guard staff  reduction.   Please let me know if you have any questions.      Sincerely yours,     ~ Christina         Christina Schmidt, President  Palo Alto Council of PTAs  Every Child, One Voice  email:president@paloaltopta.org  Web: https://ptac.paloaltopta.org/  email:council@paloaltopta.org  6 Baumb, Nelly From:Jeremy Erman <jeremy_erman@yahoo.com> Sent:Wednesday, May 12, 2021 12:27 PM To:Council, City; Administrative Services Cc:O'Kane, Kristen; info@friendsjmz.org Subject:JMZ fee compromise idea CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear City and Friends,    I personally feel, like so many others, that $18 is far too high a drop‐in fee for the new JMZ.    However, here is an idea that could work with any fee level: non‐members could register their name and address with  the Museum, if they so choose, so that their attendance fees are recorded whenever they visit, so that once they or  other family members accumulate the cost of an annual membership, they automatically become members and would  not have to pay any more entrance fees for the year.    This way, the cost of any one family attending the JMZ during a year would be capped at the cost of the applicable  annual family membership.    This would be a strictly opt‐in program, so that no one would have to register their personal information with the  museum unless they so chose.    This is, by the way, the way a Day Pass works on VTA transit; you pay per ride until you reach the price of a Day Pass, and  then don't pay any more.    This might help compromise between the needs of charging an entrance fee and encouraging frequent visits to the new  JMZ.    Best,    Jeremy Erman  1 Baumb, Nelly From:Sheri Furman <sheri11@earthlink.net> Sent:Saturday, May 15, 2021 7:57 PM To:Council, City Cc:jdong@paweekly.com; gsheyner@paweekly.com; price@padailypost.com; jgreen@dailynewsgroup.com; Cook, James F. Subject:PAN Letters regarding 955 Alma and 2239 Wellesley Attachments:955 Alma PAN Letter.docx; 2239-41 Wellesley PAN Letter.docx CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Please see the attached letters regarding items 1 (955 Alma) and 2 (2239 Wellesley) on the May 18 Council agenda. Thank you, Sheri Furman Subject Line: 955 Alma is a $4 Million Developer Giveaway Dear Councilmembers: 955 Alma is an unprecedented giveaway of millions of dollars to a private developer under the guise of affordable housing. At the May 2021 PAN (Palo Alto Neighborhoods) meeting, our members voted to have us communicate to you about this and other major concerns we have about the proposal. 20% AFFORDABILITY IS VASTLY OVERSTATED: The staff report incorrectly claims that, “Twenty percent of the housing units (seven total) are proposed to be affordable,” which amounts to seven units. • Three of those will actually be rented at market rate ($3,000 a month) and a fourth at $2,973 a month, which is less than a 1% discount. • These four tiny studios will average just 342 sq. ft. in size, which is smaller than a two-car garage, and many will have no parking space. • So these four units are being offered at top market rates and are not at all “affordable.” • That means only three units out of the 36 in the building will truly be below-market, or about 8% of the housing units, not 20%. STAFF REPORT FAILS TO EVALUATE THE TRUE PUBLIC BENEFITS A key question that has plagued PCs in Palo Alto for years is whether the City is receiving adequate benefits in exchange for the bonuses it allows developer. The staff report does not attempt to evaluate this at all, but we calculate that the City is receiving $4 million less in benefits than the value of the bonus the developer seeks. Here’s how we figured that: First, the developer is asking for the right to build about 16,073 square feet in excess of what the normal zoning allows. • Other developers have had to pay for the right to do this by purchasing TDR (Transferable Development Rights). • Back in 2018, the city itself sold TDRs for about $341 per square foot. • At that rate, 955 Alma should be paying about $5.5 million for the extra square feet it wants. Next, what is the benefit of the three below-market units the building will provide? • The rent on each would be $1,382 a month, representing a discount of $1,618 off the regular $3,000 rent, which means the building will collect $58,248 less in rent a year for all three units combined. • At a typical 4.2% capitalization rate, a rental property earning that much less a year will sell for a discount of about $1.4 million. • In other words, a potential buyer assessing what the building is worth would want to pay about $1.4 million less because of those three below-market rate units. • So we think it reasonable to say that the economic benefit to the tenants of those three units over the life of the building, and thus to the City for its affordable housing goals, is that very same amount, namely $1.4 million. The obvious problem then is that the $5.5 million in extra square footage that developer gets at no cost exceeds the $1.4 benefit to the City by more than $4 million dollars. Simply put, this is a terrible deal for the City and for its goals of affordable housing! HOW TO FIX THE IMBALANCE: It’s easy to fix this problem. The City can simply insist that instead of three units being offered for $1,382 a month, the building should have 12 such units. That would increase the affordable housing benefit to about $5.5 million, or about what the City would collect if it were to sell a TDR for the same amount of extra square footage. In general, we urge you to never look only at the percentage of a building that’s “affordable.” To say that a PHZ project requires 20% affordable housing and is thus better than the 15% often required already by the city is misleading. One must look at the specific rents for each unit to avoid being misled. For example, note that 955 Alma’s units at the 81% to 120% “moderate income BRM” level will be rented at $2,978 a month, which is just a few dollars under the market rate of $3,000 a month. If the project switched to having all units at this rent level, it could call itself 100% “affordable,” and yet tenants and the City would receive virtually no benefit. Calculating how much less a building is worth due to its mix and type of affordable units is a far better way to evaluate the public benefit. PARKING PROBLEMS 955 Alma’s request for a 30% residential parking reduction is worrisome. Although the staff report does not provide details for this particular building, parking reductions of 30% in Palo Alto generally require both a TDM (Transportation Demand Management) plan and a joint-use reduction. But a joint use reduction makes no sense for 955 Alma for many reasons, including: 1) 2019 U.S Census data shows that 94% of Palo Alto households have at least one car and that’s especially likely for employed renters who earn enough to pay $3,000 a month in rent. 2) A joint-use reduction relies on residents driving off on workdays, freeing up parking spaces for office workers. But 955 Alma’s residential units are being promoted as work-live, meaning residents wouldn’t leave during the day. Instead, their cars will remain parked at the building and their parking spaces won’t be available to the office workers. 3) A strong TDM encourages people to walk, bike, carpool, and use transit. So that’s another reason why residents won’t move their cars during workdays, leaving them parked at the building and not freeing up parking spaces for the office workers. 4) The offices at 955 Alma will themselves be under-parked by 40% to 56% (25 are required but only 11 to 15 will be provided), thanks in part to grandfathering. So there won’t be many free office parking spaces for the residents to use at night – plus the staff report says the office parking spaces will be dedicated and thus not available for resident use. 5) The City has eliminated the requirements for residential guest parking. But guests will still come, exacerbating parking problems on the street. 6) Past mixed-use reductions have relied on statistics compiled from comparable situations elsewhere. 955 Alma’s unique combination of tiny residential units, a work-live rather than commuter modality, inconvenient stacker parking, and under-parked offices will have no parallel, so there simply won’t be any good statistics to use for the parking analysis required by our Municipal Code section13.52.050 as the basis for granting joint-use parking reductions. We therefore recommend the Council allow instead very conservative parking reductions for this project, given its proposed work-live residences and severely under-parked offices. We also urge the Council to help insure the building’s TDM goals are met by not allowing any of its occupants to purchase RPP permits. Thank you for consideration of these important issues, Sheri Furman and Rebecca Sanders PAN (Palo Alto Neighborhoods) Co-Chairs P.S. Here’s some further information about using TDR pricing to evaluate the benefit of extra square footage. Square footage purchased via TDRs can be used to build housing, although it is generally used for offices, which might cause some to think TDR pricing may not be the right metric to use for the value of extra square footage for a mostly-residential project like 955 Alma. However, the small units proposed for at 955 Alma actually earn gross rents of $5.32 per square foot (factoring Subject Line: 955 Alma is a $4 Million Developer Giveaway 2 Baumb, Nelly From:Chris Robell <chris_robell@yahoo.com> Sent:Friday, May 14, 2021 9:18 AM To:Council, City Subject:955 Alma St Attachments:L. Beaton Letter to City Council re 955 Alma - 5-13-2021.PDF CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear City Council,    I want to express my support for the attached letter recently sent to you regarding the proposed project at 955  Alma.  Thank you in advance for carefully considering the four key points described so that the community and housing  affordability goals are met.    Chris Robell    3 Baumb, Nelly From:Laura Beaton <Beaton@smwlaw.com> Sent:Thursday, May 13, 2021 4:33 PM To:Council, City Cc:Neilson Buchanan Subject:Letter re May 18, 2021 City Council Study Session: 955 Alma (Item 1) Attachments:L. Beaton Letter to City Council re 955 Alma - 5-13-2021.PDF CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council,    Please find attached a letter on behalf of Neilson Buchanan regarding Agenda Item 1 for the City Council’s May 18, 2021  meeting.    Please let me know if you have any problem opening the attachment.    Best,  Laura Beaton      Laura D. Beaton  Attorney  Shute, Mihaly & Weinberger LLP  396 Hayes Street  San Francisco, CA 94102‐4421  p: 415/552‐7272 x231 | she/hers   www.smwlaw.com | A San Francisco Green Business      SM 40 E 396 HAYES STREET, SAN FRANCISCO, CA 94102 T: (415) 552-7272 F: (415) 552-5816 www.smwlaw.com LAURA D. BEATON Attorney Beaton@smwlaw.com May 13, 2021 Via Electronic Mail City Council of the City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 E-Mail: city.council@cityofpaloalto.org Re: 955 Alma Street: Comments re PHZ Prescreening Dear Council Members: I represent Neilson Buchanan and submit this letter on behalf of Mr. Buchanan and other concerned residents in the neighborhood regarding the City Council’s prescreening of a proposal to redevelop 955 Alma Street with a four-story mixed-use development. The proposed development would include over 6,300 square feet of office space and 36 residential “microstudio” apartments, including 7 income- restricted inclusionary housing units. Mr. Buchanan strongly supports the development of more affordable housing in Palo Alto, especially in transit-rich locations like 955 Alma. We provide these comments to seek the Council’s consideration of a few key issues that could ensure a project that is beneficial for the project’s future residents, the surrounding neighborhood, and all of Palo Alto. Specifically, the Council should (1) maximize affordable housing requirements with a focus on deep affordability, (2) ensure equitable access to amenities for affordable housing residents, (3) prevent units from being removed from the housing market for use as short-term rentals, and (4) exclude the development from the existing Downtown Residential Preferential Parking (RPP) District. I. Maximize Affordable Housing. The City Council should ensure that transit-rich, dense housing like the development proposed at 955 Alma includes as much affordable housing as possible within the current proposed footprint and height. Currently, the project proposes 7 designated affordable units: three very-low income units, one moderate income unit, and three “workforce” housing units, relying on the “weighted” approach in Option 2 for SHUTE MIHALY ~ w E I N B ERG ER LLP City Council of the City of Palo Alto May 13, 2021 Page 2 calculating affordable housing for PHZ projects, which was approved by the City Council at its September 21, 2020 meeting. Mr. Buchanan strongly supports the City’s goal to include below-market- rate units in new developments like these. We note, however, that due to the “micro” size of these units, there is little actual benefit to moderate income and workforce housing tenants, who would pay the same or virtually the same rent as market-rate tenants. The pre-screening letter from the applicant’s architect indicates that designated workforce units would be rented at the same rate as market-rate units, and moderate income BMR units would enjoy a mere $27 per month discount on market-rate rent. This renders the benefit of the so-called affordable units somewhat illusory. Affordable rent for BMR units is calculated based on the Low Income Housing Tax Credit Program methodology, which establishes rents at 30% of the AMI tied to the unit, taking into account how many people are assumed to live in the unit. Relevant here, the maximum rent for any very-low-income studio in Santa Clara County is $1,382, and for any moderate-income studio is $2,973. This allowable rent does not take into account the size of the unit. This allows the developer here to collect market- rate rent while claiming units fulfill below-market-rate requirements. The result is that the developer can arguably meet the letter of the City’s inclusionary housing policies for PHZ projects, without satisfying the policies’ intent. Instead, the City should aim for a more deeply affordable mix of inclusionary units in this project—or even seek to find a way to develop a 100% affordable development—that which would provide actual affordability to the most vulnerable Palo Alto residents, who desperately need access to housing. Either way, the Council should seek to encourage truly affordable developments, instead of allowing the developer to meet its affordable housing requirements while renting 4 of its 7 “affordable” units at essentially market rate. II. Ensure Affordable Units Have Equal Access to Amenities. When considering this project, the Council should also ensure that affordable units are treated equitably to market-rate units, as required by Palo Alto Municipal Code (PAMC) section 16.65.075. Specifically, affordable units should enjoy dispersal throughout the building, equal size to market-rate units, equal outdoor space, and equal access to parking. Each of these issues is discussed in more detail below. Unit location. Alma Street and the adjacent train tracks are known to have very high noise. Six of the 36 units (16.6%) directly face Alma and the train tracks and SHUTE MIHALY ~WE IN BERGER LLP City Council of the City of Palo Alto May 13, 2021 Page 3 thus will experience more noise impacts. To avoid inequitable treatment of affordable units, no more than 16.6% of the affordable units (or, roughly, one affordable unit) should face Alma Street. Unit size. The proposed developments’ microstudio units range in size from 329 to 516 square feet, with most units being between 329 and 347.5 square feet, and 6 larger units being between 377 and 516 square feet. The Council should direct the developer to designate at least one of the 6 larger units as inclusionary housing, and the remaining affordable units should be equally distributed among the range of smaller unit sizes—not all designated as the smallest, 329 square foot units. Outdoor space. The Council should confirm that the rooftop common space is equally accessible to affordable unit residents, and that affordable units are not left with only the smallest private decks. Parking. The proposed project would include 40 parking spaces, though City staff has indicated that the four spots on Alma Street are problematic as designed. Only 25 of those spots would be available to the 36 residential units, potentially leaving 11 residents without available parking. As required by the PAMC, the affordable units must have equal access to parking, and so at least a proportional number of parking spots should be allocated specifically to the affordable units. If the developer intends to “unbundle” parking from rental units and rent the parking separately, the Council should require that the spots reserved for inclusionary units be provided for free, or at least rented at reduced rates that would be affordable to those tenants. For example, the City of San Francisco requires unbundled parking to be rented to BMR tenants at significantly reduced rates that such tenants can afford.1 Finally, we urge the Council to consider allocating more parking spots to affordable units than would be proportional to the number of those units. Lower income tenants are more likely to be car-dependent than their wealthier counterparts. They are more likely to be unable to work from home, have longer commutes without employer 1 See City & County of San Francisco Mayor’s Office of Housing and Community Development, Inclusionary Affordable Housing Program Monitoring and Procedures Manual, at 68 (Oct. 11, 2018), available at https://sfmohcd.org/sites/default/files/Documents/MOH/Inclusionary%20Manuals/Inclusi onary%20Affordable%20Housing%20Program%20Manual%2010.15.2018.pdf SHUTE MIHALY ~WE IN BERGER LLP City Council of the City of Palo Alto May 13, 2021 Page 4 subsidies like transit passes or private commuter buses, and have irregular hours that make reliance on public transit impractical. III. Ensure Housing Remains Housing. The PAMC currently does not allow use of rental units as short-term, hotel- like “AirBnB” rental units. Nonetheless, such units have proliferated in Palo Alto and have reduced residents’ access to housing. The Council should consider measures to ensure that this much-needed housing remains available to long-term residents and does not become the subject of a bait-and-switch like one that recently occurred in San Francisco. A San Francisco development at 2100 Market Street achieved support from residents and the Board of Supervisors by touting the large number of units it would add to the City’s strained rental market. But after securing widespread buy-in, acquiring approvals, and building the project, the developer pivoted and leased the entire building to a startup called “Sonder,” which rents apartments for short periods of time – but longer than 30 days – at a premium.2 This unexpected transformation from housing to de facto hotel angered neighbors and officials alike, who felt duped. One San Francisco Planning Commissioner stated, “I feel like we are being played. … The whole idea that we are solving the housing crisis—really we are solving a hotel crisis.”3 Here, the Council should ensure that the developer rents units on an individual basis to actual tenants and that the building does not become a de facto hotel. IV. Don’t Let the Developer’s Parking Problems Become Everyone’s Parking Problems. Finally, the Council should ensure that this new, dense housing and office development is not able to export its parking problems to the surrounding residential neighborhoods. Specifically, the Council should expressly exclude the development— which is currently outside the border of the Downtown RPP—from future addition to the RPP. 2 “‘Corporate rentals’ draw scrutiny from city officials,” San Francisco Examiner (July 25, 2019), https://www.sfexaminer.com/news/short-term-corporate-rentals-draw- scrutiny-from-city-officials/. 3 Id. SHUTE MIHALY ~WE IN BERGER LLP City Council of the City of Palo Alto May 13, 2021 Page 5 Parking is already quite constrained in the area, and the proposed development at 955 Alma would not include enough parking for all of the residential and office tenants. Providing less parking can reduce car ownership, but this goal would be undercut if there is easy and cheap access to permits to park on streets in the surrounding neighborhoods. Indeed, if the developer rents parking stalls separately from units, comparatively inexpensive RPP permits could become tenants’ first choice, further burdening neighborhood parking supply. Anticipating just such an issue, the City of San Francisco has taken affirmative steps when developing RPPs to exclude new, dense housing. San Francisco Municipal Transportation Agency Staff explained the problem: The [relevant specific plan] includes policies for new developments that limit the number of off-street parking spaces to no more than one per unit or fewer, and require developers to meet trip reduction measures in order to encourage new residents to use alternative modes of travel. Over the last few years, as new high- density housing has been constructed and occupied, residents of such developments have sometimes opted to keep their cars and park them on-street rather than pay between $250 and $400 per month for onsite parking. The residential parking permit program allows residents of those developments, if built within existing parking permit areas, to obtain RPP permits, allowing them to forgo the pricier on-site parking and keep their extra vehicles. Over time, this tends to weaken planning efforts to discourage car use and ownership.4 To resolve the issue, the City designed the RPP “include existing housing but exclude the larger high-density, low-parking projects built since 2016.”5 The Palo Alto City Council should adopt the same approach here, and not consider adding this project to the existing Downtown RPP. Thank you for your careful consideration of this issue. 4 San Francisco Municipal Transportation Agency Staff Report (Apr. 10, 2018), p. 9, available at https://www.sfmta.com/sites/default/files/reports-and-documents/2018/04/4- 17-18_item_12_residential_parking_permit_area_ee_-_dogpatch.pdf. 5 Id. SHUTE MIHALY ~WE IN BERGER LLP City Council of the City of Palo Alto May 13, 2021 Page 6 Very truly yours, SHUTE, MIHALY & WEINBERGER LLP Laura D. Beaton cc: Neilson Buchanan 1371458.1 S H UTE M IHA LY 6.......___WE I BE RGER LLP 4 Baumb, Nelly From:Melanie Grondel <mel.grondel@gmail.com> Sent:Tuesday, May 18, 2021 12:01 PM To:Council, City Cc:Melanie Grondel Subject:955 ALMA Street Micro Studio Development. CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Mayor Dubois and City Council members,      How tiny can you go with micro dwellings ? 342sf ??!!    The developer and the architect claim this as a contribution to the solution for the lack of multi ‐ family housing. I  seriously doubt that.    The developer refers to a tiny studio in his backyard that he rents out with great success. From that example he  extrapolates that a large and dense stack of tiny dwellings is even better.   He forgets that a tiny unit in a backyard is surrounded by green space in a single family neighborhood is an entirely  different situation. While the space inside may be limited,  the outside green space makes up for it, even with outside  seating space.      Please do not consider a tiny garden cottage a valid model for stacking it in a dense stack of 35 units like shoeboxes in a  department store holding space.  All principles of overcrowding will apply.    Thank you for your consideration.  Melanie Grondel,   Resident of Palo Alto   5 Baumb, Nelly From:geetha srikantan <gsrikantan@yahoo.com> Sent:Monday, May 17, 2021 8:28 PM To:Council, City Cc:geetha srikantan; Neilson Buchanan Subject:Letter re May 18, 2021 City Council Study Session: 955 Alma CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City of Palo Alto Council Members, Neilson Buchanan and other concerned residents have submitted a letter, dated May 13, 2021, represented by Laura Beaton, of Shute, Mihaly & Weinberger, LLP, regarding 955 Alma St, PA CA 94301. I am as concerned as Neilson and other residents about the items noted in this letter and respectfully urge Council members to please give serious consideration to all the comments noted in this letter. As a long time resident of Downtown/Downtown North, and seeing how and what issues need to be addressed in this part of our city, I am in support of the proposals put forth in the letter. Thank you, Sincerely, (Dr) Geetha Srikantan 385 Waverley Street Palo Alto, CA 94301 6 Baumb, Nelly From:Mary Dimit <marydimit@sonic.net> Sent:Sunday, May 16, 2021 5:36 AM To:Council, City Cc:Clerk, City Subject:955 Alma Project -- 5/18/2021 Study Session/Special Meeting Item 1 CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Dear City Council Members,    I have three areas of concern related to the housing component of the 955 Alma Project:       Affordable housing requirements and equity issues   Parking requirements and restricting access to the Downtown RPP District   Ensure the rental units are part of the housing market and not commercial use as short‐term rentals  Affordable housing requirements and equity issues    The micro‐units designated as affordable housing are misleading. Four of the seven (moderate income and  workforce housing) are being offered at or almost at the market rate which does not really benefit those  tenants. City Council can strongly encourage and preferably require the developer to offer more realistic  affordable housing.   The affordable housing units should be treated equitably with the market‐rate units, meaning there should be  a mix of unit sizes (not just the smallest units assigned to be affordable housing), not all the affordable housing  units be assigned along Alma St., all common spaces are accessible to all unit residents, and all affordable  housing should not have to pay for assigned parking spaces on the premises.    Parking requirements and restricting access to the Downtown RPP District    It is great that there will be both short‐ and long‐term bike parking on the premises. However, the project is  under‐parked for cars with only 25 spaces for 36 proposed units. The intent of providing insufficient parking  spaces for tenants is to reduce their car ownership. That is difficult given that transportation options between  homes and jobs do not always match the needs of the commuter. (That said, even though our four  environmentally‐conscious family members have almost always walked, biked, or taken trains, bus shuttles,  light rail, instead of commuting to our jobs via car ‐‐ we still have needed a car for all our other activities.)    The City of Palo Alto's RPP Districts have been designed for existing housing and not for the high‐density, low‐ parking projects built in the last five years. City Council must not add the 955 Alma project to the Downtown  RPP District, otherwise the residents in this project would be able to park in the nearby neighborhood and  limit parking availability to the existing neighborhood housing. This parking intrusion will be even more likely if  the developer rents the limited parking spaces separately ‐‐ instead of including them in the unit's rental fee.    Ensure the rental units are part of the housing market and not commercial use as short‐term rentals  7   I encourage City Council to ensure that this much‐needed housing will be used to meet long‐term housing  needs and does not reduce residents' housing options by converting the rental units to short‐term commercial  (hotel or AirBnb‐like) housing.    Thank you for your contributions to Palo Alto,    Mary Dimit  University Ave.  8 Baumb, Nelly From:Donald A. Barr <barr@stanford.edu> Sent:Friday, May 14, 2021 3:42 PM To:Council, City Subject:955 Alma Street: PHZ Prescreening CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Council Members,     As a close neighbor to 955 Alma Street and as someone who has worked for more than two decades to  expand affordable housing in Palo Alto, I would like to express both my support for the proposed project and  my serious concern about the level of affordability in the project as currently proposed.    The proposed project would include 36 rental apartments labeled as “micro studios”, the majority of which  would be between 325 and 350 square feet in area. I believe these units would be a valuable addition to the  housing in the downtown/SOFA area, especially given the proximity of the CalTrain station. However, I find the  proposed level of affordability for these units to be unacceptable. I would urge the Council:  • To require than 12 of the 36 units be available to low‐income and very‐low‐income tenants (6 low‐income  and 6 very‐low‐income);  • To assure that rents for these units will not exceed 30% of household income;  • To assure that these units will remain as affordable rental units for a minimum of 30 years.  If these requirements were met, the project would be a valuable addition to the affordable housing resources  in Palo Alto.    I have serious concerns about the stacked parking proposed for the project. The very small area of the garage  space would, in my opinion, create a substantial risk of vehicular damage. I ask the council to consider this  issue in their review of the project.    Thank you for your support of additional affordable housing in Palo Alto.    Sincerely,  Donald Barr   9 Baumb, Nelly From:Allen Akin <akin@arden.org> Sent:Friday, May 14, 2021 2:12 PM To:Council, City Subject:May 18, 2021 Council Meeting Item 1: 955 Alma Prescreening CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Council,    I support this project if three conditions are met.  One additional matter would be worth discussion.    Condition 1: Commitment to reduced parking    The project is based on the belief that proximity to transit will significantly reduce the need for personal vehicles and the  amount of parking required for them.  While the main purpose of reduced parking is to increase the developer's return  on investment, it also advances the City's sustainability goals.  If this belief turns out to be mistaken, nearby residents  and businesses would bear the costs of increased contention for parking resources, and the sustainability goals would be  compromised.    Therefore, for fairness and for consistency with the City's goals, neither commercial tenants nor residential tenants of  the building should be eligible to purchase parking permits in the commercial district lots and garages or in the  Downtown RPP district.  This condition, and provisions for enforcing it, must be stated in the project's TDM plan.  The  condition must also be explicit in all sale or lease agreements in perpetuity.    Condition 2: Secure bicycle storage    Perhaps I missed it, but when I examined the project plans I didn't see a secure weatherproof enclosure for bicycle  storage.  To reduce the need for personal vehicles, one should be provided, preferably at ground level.    Condition 3: Noise protection for lower‐income tenants    Any window or balcony with line‐of‐sight to Alma will be unusable due to high noise levels.  I assume the architect will  specify noise‐reducing construction for doors and windows.  However, it's unavoidable that some units will be subject to  much more noise than others, particularly at the balconies.  As a matter of fairness, the affordable units should not be  concentrated in the noisiest locations.    Discussion Item: Increasing the number of affordable units    The fraction of affordable units proposed for this project is less than the fraction of Santa Clara County's population that  meets the corresponding income definitions.  As a result, this project increases gentrification.  It would be worthwhile  for the developer to conduct a good‐faith discussion with Staff to check the project financials and see if any increase in  the number of affordable units would be possible.  The results of that negotiation should be made available to Council.    Best regards,  Allen Akin  1 Baumb, Nelly From:Amie Ashton <aashton@gmail.com> Sent:Tuesday, May 18, 2021 10:25 AM To:Council, City Subject:Support for HOUSING! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Honorable City Council,     I am writing in support of the housing projects that are on the agenda tonight, the 36 units on Alma (microunits are  amazing, after all ‐ half of Paris lives quite happily in small units like this) and the 24 apartments on Wellesley.    I support a community that is diverse and providing a diversity of housing is the first step in that journey. Housing also  supports our vital retail areas by creating more customers and supporting longer business hours for sales to occur. Our  downtown areas cannot survive as malls (which are dying by the hundreds right now). We need more residents to  provide retail and restaurant demand.    I also urge the removal of barriers to housing on all fronts, from removing parking requirements to lessening fees. We cannot simultaneously support affordable housing while creating additional barriers for housing developers.     Thank you,    Amie Ashton  236 MIddlefield Road  2 Baumb, Nelly From:slevy@ccsce.com Sent:Sunday, May 16, 2021 5:02 PM To:Council, City; Planning Commission Cc:Lait, Jonathan; Wong, Tim Subject:Study session items 1 and 2 5/18/21 CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Mayor DuBois and council members, The council has a chance to give positive feedback to am mixed use, mainly housing project on Alma on a site close to jobs, services, shopping and transit and at the same time correct a premature decision with regard to the application of PHZ projects in R-1 neighborhoods. The Alma project would add housing and reduce office space on a desirable site. The Wellesley project would add housing oriented to both the missing middle and low income residents. That site, like the Alma site, is close to jobs, services, shopping and both freeways and public transit. Both projects meet a city goal of projects with 20% BMR units. Taking any housing options off the table either with regard to PHZ zoning or the NVCAP area before the housing element site review process even begins strikes me as reckless and irresponsible and puts the city at legal risk since it is very likely that we will easily find suitable sites and policies to incentivize 6,000 units or even a bit smaller if the city wins an appeal. One of the requirements of the housing element is to identify and overcome challenges to meeting our housing goal. I understand that there is political pressure to to oppose state law and many projects but your job as the Mayor has said is to proceed with a good faith effort to meet ALL of the housing element update requirements. Please let the housing element process develop findings before taking housing options off the table. Stephen Levy 1 Baumb, Nelly From:Palo Alto Forward <palo.alto.fwd@gmail.com> Sent:Tuesday, May 18, 2021 9:11 AM To:Council, City; DuBois, Tom; Filseth, Eric (Internal); Kou, Lydia; Tanaka, Greg; Cormack, Alison; Burt, Patrick; Stone, Greer Subject:Comments on Palo Alto's Affordable Housing Month Attachments:Dear City Council,.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Mayor DuBois and Palo Alto City Council,    Thank you for your Affordable Housing Month Proclamation, calling upon our community to support affordable housing solutions. Palo Alto Forward has joined this regional effort as a sponsor for Silicon Valley at Home’s Affordable Housing Month. It is our hope and expectation that the Council will take the proclamation seriously by taking actions to support it.    This month is a time to celebrate the ways we support one another and reflect on the importance and value of affordable housing in our communities. Affordable housing is essential to our community. It provides opportunities and allows for economic and racial diversity. It creates equity for residents of all income levels. But our Proclamation isn’t enough. Without actionable steps connected to this declaration it is little more than a performance. We must demonstrate a willingness to work with housing developers in order to meet our affordable housing needs.     Unfortunately, so far in 2021, the Palo Alto City Council has taken a number of steps which are detrimental to affordable housing (new affordable and below market rate homes):       Disproportionately  increased impact fees for multi-family housing projects from  $5,557/unit to $47,707/unit (over 850%)       Limited  the Planned Home Zone applications and restricted new affordable housing proposals  on single family lots (This action limited the possibility of even hearing  about innovative housing proposals)  2      Signaled non-support or  created roadblocks for housing project proposals (all including below market rate homes) totalling almost 600 needed housing units:  o o 3300 El Camino - 187 apartments o (PHZ) o   Proposal shifted to by-right  office  o o 2951 El Camino - 113-119 o apartments (PHZ) o   Proposal only moving forward if reduced in size  o o 3397 Fabian Way - 290 apartments (HIP) o   Proposal unlikely to move forward  o o Wellesley Avenue - 24 apartments (PHZ) o   Multi-family eliminated at site  These 600 new homes are unlikely to be built because of our failure to lead on housing.    Through the RHNA process, Palo Alto is responsible for identifying policies and feasible sites for an additional 6,086 units of housing in our opportunity-rich city. Reaching this level would enable more economic diversity in our community, shorter commutes for essential workers (especially for sites adjacent to transit and jobs), support sustainability goals, and help the region reduce homelessness and overcrowding in existing units.     Palo Alto Forward is committed to supporting the RHNA process and its goals because affordable housing in cities like ours are the best way to create long term self-sufficiency and economic mobility for low-income community members. We hope that this Council will join us in seeing this as an opportunity for renewal and change, rather than appealing a process aimed at promoting equity.     3 Sincerely,  Gail Price, President Palo Alto Forward   May 18, 2021 Dear Mayor DuBois and Palo Alto City Council, Thank you for your Affordable Housing Month Proclamation,calling upon our community to support affordable housing solutions.Palo Alto Forward has joined this regional effort as a sponsor for Silicon Valley at Home’s Affordable Housing Month. It is our hope and expectation that the Council will take the proclamation seriously by taking actions to support it. This month is a time to celebrate the ways we support one another and reflect on the importance and value of affordable housing in our communities. Affordable housing is essential to our community. It provides opportunities and allows for economic and racial diversity. It creates equity for residents of all income levels. But our Proclamation isn’t enough. Without actionable steps connected to this declaration it is little more than a performance.We must demonstrate a willingness to work with housing developers in order to meet our affordable housing needs. Unfortunately, so far in 2021, the Palo Alto City Council has taken a number of steps which are detrimental to affordable housing (new affordable and below market rate homes): ●Disproportionately increased impact fees for multi-family housing projects from $5,557/unit to $47,707/unit (over 850%) ●Limited the Planned Home Zone applications and restricted new affordable housing proposals on single family lots (This action limited the possibility of even hearing about innovative housing proposals) ●Signaled non-support or created roadblocks for housing project proposals (all including below market rate homes) totalling almost 600 needed housing units: ○3300 El Camino - 187 apartments (PHZ) ■Proposal shifted to by-right office ○2951 El Camino - 113-119 apartments (PHZ) ■Proposal only moving forward if reduced in size ○3397 Fabian Way - 290 apartments (HIP) ■Proposal unlikely to move forward ○Wellesley Avenue - 24 apartments (PHZ) ■Multi-family eliminated at site These 600 new homes are unlikely to be built because of our failure to lead on housing. Through the RHNA process, Palo Alto is responsible for identifying policies and feasible sites for an additional 6,086 units of housing in our opportunity-rich city. Reaching this level would enable more economic diversity in our community, shorter commutes for essential workers (especially for sites adjacent to transit and jobs), support sustainability goals, and help the region reduce homelessness and overcrowding in existing units. Palo Alto Forward is committed to supporting the RHNA process and its goals because affordable housing in cities like ours are the best way to create long term self-sufficiency and economic mobility for low-income community members.We hope that this Council will join us in seeing this as an opportunity for renewal and change, rather than appealing a process aimed at promoting equity. Sincerely, Gail Price, President Palo Alto Forward 4 Baumb, Nelly From:Hank Edson <hank.edson@gmail.com> Sent:Monday, May 17, 2021 2:13 PM To:Council, City Cc:Ingrid Rulifson; Andrew Fetter; Jeff Stoen; Sukhi Nagesh; Kara Davis; Carol Li; Cook, James F.; mattydavis139@gmail.com; Annawork Lembke; Berkeley Revenaugh; Clara Stoen; Colin Born; Daniel Kaleba; Valerie Sarma; Al Gianotti; Andrea Cook Fleming; Eileen Stolee Subject:Wellesley St. Proposed Project - Developer's Recent Misconduct Attachments:Exhibit 1.jpg; Exhibit 2.jpg; Exhibit 3.jpg; Exhibit 4.jpg; Exhibit 5.jpg; Exhibit H.jpg; Exhibit I.jpg; Exhibit M.jpg; Exhibit N.jpg; Exhibit B.pdf; Exhibit C.pdf; Exhibit D.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Council Members,  I want to thank you for recently affirming the limited application of the PHZ tool and say that ‘incentivizing’  private developers to achieve a public policy goal of building affordable housing is the wrong  approach.  Instead, city council should take on the leadership of developing a citywide map and plan for  achieving the needed increase in affordable housing units through a process that brings all stakeholders to the  table and applies affordable housing industry standards.   I also want to alert you to Cato Investment’s outrageous conduct this past week in its deceitful staging of a  “community conversation” in which the actual community was prohibited from offering untampered  input.  Cato’s “conversation” consisted of five panelists, four of whom were not Palo Alto residents, who spoke  at the audience for nearly an hour falsely representing themselves and the issue at hand.  No comments from  the public were allowed.  Only at the end could questions be asked but these were forced to accept Cato’s  falsely asserted premises, and were kept hidden from the public.  Panelists only answered questions they  wanted to answer, and these were edited and falsely represented to the audience.  (See Exhibit 1 through  4)  In particular, I draw your attention to the way Cato used Josh Zimke, a first‐year law student at Stanford  with an admirable commitment to progressive activism, inducing him to emcee a dishonest event with no  regard for its impact on his reputation.  (See Exhibit 4 for further description)  This bad behavior stands in  stark contrast to the outreach being conducted by Mercy Housing and Abode Communities in the 231Grant  Avenue project.  (See Exhibits H, I, M & N)  But Cato Investments is also unacceptable for two other reasons.  First, its economic activity purchasing numerous lots around Palo Alto, especially in College Terrace, actually  drives up prices for families trying to get into the housing market.  (See Exhibit 5)  This activity is for  profit.  Likewise, Cato’s proposed development dedicates a mere 20% of its units to affordable housing, and  these are studios and one bedrooms.  Such a paltry contribution would not offset the inflationary effect of  increasing unit density by twelve times on a residential lot.  The proposed project would not lower housing  costs.  It would increase them.  (See UBC's Professor Patrick Condon presenting his research at https://www.youtube.com/watch?v=24vf2c9AIwQ)  Attendees who could not share their emotional upset during the event due to the tight control and  manipulation of the “conversation” by Cato and its panelists, later described the event as insulting, inspiring  5 outrage, out of the George Orwell novel 1984, exploding their head in its brazen and shocking dishonesty, as a  tooth fairy story, and falsely accusing opposition as in violation the law.  One attendee noted:  “I’ve been on multiple Zoom all hands meetings at my company and the Q&A stream is seen by all  attendees. Uncomfortable and even inappropriate questions scroll by but they try to answer them all.  This meeting was a joke. I submitted questions, tried to chat with the panelists ... not one thing got  answered even privately. If this is their way of connecting with the community, with a one way lecture  cheery picking questions from their constituents, they failed miserably!”    Second, Cato’s proposal fails to meet affordable housing industry standards embodied in the Grant Avenue  project, namely: 1. It should be 100% affordable housing, 2. The land should be owned by the city, county or other  public agency, 3. The developer should demonstrate financing‐obligation and tax‐benefit transparency and rigorous  accounting practices before claiming non‐profit status, 4. The developer should be chosen through a strictly  scrutinized public bidding process, and 5. The developer should engage in extended, open, democratic, authentic  community dialog free of manipulation.  In my opinion Cato, which has no experience in building non‐profit affordable housing, and which, at the same time,  is headed by Jeff Colin, who also heads Baker Street Investments, which manages over $10 billion in assets, is  partially owned by Affiliated Fund Management, which manages over $700 billion in assets, should be blacklisted  from receiving any permits from the city of Palo Alto.  (See Exhibits B, C, and D for information about these  entities)  Cato's conduct has been dishonest and counter to city resident’s interest in both affordable housing and  zoning protections.  City council is here to serve and protect the people who live in our city, not outside corporate  interests of concentrated wealth that dishonestly portray themselves as serving affordable housing goals while  simultaneously running a business that offers billionaires tax‐advantageous investments.  These two activities are  irreconcilable and it is the city council’s responsibility to protect the residents of Palo Alto from Cato’s abusive  misconduct.    Thank you.      Hank Edson  2106 Oberlin Street,  Palo Alto, CA  94306  From The Well. .. to All panelists and attendees: it 1: While the speakers talke.d AT the vou .can se e #' ot attendees ,n . nce'A.. attempts to comment were hidden Lr ,e t o o cortle r . the pul:>11t ana ignored by the panelists. From Me to All panelists: So this is not a dialog; it's you taking our time to talk at us. Gas lighting. The issue is: We don't need middle man investors who DON'T PLAN TO LIVE HERE acting as middle men driving up land values. CATO is just a middle man investor driving up land To: All panelists ~our text can onJbe seen by panelists it 2: WhiJ.s. t!)~Sl?fg ~r~Ji!J~E:!,~T the audience, attempts to comment by ers of the audience were kept hidden and were ignored by the panelists. ents about the impropriety of the procedure being employed were not ssed or acknowledged, The issue is: We don't need middle man investors who DON'T PLAN TO LIVE HERE acting as middle men driving up land values. CATO is just a middle man investor driving up land prices, buying lots out from under families who actually want to live here and then selling them at a profit. The latest is the worst: Presuming as outsiders to impose on a city map its own interests and in the fake name of low income housing. • Exhibit 3: While the speakers talked AT the audience, attempts to comment were hidden from the public and ignored by the panelists. The W t,fm1.h ot Other Sun• WOik l.>1 n 11pc,.:>c--v,~ ... --w•-..r< • •-,-, •- own interests and in the fake name of low income housing. You don't even allow a chat that all attendees can see. You are controlling this entire presentation to appear as a dialog, but imposing an hour of speakers who gaslight and frame the issue dishonestly. To: All pant"lists ~our text can only be seen by panelists TOOW ,mthof h 1nsl 1W'!l,Rle' bf 111 II Exhibit 4: During the curtailed question and answer period, only panelists could see the questions and they only answered questions they wanted to, and then edited and mistrepresented the questions. The young man below is a committed progressive activist, first-year law stu· dent who Cato Investments is responsible for inducing him to participate in such an anti-democratic and dishonest misrepresentation of what was billed as a community conversation. In time, he will feel mistreated by Cato when he thinks about the impropriety in which he participated, Cato hosted the event and is responsible for such unprincipled misconduct. The city should black list it from receiving permits in the future, All questions (S) • Hank Edson (You) 06 5 PM CATO IS NOT OUR COMMUNITY • Hiink Edson (You) S.:> PM My questions (S) 0 )< 1 want to say you have insulted our community with this dishonest forum • Har1k Edson (You) 06 54 PM This not a community conversation. Type your question here ... Exhibit 5: Cato's FOR PROFIT buying spree in Palo Alto. This is a San Francisco- based corporation out-bidding families trying to get into the housing market and in the process driving up housing prices. The public policy behind urban planning is to encourage human beings to root themselves in the urban com- munity through homeownership; it is not to encourage extraction of profits gained by treating our neighborhoods as an investment opportunity. APN Owner Full Name Street City State Zip LastSaleDate LastSalePrice 13707036 Cato Investment Co Lie 2057 Amherst St Palo Alto, CA 94306 11/04/2016 $2,300,00( 13702068 Cato Investment Company Lie 720 College Ave Palo Alto, CA 94306 07/20/2018 $2,300,00( 13705002 Cato Investment Co Lie 2341 Hanover St Palo Alto, CA 94306 10/14/2016 $2,501,00( 13239054 Cato Investment Company Lie 468 Margarita Ave Palo Alto, CA 94306 09/26/2018 $2,880,00( 13708092 Cato Investment Co Lie 523 Matadero Ave Palo Alto, CA 94306 10/02/2019 $12,010,00( 13708091 Cato Investment Co Lie 525 Matadero Ave Palo Alto, CA 94306 10/02/2019 $12,010,00( 13708014 Cato Investment Co Lie 529 Matadero Ave Palo Alto, CA 94306 10/02/2019 $12,010,00( 13733004 Cato Investment Company Lie 2020 Oberlin St Palo Alto, CA 94306 09/11/2017 $2,130,00( 13703015 Cato Investment Company Lie 937 Stanford Ave Palo Alto, CA 94306 05/24/2017 $2,781,00( 13703089 Cato Investment Company Lie 943 Stanford Ave Palo Alto, CA 94306 05/24/2017 $2,781,00( 13701031 Cato Investment Company Lie 2130 Staunton Ct Palo Alto, CA 94306 05/04/2018 $1,825,00( 13702008 Cato Investment Co Lie 2239 Wellesley St Palo Alto, CA 94306 08/14/2019 $2,960,00( 13702007 Cato Investment Co 2241 Wellesley St Palo Alto, CA 94306 01/14/2020 $2,900,00( CATO INVESTMENT COMPANY, LLC Company Number 201603210132 Status Active lncorporaUon Date 29 January 2016 (over 5 years ago) Company Type DOMESTIC JurlsdicUon Galifomia (US) Registered Address 575 MARKET STREET STE 600 SAN FRANCISCO CA94105 United States Agent Name JEFFREY w COLIN Agent Address 575 MARKET STREET STE 600 SAN FRANCISCO CA 94105 Directors/ Officers JEFFREY W COLIN n Registry Page https1/businesssearch.sos.ca.gov/CBS ... Recent filings for CATO INVESTMENT COMPANY, LLC 8 Jan 2020 SI-COMPLETE - 29 Jan 2018 SI-NO CHANGE ....., 22Mar2016 SI-COMPLETE - Company network Nol yet available tor this company. Click to find out more Latest Events • 2016-01-29 • 2018-11.()4 • 2016-01-29 • 2020-08-14 • 2020-08-14 · 2021-01-31 Addition ol officer INCORPORATING SERVICES, LTD, agent Addition ol officer JEFFREY W COLIN, agent Removal of officer INCORPORATING SERVICES, LTD, agent See all events Corporate Grouping @'f-i#ilrl•Pll;Jl=li■13•t None known. t·tiGl·i,IJ,M 4 See an eo<p0rate groupings ~t BAKER STREET ADVISORS ~ lndeptndtnl Custo11uud focwtd. HOME COMPANY APPROACH SERVICES FORM CRS NEWS People Our people make the difference. Baker Street Advisors, LLC has a team of professionals with deep expertise in the fields of investment management, tax and financial planning. Our blend of focused technicol skills and strong inter-personal skills enable us to help our clients in their efforts to successfully address complex financial challenges. Select a name to view bio. Leadership Jeff Colin, Portner Jim Milligan, Portner Michael van den Akker, Partner Chris Wilkens, Portner Heather Pelont, Portner Wendy Umphrey, Partner Jennifer Bonvechio, Portner Adorn T. Elegant, Managing Director Jeff Bordini, Managing Director Madeline Rogers, Senior Vice Presidenl Patrick Burke, Director of Clienl Services Client Service Catherine leM, Director of Special Projects Jeff Colin Portner Monoge'T1enl (ol"'1mi .. ee and ·s the Portner ·n charge of-he fim'"s lnves•rne'l' Strote3y Group JeH began his career advising some of the notion's wee iliest families in 1991. Prior lo his curre'lt role. Jeff served as the Notiono Head of \','eolth F onn·ng for Deuts<:he Bonk. Alex. Brown and was the Managing Director in charge of the =>r· ,ate C 1·en• Division of Robe•tso'l Stephe'ls. He co-lou'ldea the Investment Advisory Services Group of myCFO and woro::ed os o Vice-Pres"dent in the Pr" -'0'e crent Services Jivision of Go dmon Soc'ls FORM ADV UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS Primary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066 Annual Amendment - All Sections Rev. 10/2017 3/30/2020 4:16:32 PM WARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4. Item 1 Identifying Information Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration. A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLC B.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A. BAKER STREET ADVISORS, LLC List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business. (2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser. C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is of your legal name or your primary business name: D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370 (2) If you report to the SEC as an exempt reporting adviser, your SEC file number: (3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information Filed E.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066 If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates. (2) If you have additional CRD Numbers, your additional CRD numbers: No Information Filed F.Principal Office and Place of Business (1)Address (do not use a P.O. Box): Number and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600 City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105 If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year. (2)Days of week that you normally conduct business at your principal office and place of business: Monday - Friday Other: Normal business hours at this location: 8:00 AM - 5:00 PM (3)Telephone number at this location: 415-344-6180 (4)Facsimile number at this location, if any: 415-344-6190 (5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your most recently completed fiscal year? 0 □ □ • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0 G.Mailing address, if different from your principal office and place of business address: Number and Street 1:Number and Street 2: City:State:Country:ZIP+4/Postal Code: If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.: Number and Street 1:Number and Street 2: City:State:Country:ZIP+4/Postal Code: Yes No I.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)? If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the other information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social media platforms. J.Chief Compliance Officer (1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below. Name:Other titles, if any: Telephone number: Facsimile number, if any: Number and Street 1:Number and Street 2: City:State:Country:ZIP+4/Postal Code: Electronic mail (e-mail) address, if Chief Compliance Officer has one: (2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any): Name: IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, you may provide that information here. Name:Titles: Telephone number: Facsimile number, if any: Number and Street 1:Number and Street 2: City:State:Country:ZIP+4/Postal Code: Electronic mail (e-mail) address, if contact person has one: Yes No L.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than your principal office and place of business? If "yes," complete Section 1.L. of Schedule D. Yes No M.Are you registered with a foreign financial regulatory authority? Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes," complete Section 1.M. of Schedule D. Yes No N.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934? Yes No O.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets: $1 billion to less than $10 billion $10 billion to less than $50 billion $50 billion or more □ • • • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shown on the balance sheet for your most recent fiscal year end. P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier. SECTION 1.B. Other Business Names No Information Filed SECTION 1.F. Other Offices No Information Filed SECTION 1.I. Website Addresses List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform. Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/ Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/ Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/ SECTION 1.L. Location of Books and Records Complete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separate Schedule D, Section 1.L. for each location. Name of entity where books and records are kept: BAKER STREET ADVISORS, LLC Number and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600 City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105 If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other. Briefly describe the books and records kept at this location. CLOUD BASED STORAGE SECTION 1.M. Registration with Foreign Financial Regulatory Authorities □ • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information Filed Item 2 SEC Registration/Reporting Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submitting an annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only. A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you may affirmatively respond to each of these items. You (the adviser): (1)are a large advisory firm that either: (a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or (b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registered with the SEC; (2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and you are either: (a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or (b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business; Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority. (3)Reserved (4)have your principal office and place of business outside the United States; (5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940; (6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under management; (7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a); (8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, and your principal office and place of business is the same as the registered adviser; If you check this box, complete Section 2.A.(8) of Schedule D. (9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days; If you check this box, complete Section 2.A.(9) of Schedule D. (10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d); If you check this box, complete Section 2.A.(10) of Schedule D. (11)are an Internet adviser relying on rule 203A-2(e); (12)have received an SEC order exempting you from the prohibition against registration with the SEC; If you check this box, complete Section 2.A.(12) of Schedule D. (13)are no longer eligible to remain registered with the SEC. State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers C. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck the box(es) next to those state(s). Jurisdictions AL AK AZ AR CA CO CT DE DC FL IL IN IA KS KY LA ME MD MA MI NE NV NH NJ NM NY NC ND OH OK SC SD TN TX UT VT VI VA WA WV □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ □ ~ ~ □ □ □ □ ~ ~ □ □ □ ~ □ FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGA GU HI ID ILINIAKSKYLAMEMDMAMIMN MS MO MT NENVNHNJNMNYNCNDOHOKOR PA PR RI SCSDTNTXUTVTVIVAWAWVWI WY If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31). SECTION 2.A.(8) Related Adviser If you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information: Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 Days If you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations. You must make both of these representations: I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within 120 days after the date my registration with the SEC becomes effective. I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Act from registering with the SEC. SECTION 2.A.(10) Multi-State Adviser If you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations: I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the state securities authorities in those states. I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as an investment adviser with the state securities authorities of those states. If you are submitting your annual updating amendment, you must make this representation: Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15 states to register as an investment adviser with the state securities authorities in those states. SECTION 2.A.(12) SEC Exemptive Order If you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information: Application Number: 803- Date of order: Item 3 Form of Organization If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only. A. How are you organized? Corporation Sole Proprietorship Limited Liability Partnership (LLP) Partnership I I, □ □ □ □ D □ □ □ ,____ ______ II 0 _ __J~ _ _JL_ _ _ , _I FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC) Limited Partnership (LP) Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4. B.In what month does your fiscal year end each year? DECEMBER C.Under the laws of what state or country are you organized? State Country Delaware United States If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state or country where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes No A. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g., form of organization or state of incorporation)? If "yes", complete Item 4.B. and Section 4 of Schedule D. B.Date of Succession: (MM/DD/YYYY) If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4. SECTION 4 Successions No Information Filed Item 5 Information About Your Advisory Business - Employees, Clients, and Compensation Responses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1A Instruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5. Employees If you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs more than one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5). A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers. 50 B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)? 11 (2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer? 0 (3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives? 0 (4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for an investment adviser other than you? 0 (5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency? 0 (6)Approximately how many firms or other persons solicit advisory clients on your behalf? 0 • • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf. Clients In your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recently completed fiscal year? 0 (2)Approximately what percentage of your clients are non-United States persons? 0% D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not include businesses organized as sole proprietorships. The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or (d)(3) below. Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item 5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable. Type of Client (1) Number of Client(s) (2) Fewer than 5 Clients (3) Amount of Regulatory Assets under Management (a) Individuals (other than high net worth individuals)$ (b) High net worth individuals 343 $ 9,957,000,000 (c) Banking or thrift institutions $ (d) Investment companies $ (e) Business development companies $ (f) Pooled investment vehicles (other than investment companies and business development companies) $ (g) Pension and profit sharing plans (but not the plan participants or government pension plans) $ (h) Charitable organizations 13 $ 243,000,000 (i) State or municipal government entities (including government pension plans)$ (j) Other investment advisers $ (k) Insurance companies $ (l) Sovereign wealth funds and foreign official institutions $ (m) Corporations or other businesses not listed above $ (n) Other: $ Compensation Arrangements E.You are compensated for your investment advisory services by (check all that apply): (1) A percentage of assets under your management (2)Hourly charges (3)Subscription fees (for a newsletter or periodical) (4)Fixed fees (other than subscription fees) (5)Commissions (6)Performance-based fees (7)Other (specify): Item 5 Information About Your Advisory Business - Regulatory Assets Under Management Regulatory Assets Under Management Yes No F. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts? U.S. Dollar Amount Total Number of Accounts Discretionary:(a)$ 10,200,000,000 (d)4,010 □ □ □ □ □ □ □ □ □ □ □ □ • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0 Total:(c)$ 10,200,000,000 (f)4,010 Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item. (3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United States persons? $ 0 Item 5 Information About Your Advisory Business - Advisory Activities Advisory Activities G. What type(s) of advisory services do you provide? Check all that apply. (1) Financial planning services (2)Portfolio management for individuals and/or small businesses (3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the Investment Company Act of 1940) (4)Portfolio management for pooled investment vehicles (other than investment companies) (5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles) (6)Pension consulting services (7)Selection of other advisers (including private fund managers) (8)Publication of periodicals or newsletters (9)Security ratings or pricing services (10)Market timing services (11)Educational seminars/workshops (12)Other(specify): Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advice in Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year? 0 1 - 10 11 - 25 26 - 50 51 - 100 101 - 250 251 - 500 More than 500 If more than 500, how many? (round to the nearest 500) In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes No I.(1) Do you participate in a wrap fee program? (2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as: (a) sponsor to a wrap fee program $ (b) portfolio manager for a wrap fee program? $ (c) sponsor to and portfolio manager for the same wrap fee program? $ If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program, do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes No J.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments? (2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets under management? □ □ • • • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement? K.Separately Managed Account Clients Yes No (1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)? If yes, complete Section 5.K.(1) of Schedule D. (2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise? If yes, complete Section 5.K.(2) of Schedule D. (3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise? If yes, complete Section 5.K.(2) of Schedule D. (4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of this remaining amount of regulatory assets under management? If yes, complete Section 5.K.(3) of Schedule D for each custodian. SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development Companies No Information Filed SECTION 5.I.(2) Wrap Fee Programs No Information Filed SECTION 5.K.(1) Separately Managed Accounts After subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amount attributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If the remaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months before the end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do not report those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bank instruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventions of your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you report internally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relating to this Section. (a)Asset Type Mid-year End of year (i)Exchange-Traded Equity Securities %% (ii)Non Exchange-Traded Equity Securities %% (iii)U.S. Government/Agency Bonds %% (iv)U.S. State and Local Bonds %% (v)Sovereign Bonds %% (vi)Investment Grade Corporate Bonds %% (vii)Non-Investment Grade Corporate Bonds %% (viii)Derivatives %% (ix)Securities Issued by Registered Investment Companies or Business Development Companies %% (x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%% (xi)Cash and Cash Equivalents %% (xii)Other %% Generally describe any assets included in "Other" • • • • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other" (b)Asset Type End of year (i)Exchange-Traded Equity Securities 20 % (ii)Non Exchange-Traded Equity Securities 0 % (iii)U.S. Government/Agency Bonds 0 % (iv)U.S. State and Local Bonds 0 % (v)Sovereign Bonds 0 % (vi)Investment Grade Corporate Bonds 0 % (vii)Non-Investment Grade Corporate Bonds 0 % (viii)Derivatives 0 % (ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 % (x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 % (xi)Cash and Cash Equivalents 5 % (xii)Other 35 % Generally describe any assets included in "Other" OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATED STOCK POSITIONS. SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand Derivatives No information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2) If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets under management attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b). (a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 with respect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. (i) Mid-Year Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings (3) Derivative Exposures (a) Interest Rate Derivative (b) Foreign Exchange Derivative (c) Credit Derivative (d) Equity Derivative (e) Commodity Derivative (f) Other Derivative Less than 10%$$%%%%%% 10-149%$$%%%%%% 150% or more $$%%%%%% Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. (ii) End of Year Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings (3) Derivative Exposures (a) Interest Rate Derivative (b) Foreign Exchange Derivative (c) Credit Derivative (d) Equity Derivative (e) Commodity Derivative (f) Other Derivative Less than 10%$$%%%%%% I I I I FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%% 150% or more $$%%%%%% Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets under management for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings Less than 10%$$ 10-149%$$ 150% or more $$ Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed Accounts Complete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets under management. (a)Legal name of custodian: CHARLES SCHWAB & CO., INC. (b)Primary business name of custodian: CHARLES SCHWAB & CO., INC. (c)The location(s) of the custodian's office(s) responsible for custody of the assets : City: SAN FRANCISCO State: California Country: United States Yes No (d)Is the custodian a related person of your firm? (e)If the custodian is a broker-dealer, provide its SEC registration number (if any) 8 - 16514 (f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any) (g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian? $ 4,440,000,000 (a)Legal name of custodian: FIDELITY BROKERAGE SERVICES LLC (b)Primary business name of custodian: FIDELITY BROKERAGE SERVICES LLC (c)The location(s) of the custodian's office(s) responsible for custody of the assets : City: BOSTON State: Massachusetts Country: United States Yes No (d)Is the custodian a related person of your firm? • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any) 8 - 23292 (f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any) (g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian? $ 3,600,000,000 Item 6 Other Business Activities In this Item, we request information about your firm's other business activities. A. You are actively engaged in business as a (check all that apply): (1) broker-dealer (registered or unregistered) (2)registered representative of a broker-dealer (3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration) (4)futures commission merchant (5)real estate broker, dealer, or agent (6)insurance broker or agent (7)bank (including a separately identifiable department or division of a bank) (8)trust company (9)registered municipal advisor (10)registered security-based swap dealer (11)major security-based swap participant (12)accountant or accounting firm (13)lawyer or law firm (14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D. Yes No B.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)? (2)If yes, is this other business your primary business? If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name. Yes No (3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name. SECTION 6.A. Names of Your Other Businesses No Information Filed SECTION 6.B.(2) Description of Primary Business Describe your primary business (not your investment advisory business): If you engage in that business under a different name, provide that name: SECTION 6.B.(3) Description of Other Products and Services Describe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS. If you engage in that business under a different name, provide that name: Item 7 Financial Industry Affiliations In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you and your clients. A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and any person that is under common control with you. You have a related person that is a (check all that apply): (1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered) (2)other investment adviser (including financial planners) I I' I I □ □ □ □ □ □ □ □ □ • • _J ' FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor (4)registered security-based swap dealer (5)major security-based swap participant (6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration) (7)futures commission merchant (8)banking or thrift institution (9)trust company (10)accountant or accounting firm (11)lawyer or law firm (12)insurance company or agency (13)pension consultant (14)real estate broker or dealer (15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles (16)sponsor, general partner, managing member (or equivalent) of pooled investment vehicles Note that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. The number of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registered representatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. in Schedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act. SECTION 7.A. Financial Industry Affiliations No Information Filed Item 7 Private Fund Reporting Yes No B.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information Filed SECTION 7.B.(2) Private Fund Reporting No Information Filed Item 8 Participation or Interest in Client Transactions In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occur between you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the next year. Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates. □ □ □ • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor(4)registered security-based swap dealer(5)major security-based swap participant(6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(7)futures commission merchant(8)banking or thrift institution(9)trust company(10)accountant or accounting firm(11)lawyer or law firm(12)insurance company or agency(13)pension consultant(14)real estate broker or dealer(15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles(16)sponsor, general partner, managing member (or equivalent) of pooled investment vehiclesNote that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. Thenumber of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registeredrepresentatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. inSchedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory servicesyou provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related persondoes not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe thatyour relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other thanany mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule206(4)-2 of the Advisers Act.SECTION 7.A. Financial Industry Affiliations No Information FiledItem 7 Private Fund Reporting Yes NoB.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and inInstruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registeredadviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser),do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similardesignation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information FiledSECTION 7.B.(2) Private Fund Reporting No Information FiledItem 8 Participation or Interest in Client TransactionsIn this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occurbetween you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the nextyear.Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.Proprietary Interest in Client Transactions A. Do you or any related person:Yes No (1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)? (2)buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients? (3)recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (other than those mentioned in Items 8.A.(1) or (2))? Sales Interest in Client Transactions B.Do you or any related person:Yes No (1)as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions)? (2)recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any related person serves as underwriter or general or managing partner? (3)recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of sales commissions as a broker or registered representative of a broker-dealer)? Investment or Brokerage Discretion C.Do you or any related person have discretionary authority to determine the:Yes No (1)securities to be bought or sold for a client's account? (2)amount of securities to be bought or sold for a client's account? (3)broker or dealer to be used for a purchase or sale of securities for a client's account? (4)commission rates to be paid to a broker or dealer for a client's securities transactions? D.If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons? E.Do you or any related person recommend brokers or dealers to clients? F.If you answer "yes" to E. above, are any of the brokers or dealers related persons? G.(1)Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") in connection with client securities transactions? (2)If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of the Securities Exchange Act of 1934? H.(1)Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals? (2)Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cash compensation in addition to the employee's regular salary)? I.Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for client referrals? In your response to Item 8.I., do not include the regular salary you pay to an employee. In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answering Item 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. Item 9 Custody In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940) assets and about your custodial practices. A. (1) Do you have custody of any advisory clients':Yes No (a) cash or bank accounts? (b) securities? If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from your clients'accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person. (2)If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody: U.S. Dollar Amount Total Number of Clients (a) $ 3,496,000,000 (b) 237 If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients'accounts, do not include the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provide • • • • • • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor(4)registered security-based swap dealer(5)major security-based swap participant(6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(7)futures commission merchant(8)banking or thrift institution(9)trust company(10)accountant or accounting firm(11)lawyer or law firm(12)insurance company or agency(13)pension consultant(14)real estate broker or dealer(15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles(16)sponsor, general partner, managing member (or equivalent) of pooled investment vehiclesNote that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. Thenumber of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registeredrepresentatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. inSchedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory servicesyou provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related persondoes not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe thatyour relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other thanany mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule206(4)-2 of the Advisers Act.SECTION 7.A. Financial Industry Affiliations No Information FiledItem 7 Private Fund Reporting Yes NoB.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and inInstruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registeredadviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser),do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similardesignation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information FiledSECTION 7.B.(2) Private Fund Reporting No Information FiledItem 8 Participation or Interest in Client TransactionsIn this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occurbetween you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the nextyear.Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.Proprietary Interest in Client TransactionsA. Do you or any related person:Yes No(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?(2)buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?(3)recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (otherthan those mentioned in Items 8.A.(1) or (2))?Sales Interest in Client TransactionsB.Do you or any related person:Yes No(1)as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold toor bought from the brokerage customer (agency cross transactions)?(2)recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any relatedperson serves as underwriter or general or managing partner?(3)recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of salescommissions as a broker or registered representative of a broker-dealer)?Investment or Brokerage DiscretionC.Do you or any related person have discretionary authority to determine the:Yes No(1)securities to be bought or sold for a client's account?(2)amount of securities to be bought or sold for a client's account?(3)broker or dealer to be used for a purchase or sale of securities for a client's account?(4)commission rates to be paid to a broker or dealer for a client's securities transactions?D.If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?E.Do you or any related person recommend brokers or dealers to clients?F.If you answer "yes" to E. above, are any of the brokers or dealers related persons?G.(1)Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") inconnection with client securities transactions?(2)If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of theSecurities Exchange Act of 1934?H.(1)Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?(2)Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cashcompensation in addition to the employee's regular salary)?I.Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for clientreferrals?In your response to Item 8.I., do not include the regular salary you pay to an employee.In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answeringItem 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. Item 9 CustodyIn this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940)assets and about your custodial practices.A. (1) Do you have custody of any advisory clients':Yes No(a) cash or bank accounts?(b) securities?If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from yourclients'accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that youare not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.(2)If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:U.S. Dollar Amount Total Number of Clients(a) $ 3,496,000,000 (b) 237If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients'accounts, do not include the amountof those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provideto clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2). B.(1)In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients':Yes No (a) cash or bank accounts? (b) securities? You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b). (2)If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons have custody: U.S. Dollar Amount Total Number of Clients (a) $ 11,682,000 (b) 13 C.If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply: (1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage. (2)An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to the investors in the pools. (3)An independent public accountant conducts an annual surprise examination of client funds and securities. (4)An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodians for client funds and securities. If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the private funds you advise in Section 7.B.(1) of Schedule D). D.Do you or your related person(s)act as qualified custodians for your clients in connection with advisory services you provide to clients?Yes No (1)you act as a qualified custodian (2)your related person(s)act as qualified custodian(s) If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act. E.If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide the date (MM/YYYY) the examination commenced: 12/2019 F.If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons,act as qualified custodians for your clients in connection with advisory services you provide to clients? 8 SECTION 9.C. Independent Public Accountant You must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled investment vehicle that you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public accountant. (1)Name of the independent public accountant: NAVOLIO & TALLMAN LLP (2)The location of the independent public accountant's office responsible for the services provided: Number and Street 1:Number and Street 2: 201 MISSION STREET SUITE 650 City:State:Country:ZIP+4/Postal Code: SAN FRANCISCO California United States 94105 Yes No (3)Is the independent public accountant registered with the Public Company Accounting Oversight Board? If "yes," Public Company Accounting Oversight Board-Assigned Number: 5442 (4)If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in accordance with its rules? (5)The independent public accountant is engaged to: • • □ • • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor(4)registered security-based swap dealer(5)major security-based swap participant(6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(7)futures commission merchant(8)banking or thrift institution(9)trust company(10)accountant or accounting firm(11)lawyer or law firm(12)insurance company or agency(13)pension consultant(14)real estate broker or dealer(15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles(16)sponsor, general partner, managing member (or equivalent) of pooled investment vehiclesNote that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. Thenumber of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registeredrepresentatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. inSchedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory servicesyou provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related persondoes not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe thatyour relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other thanany mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule206(4)-2 of the Advisers Act.SECTION 7.A. Financial Industry Affiliations No Information FiledItem 7 Private Fund Reporting Yes NoB.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and inInstruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registeredadviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser),do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similardesignation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information FiledSECTION 7.B.(2) Private Fund Reporting No Information FiledItem 8 Participation or Interest in Client TransactionsIn this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occurbetween you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the nextyear.Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.Proprietary Interest in Client TransactionsA. Do you or any related person:Yes No(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?(2)buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?(3)recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (otherthan those mentioned in Items 8.A.(1) or (2))?Sales Interest in Client TransactionsB.Do you or any related person:Yes No(1)as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold toor bought from the brokerage customer (agency cross transactions)?(2)recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any relatedperson serves as underwriter or general or managing partner?(3)recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of salescommissions as a broker or registered representative of a broker-dealer)?Investment or Brokerage DiscretionC.Do you or any related person have discretionary authority to determine the:Yes No(1)securities to be bought or sold for a client's account?(2)amount of securities to be bought or sold for a client's account?(3)broker or dealer to be used for a purchase or sale of securities for a client's account?(4)commission rates to be paid to a broker or dealer for a client's securities transactions?D.If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?E.Do you or any related person recommend brokers or dealers to clients?F.If you answer "yes" to E. above, are any of the brokers or dealers related persons?G.(1)Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") inconnection with client securities transactions?(2)If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of theSecurities Exchange Act of 1934?H.(1)Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?(2)Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cashcompensation in addition to the employee's regular salary)?I.Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for clientreferrals?In your response to Item 8.I., do not include the regular salary you pay to an employee.In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answeringItem 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. Item 9 CustodyIn this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940)assets and about your custodial practices.A. (1) Do you have custody of any advisory clients':Yes No(a) cash or bank accounts?(b) securities?If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from yourclients'accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that youare not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.(2)If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:U.S. Dollar Amount Total Number of Clients(a) $ 3,496,000,000 (b) 237If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients'accounts, do not include the amountof those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provideto clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2).B.(1)In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients':Yes No(a) cash or bank accounts?(b) securities?You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).(2)If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons havecustody:U.S. Dollar Amount Total Number of Clients(a) $ 11,682,000 (b) 13C.If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply:(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.(2)An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to theinvestors in the pools.(3)An independent public accountant conducts an annual surprise examination of client funds and securities.(4)An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodiansfor client funds and securities.If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal controlreport. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the privatefunds you advise in Section 7.B.(1) of Schedule D).D.Do you or your related person(s)act as qualified custodians for your clients in connection with advisory services you provide to clients?Yes No(1)you act as a qualified custodian(2)your related person(s)act as qualified custodian(s)If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must beidentified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act.E.If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide thedate (MM/YYYY) the examination commenced: 12/2019F.If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons,act as qualified custodiansfor your clients in connection with advisory services you provide to clients?8SECTION 9.C. Independent Public AccountantYou must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled investment vehiclethat you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public accountant.(1)Name of the independent public accountant:NAVOLIO & TALLMAN LLP(2)The location of the independent public accountant's office responsible for the services provided:Number and Street 1:Number and Street 2:201 MISSION STREET SUITE 650City:State:Country:ZIP+4/Postal Code:SAN FRANCISCO California United States 94105 Yes No(3)Is the independent public accountant registered with the Public Company Accounting Oversight Board?If "yes," Public Company Accounting Oversight Board-Assigned Number: 5442(4)If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in accordance with itsrules?(5)The independent public accountant is engaged to:A. audit a pooled investment vehicle B. perform a surprise examination of clients' assets C. prepare an internal control report (6)Since your last annual updating amendment, did all of the reports prepared by the independent public accountant that audited the pooled investment vehicle or that examined internal controls contain unqualified opinions? Yes No Report Not Yet Received If you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is available. Item 10 Control Persons In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be provided for the filing adviser only. If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C. Yes No A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies? If yes, complete Section 10.A. of Schedule D. B.If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934, please complete Section 10.B. of Schedule D. SECTION 10.A. Control Persons No Information Filed SECTION 10.B. Control Person Public Reporting Companies B. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934, please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting company): (1)Full legal name of the public reporting company:AFFILIATED MANAGERS GROUP, INC. (2)The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company):1004434 Item 11 Disclosure Information In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an umbrella registration. Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are. If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed. You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11. Yes No Do any of the events below involve you or any of your supervised persons? For "yes" answers to the following questions, complete a Criminal Action DRP: A. In the past ten years, have you or any advisory affiliate:Yes No (1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony? (2)been charged with any felony? • • • • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor(4)registered security-based swap dealer(5)major security-based swap participant(6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(7)futures commission merchant(8)banking or thrift institution(9)trust company(10)accountant or accounting firm(11)lawyer or law firm(12)insurance company or agency(13)pension consultant(14)real estate broker or dealer(15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles(16)sponsor, general partner, managing member (or equivalent) of pooled investment vehiclesNote that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. Thenumber of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registeredrepresentatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. inSchedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory servicesyou provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related persondoes not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe thatyour relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other thanany mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule206(4)-2 of the Advisers Act.SECTION 7.A. Financial Industry Affiliations No Information FiledItem 7 Private Fund Reporting Yes NoB.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and inInstruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registeredadviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser),do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similardesignation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information FiledSECTION 7.B.(2) Private Fund Reporting No Information FiledItem 8 Participation or Interest in Client TransactionsIn this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occurbetween you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the nextyear.Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.Proprietary Interest in Client TransactionsA. Do you or any related person:Yes No(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?(2)buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?(3)recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (otherthan those mentioned in Items 8.A.(1) or (2))?Sales Interest in Client TransactionsB.Do you or any related person:Yes No(1)as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold toor bought from the brokerage customer (agency cross transactions)?(2)recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any relatedperson serves as underwriter or general or managing partner?(3)recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of salescommissions as a broker or registered representative of a broker-dealer)?Investment or Brokerage DiscretionC.Do you or any related person have discretionary authority to determine the:Yes No(1)securities to be bought or sold for a client's account?(2)amount of securities to be bought or sold for a client's account?(3)broker or dealer to be used for a purchase or sale of securities for a client's account?(4)commission rates to be paid to a broker or dealer for a client's securities transactions?D.If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?E.Do you or any related person recommend brokers or dealers to clients?F.If you answer "yes" to E. above, are any of the brokers or dealers related persons?G.(1)Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") inconnection with client securities transactions?(2)If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of theSecurities Exchange Act of 1934?H.(1)Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?(2)Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cashcompensation in addition to the employee's regular salary)?I.Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for clientreferrals?In your response to Item 8.I., do not include the regular salary you pay to an employee.In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answeringItem 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. Item 9 CustodyIn this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940)assets and about your custodial practices.A. (1) Do you have custody of any advisory clients':Yes No(a) cash or bank accounts?(b) securities?If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from yourclients'accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that youare not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.(2)If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:U.S. Dollar Amount Total Number of Clients(a) $ 3,496,000,000 (b) 237If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients'accounts, do not include the amountof those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provideto clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2).B.(1)In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients':Yes No(a) cash or bank accounts?(b) securities?You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).(2)If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons havecustody:U.S. Dollar Amount Total Number of Clients(a) $ 11,682,000 (b) 13C.If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply:(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.(2)An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to theinvestors in the pools.(3)An independent public accountant conducts an annual surprise examination of client funds and securities.(4)An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodiansfor client funds and securities.If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal controlreport. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the privatefunds you advise in Section 7.B.(1) of Schedule D).D.Do you or your related person(s)act as qualified custodians for your clients in connection with advisory services you provide to clients?Yes No(1)you act as a qualified custodian(2)your related person(s)act as qualified custodian(s)If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must beidentified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act.E.If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide thedate (MM/YYYY) the examination commenced: 12/2019F.If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons,act as qualified custodiansfor your clients in connection with advisory services you provide to clients?8SECTION 9.C. Independent Public AccountantYou must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled investment vehiclethat you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public accountant.(1)Name of the independent public accountant:NAVOLIO & TALLMAN LLP(2)The location of the independent public accountant's office responsible for the services provided:Number and Street 1:Number and Street 2:201 MISSION STREET SUITE 650City:State:Country:ZIP+4/Postal Code:SAN FRANCISCO California United States 94105 Yes No(3)Is the independent public accountant registered with the Public Company Accounting Oversight Board?If "yes," Public Company Accounting Oversight Board-Assigned Number: 5442(4)If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in accordance with itsrules?(5)The independent public accountant is engaged to:A. audit a pooled investment vehicleB. perform a surprise examination of clients' assetsC. prepare an internal control report(6)Since your last annual updating amendment, did all of the reports prepared by the independent public accountant that audited the pooled investment vehicle or that examinedinternal controls contain unqualified opinions?YesNoReport Not Yet ReceivedIf you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is available.Item 10 Control PersonsIn this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be provided for the filingadviser only.If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers.Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) thatyou filed with your initial application or report, you must complete Schedule C.Yes NoA. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?If yes, complete Section 10.A. of Schedule D.B.If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please complete Section 10.B. of Schedule D. SECTION 10.A. Control Persons No Information FiledSECTION 10.B. Control Person Public Reporting CompaniesB. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting company):(1)Full legal name of the public reporting company:AFFILIATED MANAGERS GROUP, INC.(2)The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company):1004434Item 11 Disclosure InformationIn this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant yourapplication for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas tofocus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance with General Instruction 5 to Form ADV, "you"and "your" include the filing adviser and all relying advisers under an umbrella registration.Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers,partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiabledepartment or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date ofthe event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of anevent only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the finalorder, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed.You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.Yes NoDo any of the events below involve you or any of your supervised persons?For "yes" answers to the following questions, complete a Criminal Action DRP:A. In the past ten years, have you or any advisory affiliate:Yes No(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?(2)been charged with any felony?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are currently pending. B.In the past ten years, have you or any advisory affiliate: (1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment- related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses? (2)been charged with a misdemeanor listed in Item 11.B.(1)? If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are currently pending. For "yes" answers to the following questions, complete a Regulatory Action DRP: C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever:Yes No (1)found you or any advisory affiliate to have made a false statement or omission? (2)found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes? (3)found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? (4)entered an order against you or any advisory affiliate in connection with investment-related activity? (5)imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity? D.Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: (1)ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical? (2)ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes? (3)ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? (4)in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity? (5)ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity? E.Has any self-regulatory organization or commodities exchange ever: (1)found you or any advisory affiliate to have made a false statement or omission? (2)found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)? (3)found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted? (4)disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities? F.Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended? G.Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.? For "yes" answers to the following questions, complete a Civil Judicial Action DRP: H. (1)Has any domestic or foreign court:Yes No (a)in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity? (b)ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations? (c)ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority? (2)Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)? Item 12 Small Businesses The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you meet the definition of "small business" or "small organization" under rule 0-7. Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state registration, or switching from SEC to state registration. For purposes of this Item 12 only: FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor(4)registered security-based swap dealer(5)major security-based swap participant(6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(7)futures commission merchant(8)banking or thrift institution(9)trust company(10)accountant or accounting firm(11)lawyer or law firm(12)insurance company or agency(13)pension consultant(14)real estate broker or dealer(15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles(16)sponsor, general partner, managing member (or equivalent) of pooled investment vehiclesNote that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. Thenumber of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registeredrepresentatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. inSchedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory servicesyou provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related persondoes not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe thatyour relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other thanany mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule206(4)-2 of the Advisers Act.SECTION 7.A. Financial Industry Affiliations No Information FiledItem 7 Private Fund Reporting Yes NoB.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and inInstruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registeredadviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser),do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similardesignation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information FiledSECTION 7.B.(2) Private Fund Reporting No Information FiledItem 8 Participation or Interest in Client TransactionsIn this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occurbetween you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the nextyear.Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.Proprietary Interest in Client TransactionsA. Do you or any related person:Yes No(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?(2)buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?(3)recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (otherthan those mentioned in Items 8.A.(1) or (2))?Sales Interest in Client TransactionsB.Do you or any related person:Yes No(1)as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold toor bought from the brokerage customer (agency cross transactions)?(2)recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any relatedperson serves as underwriter or general or managing partner?(3)recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of salescommissions as a broker or registered representative of a broker-dealer)?Investment or Brokerage DiscretionC.Do you or any related person have discretionary authority to determine the:Yes No(1)securities to be bought or sold for a client's account?(2)amount of securities to be bought or sold for a client's account?(3)broker or dealer to be used for a purchase or sale of securities for a client's account?(4)commission rates to be paid to a broker or dealer for a client's securities transactions?D.If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?E.Do you or any related person recommend brokers or dealers to clients?F.If you answer "yes" to E. above, are any of the brokers or dealers related persons?G.(1)Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") inconnection with client securities transactions?(2)If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of theSecurities Exchange Act of 1934?H.(1)Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?(2)Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cashcompensation in addition to the employee's regular salary)?I.Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for clientreferrals?In your response to Item 8.I., do not include the regular salary you pay to an employee.In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answeringItem 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. Item 9 CustodyIn this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940)assets and about your custodial practices.A. (1) Do you have custody of any advisory clients':Yes No(a) cash or bank accounts?(b) securities?If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from yourclients'accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that youare not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.(2)If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:U.S. Dollar Amount Total Number of Clients(a) $ 3,496,000,000 (b) 237If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients'accounts, do not include the amountof those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provideto clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2).B.(1)In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients':Yes No(a) cash or bank accounts?(b) securities?You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).(2)If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons havecustody:U.S. Dollar Amount Total Number of Clients(a) $ 11,682,000 (b) 13C.If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply:(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.(2)An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to theinvestors in the pools.(3)An independent public accountant conducts an annual surprise examination of client funds and securities.(4)An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodiansfor client funds and securities.If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal controlreport. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the privatefunds you advise in Section 7.B.(1) of Schedule D).D.Do you or your related person(s)act as qualified custodians for your clients in connection with advisory services you provide to clients?Yes No(1)you act as a qualified custodian(2)your related person(s)act as qualified custodian(s)If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must beidentified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act.E.If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide thedate (MM/YYYY) the examination commenced: 12/2019F.If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons,act as qualified custodiansfor your clients in connection with advisory services you provide to clients?8SECTION 9.C. Independent Public AccountantYou must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled investment vehiclethat you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public accountant.(1)Name of the independent public accountant:NAVOLIO & TALLMAN LLP(2)The location of the independent public accountant's office responsible for the services provided:Number and Street 1:Number and Street 2:201 MISSION STREET SUITE 650City:State:Country:ZIP+4/Postal Code:SAN FRANCISCO California United States 94105 Yes No(3)Is the independent public accountant registered with the Public Company Accounting Oversight Board?If "yes," Public Company Accounting Oversight Board-Assigned Number: 5442(4)If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in accordance with itsrules?(5)The independent public accountant is engaged to:A. audit a pooled investment vehicleB. perform a surprise examination of clients' assetsC. prepare an internal control report(6)Since your last annual updating amendment, did all of the reports prepared by the independent public accountant that audited the pooled investment vehicle or that examinedinternal controls contain unqualified opinions?YesNoReport Not Yet ReceivedIf you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is available.Item 10 Control PersonsIn this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be provided for the filingadviser only.If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers.Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) thatyou filed with your initial application or report, you must complete Schedule C.Yes NoA. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?If yes, complete Section 10.A. of Schedule D.B.If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please complete Section 10.B. of Schedule D. SECTION 10.A. Control Persons No Information FiledSECTION 10.B. Control Person Public Reporting CompaniesB. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting company):(1)Full legal name of the public reporting company:AFFILIATED MANAGERS GROUP, INC.(2)The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company):1004434Item 11 Disclosure InformationIn this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant yourapplication for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas tofocus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance with General Instruction 5 to Form ADV, "you"and "your" include the filing adviser and all relying advisers under an umbrella registration.Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers,partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiabledepartment or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date ofthe event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of anevent only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the finalorder, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed.You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.Yes NoDo any of the events below involve you or any of your supervised persons?For "yes" answers to the following questions, complete a Criminal Action DRP:A. In the past ten years, have you or any advisory affiliate:Yes No(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?(2)been charged with any felony?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are currentlypending.B.In the past ten years, have you or any advisory affiliate:(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy tocommit any of these offenses?(2)been charged with a misdemeanor listed in Item 11.B.(1)?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are currentlypending.For "yes" answers to the following questions, complete a Regulatory Action DRP:C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever:Yes No(1)found you or any advisory affiliate to have made a false statement or omission?(2)found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?(3)found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, orrestricted?(4)entered an order against you or any advisory affiliate in connection with investment-related activity?(5)imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?D.Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:(1)ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?(2)ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?(3)ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended,revoked, or restricted?(4)in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?(5)ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, fromassociating with an investment-related business or restricted your or any advisory affiliate's activity?E.Has any self-regulatory organization or commodities exchange ever:(1)found you or any advisory affiliate to have made a false statement or omission?(2)found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approvedby the SEC)?(3)found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, orrestricted?(4)disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliatefrom association with other members, or otherwise restricting your or the advisory affiliate's activities?F.Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?G.Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?For "yes" answers to the following questions, complete a Civil Judicial Action DRP:H. (1)Has any domestic or foreign court:Yes No(a)in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?(b)ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?(c)ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreignfinancial regulatory authority?(2)Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?Item 12 Small BusinessesThe SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you meet the definition of"small business" or "small organization" under rule 0-7.Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under management of lessthan $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state registration, or switching from SEC tostate registration.For purposes of this Item 12 only:Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that amount is larger). Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the profits, of another person is presumed to control the other person. Yes No A. Did you have total assets of $5 million or more on the last day of your most recent fiscal year? If "yes," you do not need to answer Items 12.B. and 12.C. B.Do you: (1)control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year? (2)control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year? C.Are you: (1)controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year? (2)controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year? Schedule A Direct Owners and Executive Officers 1.Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use Schedule C to amend this information. 2.Direct Owners and Executive Officers. List below the names of: (a)each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions; (b)if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act); Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security. (c)if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or more of your capital; (d)in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 5% or more of your capital, the trust and each trustee; and (e)if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of your capital, and (ii) if managed by elected managers, all elected managers. 3.Do you have any indirect owners to be reported on Schedule B? Yes No 4.In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner or executive officer is an individual. 5.Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued). 6.Ownership codes are:NA - less than 5%B - 10% but less than 25%D - 50% but less than 75% A - 5% but less than 10%C - 25% but less than 50%E - 75% or more 7.(a)In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons. (b)In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act. (c)Complete each column. FULL LEGAL NAME (Individuals: Last Name, First Name, Middle Name) DE/FE/I Title or Status Date Title or Status Acquired MM/YYYY Ownership Code Control Person PR CRD No. If None: S.S. No. and Date of Birth, IRS Tax No. or Employer ID No. COLIN, JEFFREY, WAYNE I MANAGING MEMBER 09/2003 A Y N 2178931 VANDENAKKER, MICHAEL I PARTNER 02/2004 NA Y N 4489629 WILKENS, CHRISTOPHER, JOHN I PARTNER 03/2007 B Y N 2510043 MILLIGAN, JAMES, EDWARD I PARTNER 01/2017 A Y N 1777332 BONVECHIO, JENNIFER, LYNN I SR. VICE PRESIDENT/CCO 01/2014 NA Y N 4369926 WATSON ACQUISITION, LLC DE MANAGER MEMBER 04/2015 D N N 45-1211980 PELANT, HEATHER, LEIGH I PARTNER 01/2020 NA Y N 3042529 UMPHREY, WENDY, ANNE I PARTNER 01/2020 NA Y N 4749938 ELEGANT, ADAM, TREVOR I MANAGING DIRECTOR 11/2019 NA Y N 3078079 Schedule B • • • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor(4)registered security-based swap dealer(5)major security-based swap participant(6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(7)futures commission merchant(8)banking or thrift institution(9)trust company(10)accountant or accounting firm(11)lawyer or law firm(12)insurance company or agency(13)pension consultant(14)real estate broker or dealer(15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles(16)sponsor, general partner, managing member (or equivalent) of pooled investment vehiclesNote that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. Thenumber of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registeredrepresentatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. inSchedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory servicesyou provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related persondoes not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe thatyour relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other thanany mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule206(4)-2 of the Advisers Act.SECTION 7.A. Financial Industry Affiliations No Information FiledItem 7 Private Fund Reporting Yes NoB.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and inInstruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registeredadviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser),do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similardesignation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information FiledSECTION 7.B.(2) Private Fund Reporting No Information FiledItem 8 Participation or Interest in Client TransactionsIn this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occurbetween you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the nextyear.Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.Proprietary Interest in Client TransactionsA. Do you or any related person:Yes No(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?(2)buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?(3)recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (otherthan those mentioned in Items 8.A.(1) or (2))?Sales Interest in Client TransactionsB.Do you or any related person:Yes No(1)as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold toor bought from the brokerage customer (agency cross transactions)?(2)recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any relatedperson serves as underwriter or general or managing partner?(3)recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of salescommissions as a broker or registered representative of a broker-dealer)?Investment or Brokerage DiscretionC.Do you or any related person have discretionary authority to determine the:Yes No(1)securities to be bought or sold for a client's account?(2)amount of securities to be bought or sold for a client's account?(3)broker or dealer to be used for a purchase or sale of securities for a client's account?(4)commission rates to be paid to a broker or dealer for a client's securities transactions?D.If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?E.Do you or any related person recommend brokers or dealers to clients?F.If you answer "yes" to E. above, are any of the brokers or dealers related persons?G.(1)Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") inconnection with client securities transactions?(2)If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of theSecurities Exchange Act of 1934?H.(1)Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?(2)Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cashcompensation in addition to the employee's regular salary)?I.Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for clientreferrals?In your response to Item 8.I., do not include the regular salary you pay to an employee.In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answeringItem 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. Item 9 CustodyIn this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940)assets and about your custodial practices.A. (1) Do you have custody of any advisory clients':Yes No(a) cash or bank accounts?(b) securities?If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from yourclients'accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that youare not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.(2)If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:U.S. Dollar Amount Total Number of Clients(a) $ 3,496,000,000 (b) 237If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients'accounts, do not include the amountof those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provideto clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2).B.(1)In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients':Yes No(a) cash or bank accounts?(b) securities?You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).(2)If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons havecustody:U.S. Dollar Amount Total Number of Clients(a) $ 11,682,000 (b) 13C.If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply:(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.(2)An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to theinvestors in the pools.(3)An independent public accountant conducts an annual surprise examination of client funds and securities.(4)An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodiansfor client funds and securities.If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal controlreport. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the privatefunds you advise in Section 7.B.(1) of Schedule D).D.Do you or your related person(s)act as qualified custodians for your clients in connection with advisory services you provide to clients?Yes No(1)you act as a qualified custodian(2)your related person(s)act as qualified custodian(s)If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must beidentified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act.E.If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide thedate (MM/YYYY) the examination commenced: 12/2019F.If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons,act as qualified custodiansfor your clients in connection with advisory services you provide to clients?8SECTION 9.C. Independent Public AccountantYou must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled investment vehiclethat you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public accountant.(1)Name of the independent public accountant:NAVOLIO & TALLMAN LLP(2)The location of the independent public accountant's office responsible for the services provided:Number and Street 1:Number and Street 2:201 MISSION STREET SUITE 650City:State:Country:ZIP+4/Postal Code:SAN FRANCISCO California United States 94105 Yes No(3)Is the independent public accountant registered with the Public Company Accounting Oversight Board?If "yes," Public Company Accounting Oversight Board-Assigned Number: 5442(4)If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in accordance with itsrules?(5)The independent public accountant is engaged to:A. audit a pooled investment vehicleB. perform a surprise examination of clients' assetsC. prepare an internal control report(6)Since your last annual updating amendment, did all of the reports prepared by the independent public accountant that audited the pooled investment vehicle or that examinedinternal controls contain unqualified opinions?YesNoReport Not Yet ReceivedIf you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is available.Item 10 Control PersonsIn this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be provided for the filingadviser only.If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers.Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) thatyou filed with your initial application or report, you must complete Schedule C.Yes NoA. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?If yes, complete Section 10.A. of Schedule D.B.If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please complete Section 10.B. of Schedule D. SECTION 10.A. Control Persons No Information FiledSECTION 10.B. Control Person Public Reporting CompaniesB. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting company):(1)Full legal name of the public reporting company:AFFILIATED MANAGERS GROUP, INC.(2)The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company):1004434Item 11 Disclosure InformationIn this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant yourapplication for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas tofocus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance with General Instruction 5 to Form ADV, "you"and "your" include the filing adviser and all relying advisers under an umbrella registration.Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers,partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiabledepartment or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date ofthe event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of anevent only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the finalorder, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed.You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.Yes NoDo any of the events below involve you or any of your supervised persons?For "yes" answers to the following questions, complete a Criminal Action DRP:A. In the past ten years, have you or any advisory affiliate:Yes No(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?(2)been charged with any felony?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are currentlypending.B.In the past ten years, have you or any advisory affiliate:(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy tocommit any of these offenses?(2)been charged with a misdemeanor listed in Item 11.B.(1)?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are currentlypending.For "yes" answers to the following questions, complete a Regulatory Action DRP:C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever:Yes No(1)found you or any advisory affiliate to have made a false statement or omission?(2)found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?(3)found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, orrestricted?(4)entered an order against you or any advisory affiliate in connection with investment-related activity?(5)imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?D.Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:(1)ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?(2)ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?(3)ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended,revoked, or restricted?(4)in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?(5)ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, fromassociating with an investment-related business or restricted your or any advisory affiliate's activity?E.Has any self-regulatory organization or commodities exchange ever:(1)found you or any advisory affiliate to have made a false statement or omission?(2)found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approvedby the SEC)?(3)found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, orrestricted?(4)disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliatefrom association with other members, or otherwise restricting your or the advisory affiliate's activities?F.Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?G.Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?For "yes" answers to the following questions, complete a Civil Judicial Action DRP:H. (1)Has any domestic or foreign court:Yes No(a)in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?(b)ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?(c)ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreignfinancial regulatory authority?(2)Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?Item 12 Small BusinessesThe SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you meet the definition of"small business" or "small organization" under rule 0-7.Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under management of lessthan $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state registration, or switching from SEC tostate registration.For purposes of this Item 12 only:Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you may use the totalassets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that amount is larger).Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or otherwise. Anyperson that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the profits, of another person is presumedto control the other person.Yes NoA. Did you have total assets of $5 million or more on the last day of your most recent fiscal year?If "yes," you do not need to answer Items 12.B. and 12.C.B.Do you:(1)control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more onthe last day of its most recent fiscal year?(2)control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year?C.Are you:(1)controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) ofForm ADV) of $25 million or more on the last day of its most recent fiscal year?(2)controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recentfiscal year?Schedule ADirect Owners and Executive Officers1.Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use Schedule C toamend this information.2.Direct Owners and Executive Officers. List below the names of:(a)each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if you areregistered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions;(b)if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public reporting company (acompany subject to Section 12 or 15(d) of the Exchange Act); Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your voting securities.For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling,mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days,through the exercise of any option, warrant, or right to purchase the security.(c)if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or moreof your capital;(d)in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 5% or more of yourcapital, the trust and each trustee; and(e)if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of your capital, and(ii) if managed by elected managers, all elected managers.3.Do you have any indirect owners to be reported on Schedule B? Yes No 4.In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner or executiveofficer is an individual.5.Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and forshareholders or members, the class of securities owned (if more than one is issued).6.Ownership codes are:NA - less than 5%B - 10% but less than 25%D - 50% but less than 75%A - 5% but less than 10%C - 25% but less than 50%E - 75% or more7.(a)In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note thatunder this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.(b)In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.(c)Complete each column.FULL LEGAL NAME (Individuals: Last Name, FirstName, Middle Name)DE/FE/I Title or Status Date Title or StatusAcquired MM/YYYY OwnershipCode ControlPerson PR CRD No. If None: S.S. No. and Date of Birth, IRSTax No. or Employer ID No.COLIN, JEFFREY, WAYNE I MANAGINGMEMBER 09/2003 A Y N 2178931VANDENAKKER, MICHAEL I PARTNER 02/2004 NA Y N 4489629WILKENS, CHRISTOPHER, JOHN I PARTNER 03/2007 B Y N 2510043MILLIGAN, JAMES, EDWARD I PARTNER 01/2017 A Y N 1777332BONVECHIO, JENNIFER, LYNN I SR. VICEPRESIDENT/CCO 01/2014 NA Y N 4369926WATSON ACQUISITION, LLC DE MANAGERMEMBER 04/2015 D N N 45-1211980PELANT, HEATHER, LEIGH I PARTNER 01/2020 NA Y N 3042529UMPHREY, WENDY, ANNE I PARTNER 01/2020 NA Y N 4749938ELEGANT, ADAM, TREVOR I MANAGINGDIRECTOR 11/2019 NA Y N 3078079Schedule BIndirect Owners 1.Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information. 2.Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below: (a)in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 25% or more of a class of a voting security of that corporation; For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security. (b)in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 25% or more of the partnership's capital; (c)in the case of an owner that is a trust, the trust and each trustee; and (d)in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers. 3.Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the Exchange Act) is reached, no further ownership information need be given. 4.In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner is an individual. 5.Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued). 6.Ownership codes are:C - 25% but less than 50%E - 75% or more D - 50% but less than 75%F - Other (general partner, trustee, or elected manager) 7.(a)In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons. (b)In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act. (c)Complete each column. FULL LEGAL NAME (Individuals: Last Name, First Name, Middle Name) DE/FE/I Entity in Which Interest is Owned Status Date Status Acquired MM/YYYY Ownership Code Control Person PR CRD No. If None: S.S. No. and Date of Birth, IRS Tax No. or Employer ID No. AMG WEALTH PARTNERS, LP DE WATSON ACQUISITION, LLC MEMBER 01/2015 E Y N 45-1211980 AMG WP LP HOLDINGS, LLC DE AMG WEALTH PARTNERS, LP LIMITED PARTNER 03/2011 E Y N 46-1924266 AMG WP GP HOLDINGS CORP.DE AMG WEALTH PARTNERS, LP GENERAL PARTNER 12/2011 F Y N 46-0984304 AFFILIATED MANAGERS GROUP, INC.DE AMG WP LP HOLDINGS, LLC SERIES A MEMBER AND MANAGER 03/2011 E Y Y 04-3218510 AFFILIATED MANAGERS GROUP, INC.DE AMG WP GP HOLDINGS CORP. SOLE SHAREHOLDER 12/2011 E Y Y 04-3218510 Schedule D - Miscellaneous You may use the space below to explain a response to an Item or to provide any other information. Item 5.D – Baker Street Advisors, LLC (“Baker Street”) has certain clients who have multiple accounts, including accounts for charities over which they are responsible. In such cases, to avoid double counting when determining the “type of client,” Baker Street has generally designated the type as “High Net Worth Individuals,” as the client’s primary relationship with Baker Street is personal even though the client also has charitable accounts as part of the overall relationship. Item 7.A ­ Affiliated Managers Group, Inc. (“AMG”), a publicly traded company, holds an equity interest in Baker Street through its holding company Watson Acquisition, LLC (“Watson Acquisition”). AMG's equity interest in Baker Street is structured so that Baker Street maintains operational autonomy in managing its business. The relationship between AMG , Watson Acquisition, and Baker Street is defined by an operating agreement that provides that neither AMG nor Watson Acquisition has the authority or the ability to operate or manage Baker Street’s business in the normal course. Accordingly, AMG and Watson Acquisition are not “control persons” of Baker Street. AMG also holds equity interests in certain other investment advisers ("AMG Affiliates"). Each of the AMG Affiliates, including Baker Street, operates autonomously and independently of AMG and of each other. Baker Street does not have any business dealings with these AMG Affiliates and does not conduct any joint operations with them. Baker Street carries out its asset management activity, including the exercise of investment discretion and voting rights, independent of the AMG Affiliates. Except as described in this Form ADV, the AMG Affiliates do not formulate advice for Baker Street's clients. In certain cases, money managers selected by Baker Street may include AMG Affiliates and funds selected by Baker Street may be managed by AMG Affiliates. However, neither AMG nor any AMG Affiliate has any involvement or influence in Baker Street’s selection of money managers. As such, AMG’s ownership interest in Baker Street does not, in Baker Street’s view, present any potential conflict of interest for Baker Street with respect to our clients. Consequently, information about individual AMG Affiliates is not listed in Section 7.A. of Schedule D of Part 1A of Form ADV. A list of all AMG Affiliates is available to Baker Street’s clients upon request. Item 9 - In certain instances, Baker Street is deemed, under federal securities laws, to have custody of certain client accounts by virtue of Baker Street’s specific Partners' roles as trustees to certain accounts, Baker Street’s authority from clients to pay bills from certain accounts, passwords to certain client accounts and/or the existence of standing letters of authorization (“SLOAs”) authorizing Baker Street to direct client assets from certain accounts to client­approved third parties. In such cases, the assets are maintained by independent, unaffiliated qualified custodians and are subject to an annual surprise custody examination in compliance with Rule 206(4)2 under the Investment Advisers Act. Schedule A – The full legal names of all required individuals have been listed in Schedule A. Middle names have been omitted only for individuals who do not have a legal middle name. Schedule R FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor(4)registered security-based swap dealer(5)major security-based swap participant(6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(7)futures commission merchant(8)banking or thrift institution(9)trust company(10)accountant or accounting firm(11)lawyer or law firm(12)insurance company or agency(13)pension consultant(14)real estate broker or dealer(15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles(16)sponsor, general partner, managing member (or equivalent) of pooled investment vehiclesNote that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. Thenumber of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registeredrepresentatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. inSchedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory servicesyou provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related persondoes not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe thatyour relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other thanany mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule206(4)-2 of the Advisers Act.SECTION 7.A. Financial Industry Affiliations No Information FiledItem 7 Private Fund Reporting Yes NoB.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and inInstruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registeredadviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser),do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similardesignation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information FiledSECTION 7.B.(2) Private Fund Reporting No Information FiledItem 8 Participation or Interest in Client TransactionsIn this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occurbetween you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the nextyear.Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.Proprietary Interest in Client TransactionsA. Do you or any related person:Yes No(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?(2)buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?(3)recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (otherthan those mentioned in Items 8.A.(1) or (2))?Sales Interest in Client TransactionsB.Do you or any related person:Yes No(1)as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold toor bought from the brokerage customer (agency cross transactions)?(2)recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any relatedperson serves as underwriter or general or managing partner?(3)recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of salescommissions as a broker or registered representative of a broker-dealer)?Investment or Brokerage DiscretionC.Do you or any related person have discretionary authority to determine the:Yes No(1)securities to be bought or sold for a client's account?(2)amount of securities to be bought or sold for a client's account?(3)broker or dealer to be used for a purchase or sale of securities for a client's account?(4)commission rates to be paid to a broker or dealer for a client's securities transactions?D.If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?E.Do you or any related person recommend brokers or dealers to clients?F.If you answer "yes" to E. above, are any of the brokers or dealers related persons?G.(1)Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") inconnection with client securities transactions?(2)If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of theSecurities Exchange Act of 1934?H.(1)Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?(2)Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cashcompensation in addition to the employee's regular salary)?I.Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for clientreferrals?In your response to Item 8.I., do not include the regular salary you pay to an employee.In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answeringItem 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. Item 9 CustodyIn this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940)assets and about your custodial practices.A. (1) Do you have custody of any advisory clients':Yes No(a) cash or bank accounts?(b) securities?If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from yourclients'accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that youare not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.(2)If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:U.S. Dollar Amount Total Number of Clients(a) $ 3,496,000,000 (b) 237If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients'accounts, do not include the amountof those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provideto clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2).B.(1)In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients':Yes No(a) cash or bank accounts?(b) securities?You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).(2)If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons havecustody:U.S. Dollar Amount Total Number of Clients(a) $ 11,682,000 (b) 13C.If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply:(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.(2)An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to theinvestors in the pools.(3)An independent public accountant conducts an annual surprise examination of client funds and securities.(4)An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodiansfor client funds and securities.If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal controlreport. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the privatefunds you advise in Section 7.B.(1) of Schedule D).D.Do you or your related person(s)act as qualified custodians for your clients in connection with advisory services you provide to clients?Yes No(1)you act as a qualified custodian(2)your related person(s)act as qualified custodian(s)If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must beidentified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act.E.If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide thedate (MM/YYYY) the examination commenced: 12/2019F.If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons,act as qualified custodiansfor your clients in connection with advisory services you provide to clients?8SECTION 9.C. Independent Public AccountantYou must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled investment vehiclethat you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public accountant.(1)Name of the independent public accountant:NAVOLIO & TALLMAN LLP(2)The location of the independent public accountant's office responsible for the services provided:Number and Street 1:Number and Street 2:201 MISSION STREET SUITE 650City:State:Country:ZIP+4/Postal Code:SAN FRANCISCO California United States 94105 Yes No(3)Is the independent public accountant registered with the Public Company Accounting Oversight Board?If "yes," Public Company Accounting Oversight Board-Assigned Number: 5442(4)If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in accordance with itsrules?(5)The independent public accountant is engaged to:A. audit a pooled investment vehicleB. perform a surprise examination of clients' assetsC. prepare an internal control report(6)Since your last annual updating amendment, did all of the reports prepared by the independent public accountant that audited the pooled investment vehicle or that examinedinternal controls contain unqualified opinions?YesNoReport Not Yet ReceivedIf you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is available.Item 10 Control PersonsIn this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be provided for the filingadviser only.If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers.Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) thatyou filed with your initial application or report, you must complete Schedule C.Yes NoA. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?If yes, complete Section 10.A. of Schedule D.B.If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please complete Section 10.B. of Schedule D. SECTION 10.A. Control Persons No Information FiledSECTION 10.B. Control Person Public Reporting CompaniesB. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting company):(1)Full legal name of the public reporting company:AFFILIATED MANAGERS GROUP, INC.(2)The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company):1004434Item 11 Disclosure InformationIn this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant yourapplication for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas tofocus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance with General Instruction 5 to Form ADV, "you"and "your" include the filing adviser and all relying advisers under an umbrella registration.Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers,partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiabledepartment or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date ofthe event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of anevent only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the finalorder, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed.You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.Yes NoDo any of the events below involve you or any of your supervised persons?For "yes" answers to the following questions, complete a Criminal Action DRP:A. In the past ten years, have you or any advisory affiliate:Yes No(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?(2)been charged with any felony?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are currentlypending.B.In the past ten years, have you or any advisory affiliate:(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy tocommit any of these offenses?(2)been charged with a misdemeanor listed in Item 11.B.(1)?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are currentlypending.For "yes" answers to the following questions, complete a Regulatory Action DRP:C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever:Yes No(1)found you or any advisory affiliate to have made a false statement or omission?(2)found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?(3)found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, orrestricted?(4)entered an order against you or any advisory affiliate in connection with investment-related activity?(5)imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?D.Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:(1)ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?(2)ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?(3)ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended,revoked, or restricted?(4)in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?(5)ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, fromassociating with an investment-related business or restricted your or any advisory affiliate's activity?E.Has any self-regulatory organization or commodities exchange ever:(1)found you or any advisory affiliate to have made a false statement or omission?(2)found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approvedby the SEC)?(3)found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, orrestricted?(4)disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliatefrom association with other members, or otherwise restricting your or the advisory affiliate's activities?F.Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?G.Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?For "yes" answers to the following questions, complete a Civil Judicial Action DRP:H. (1)Has any domestic or foreign court:Yes No(a)in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?(b)ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?(c)ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreignfinancial regulatory authority?(2)Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?Item 12 Small BusinessesThe SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you meet the definition of"small business" or "small organization" under rule 0-7.Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under management of lessthan $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state registration, or switching from SEC tostate registration.For purposes of this Item 12 only:Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you may use the totalassets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that amount is larger).Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or otherwise. Anyperson that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the profits, of another person is presumedto control the other person.Yes NoA. Did you have total assets of $5 million or more on the last day of your most recent fiscal year?If "yes," you do not need to answer Items 12.B. and 12.C.B.Do you:(1)control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more onthe last day of its most recent fiscal year?(2)control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year?C.Are you:(1)controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) ofForm ADV) of $25 million or more on the last day of its most recent fiscal year?(2)controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recentfiscal year?Schedule ADirect Owners and Executive Officers1.Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use Schedule C toamend this information.2.Direct Owners and Executive Officers. List below the names of:(a)each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if you areregistered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions;(b)if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public reporting company (acompany subject to Section 12 or 15(d) of the Exchange Act); Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your voting securities.For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling,mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days,through the exercise of any option, warrant, or right to purchase the security.(c)if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or moreof your capital;(d)in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 5% or more of yourcapital, the trust and each trustee; and(e)if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of your capital, and(ii) if managed by elected managers, all elected managers.3.Do you have any indirect owners to be reported on Schedule B? Yes No 4.In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner or executiveofficer is an individual.5.Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and forshareholders or members, the class of securities owned (if more than one is issued).6.Ownership codes are:NA - less than 5%B - 10% but less than 25%D - 50% but less than 75%A - 5% but less than 10%C - 25% but less than 50%E - 75% or more7.(a)In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note thatunder this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.(b)In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.(c)Complete each column.FULL LEGAL NAME (Individuals: Last Name, FirstName, Middle Name)DE/FE/I Title or Status Date Title or StatusAcquired MM/YYYY OwnershipCode ControlPerson PR CRD No. If None: S.S. No. and Date of Birth, IRSTax No. or Employer ID No.COLIN, JEFFREY, WAYNE I MANAGINGMEMBER 09/2003 A Y N 2178931VANDENAKKER, MICHAEL I PARTNER 02/2004 NA Y N 4489629WILKENS, CHRISTOPHER, JOHN I PARTNER 03/2007 B Y N 2510043MILLIGAN, JAMES, EDWARD I PARTNER 01/2017 A Y N 1777332BONVECHIO, JENNIFER, LYNN I SR. VICEPRESIDENT/CCO 01/2014 NA Y N 4369926WATSON ACQUISITION, LLC DE MANAGERMEMBER 04/2015 D N N 45-1211980PELANT, HEATHER, LEIGH I PARTNER 01/2020 NA Y N 3042529UMPHREY, WENDY, ANNE I PARTNER 01/2020 NA Y N 4749938ELEGANT, ADAM, TREVOR I MANAGINGDIRECTOR 11/2019 NA Y N 3078079Schedule BIndirect Owners1.Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first complete Schedule A,which asks for information about your direct owners. Use Schedule C to amend this information.2.Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:(a)in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 25% or more of aclass of a voting security of that corporation; For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling,mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days,through the exercise of any option, warrant, or right to purchase the security.(b)in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed,25% or more of the partnership's capital;(c)in the case of an owner that is a trust, the trust and each trustee; and(d)in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25% or more of theLLC's capital, and (ii) if managed by elected managers, all elected managers.3.Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the Exchange Act) isreached, no further ownership information need be given.4.In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner is anindividual.5.Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members, the class ofsecurities owned (if more than one is issued).6.Ownership codes are:C - 25% but less than 50%E - 75% or moreD - 50% but less than 75%F - Other (general partner, trustee, or elected manager)7.(a)In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Notethat under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.(b)In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.(c)Complete each column.FULL LEGAL NAME (Individuals: LastName, First Name, Middle Name)DE/FE/I Entity in WhichInterest is Owned Status Date StatusAcquiredMM/YYYY OwnershipCode ControlPerson PR CRD No. If None: S.S. No. and Date ofBirth, IRS Tax No. or Employer ID No.AMG WEALTH PARTNERS, LP DE WATSONACQUISITION, LLC MEMBER 01/2015 E Y N 45-1211980AMG WP LP HOLDINGS, LLC DE AMG WEALTHPARTNERS, LP LIMITED PARTNER 03/2011 E Y N 46-1924266AMG WP GP HOLDINGS CORP.DE AMG WEALTHPARTNERS, LP GENERALPARTNER 12/2011 F Y N 46-0984304AFFILIATED MANAGERS GROUP, INC.DE AMG WP LPHOLDINGS, LLC SERIES A MEMBERAND MANAGER 03/2011 E Y Y 04-3218510AFFILIATED MANAGERS GROUP, INC.DE AMG WP GPHOLDINGS CORP.SOLESHAREHOLDER 12/2011 E Y Y 04-3218510Schedule D - MiscellaneousYou may use the space below to explain a response to an Item or to provide any other information.Item 5.D – Baker Street Advisors, LLC (“Baker Street”) has certain clients who have multiple accounts, including accounts for charities over which they are responsible. In such cases,to avoid double counting when determining the “type of client,” Baker Street has generally designated the type as “High Net Worth Individuals,” as the client’s primary relationship withBaker Street is personal even though the client also has charitable accounts as part of the overall relationship. Item 7.A ­ Affiliated Managers Group, Inc. (“AMG”), a publicly tradedcompany, holds an equity interest in Baker Street through its holding company Watson Acquisition, LLC (“Watson Acquisition”). AMG's equity interest in Baker Street is structured sothat Baker Street maintains operational autonomy in managing its business. The relationship between AMG , Watson Acquisition, and Baker Street is defined by an operatingagreement that provides that neither AMG nor Watson Acquisition has the authority or the ability to operate or manage Baker Street’s business in the normal course. Accordingly, AMGand Watson Acquisition are not “control persons” of Baker Street. AMG also holds equity interests in certain other investment advisers ("AMG Affiliates"). Each of the AMG Affiliates,including Baker Street, operates autonomously and independently of AMG and of each other. Baker Street does not have any business dealings with these AMG Affiliates and does notconduct any joint operations with them. Baker Street carries out its asset management activity, including the exercise of investment discretion and voting rights, independent of theAMG Affiliates. Except as described in this Form ADV, the AMG Affiliates do not formulate advice for Baker Street's clients. In certain cases, money managers selected by Baker Streetmay include AMG Affiliates and funds selected by Baker Street may be managed by AMG Affiliates. However, neither AMG nor any AMG Affiliate has any involvement or influence inBaker Street’s selection of money managers. As such, AMG’s ownership interest in Baker Street does not, in Baker Street’s view, present any potential conflict of interest for BakerStreet with respect to our clients. Consequently, information about individual AMG Affiliates is not listed in Section 7.A. of Schedule D of Part 1A of Form ADV. A list of all AMG Affiliatesis available to Baker Street’s clients upon request. Item 9 - In certain instances, Baker Street is deemed, under federal securities laws, to have custody of certain client accounts byvirtue of Baker Street’s specific Partners' roles as trustees to certain accounts, Baker Street’s authority from clients to pay bills from certain accounts, passwords to certain clientaccounts and/or the existence of standing letters of authorization (“SLOAs”) authorizing Baker Street to direct client assets from certain accounts to client­approved third parties. Insuch cases, the assets are maintained by independent, unaffiliated qualified custodians and are subject to an annual surprise custody examination in compliance with Rule 206(4)2under the Investment Advisers Act. Schedule A – The full legal names of all required individuals have been listed in Schedule A. Middle names have been omitted only for individualswho do not have a legal middle name.Schedule R No Information Filed DRP Pages CRIMINAL DISCLOSURE REPORTING PAGE (ADV) No Information Filed REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV) No Information Filed CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV) No Information Filed Part 2 Exemption from brochure delivery requirements for SEC-registered advisers SEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients. If these exemptions excuse you from delivering a brochure to all of your advisory clients, you do not have to prepare a brochure. Yes No Are you exempt from delivering a brochure to all of your clients under these rules? If no, complete the ADV Part 2 filing below. Amend, retire or file new brochures: Brochure ID Brochure Name Brochure Type(s) 323385 BSA ADV PART 2B NOVEMBER 2019 Individuals, High net worth individuals, Pension plans/profit sharing plans, Foundations/charities, Other institutional, Financial Planning Services, Selection of Other Advisers/Solicitors 323386 BSA PART 2A MARCH 2020 High net worth individuals, Pension plans/profit sharing plans, Foundations/charities, Other institutional, Financial Planning Services, Selection of Other Advisers/Solicitors Execution Pages DOMESTIC INVESTMENT ADVISER EXECUTION PAGE You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and all amendments. Appointment of Agent for Service of Process By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing. Signature I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act. I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of these books and records to make them available to federal and state regulatory representatives. Signature: Date: MM/DD/YYYY ] • FORM ADVUNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERSPrimary Business Name:BAKER STREET ADVISORS, LLC CRD Number: 128066Annual Amendment - All Sections Rev. 10/20173/30/2020 4:16:32 PMWARNING:Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You mustkeep this form updated by filing periodic amendments. See Form ADV General Instruction 4.Item 1 Identifying InformationResponses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should beprovided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.A. Your full legal name (if you are a sole proprietor, your last, first, and middle names): BAKER STREET ADVISORS, LLCB.(1) Name under which you primarily conduct your advisory business, if different from Item 1.A.BAKER STREET ADVISORS, LLCList on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box If you check this box, complete a Schedule R for each relying adviser.C.If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is ofyour legal name or your primary business name:D.(1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-62370(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: No Information FiledE.(1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 128066If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.(2) If you have additional CRD Numbers, your additional CRD numbers: No Information FiledF.Principal Office and Place of Business(1)Address (do not use a P.O. Box):Number and Street 1:575 MARKET STREET Number and Street 2:SUITE 600City:SAN FRANCISCO State:California Country:United States ZIP+4/Postal Code:94105If this address is a private residence, check this box: List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying forregistration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or withwhom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, listthe largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year.(2)Days of week that you normally conduct business at your principal office and place of business:Monday - Friday Other:Normal business hours at this location:8:00 AM - 5:00 PM(3)Telephone number at this location:415-344-6180(4)Facsimile number at this location, if any: 415-344-6190(5)What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your mostrecently completed fiscal year? 0G.Mailing address, if different from your principal office and place of business address:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:If this address is a private residence, check this box: H.If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Yes NoI.Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and LinkedIn)?If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a websiteaddress serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the otherinformation. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you donot control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social mediaplatforms.J.Chief Compliance Officer(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your ChiefCompliance Officer, if you have one. If not, you must complete Item 1.K. below.Name:Other titles, if any:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if Chief Compliance Officer has one:(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the InvestmentCompany Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any):Name:IRS Employer Identification Number: K.Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, youmay provide that information here.Name:Titles:Telephone number: Facsimile number, if any:Number and Street 1:Number and Street 2:City:State:Country:ZIP+4/Postal Code:Electronic mail (e-mail) address, if contact person has one:Yes NoL.Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere other than yourprincipal office and place of business?If "yes," complete Section 1.L. of Schedule D.Yes NoM.Are you registered with a foreign financial regulatory authority?Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes,"complete Section 1.M. of Schedule D.Yes NoN.Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?Yes NoO.Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets:$1 billion to less than $10 billion$10 billion to less than $50 billion$50 billion or moreFor purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shownon the balance sheet for your most recent fiscal year end.P.Provide your Legal Entity Identifier if you have one: A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.SECTION 1.B. Other Business Names No Information FiledSECTION 1.F. Other Offices No Information FiledSECTION 1.I. Website AddressesList your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter,Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform.Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.BAKERSTREETADVISORS.COM/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/BAKERSTREETADVISORS/Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BAKER-STREET-ADVISORS/SECTION 1.L. Location of Books and RecordsComplete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separateSchedule D, Section 1.L. for each location.Name of entity where books and records are kept:BAKER STREET ADVISORS, LLCNumber and Street 1: 575 MARKET STREET Number and Street 2: SUITE 600City: SAN FRANCISCO State: California Country: United States ZIP+4/Postal Code: 94105If this address is a private residence, check this box: Telephone Number: 415-344-6184 Facsimile number, if any: This is (check one): one of your branch offices or affiliates. a third-party unaffiliated recordkeeper. other.Briefly describe the books and records kept at this location. CLOUD BASED STORAGESECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information FiledItem 2 SEC Registration/ReportingResponses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submittingan annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only.A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment toyour SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you mayaffirmatively respond to each of these items.You (the adviser):(1)are a large advisory firm that either:(a)has regulatory assets under management of $100 million (in U.S. dollars) or more; or(b)has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registeredwith the SEC;(2)are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and youare either:(a)not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or(b)not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.(3)Reserved(4)have your principal office and place of business outside the United States;(5)are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;(6)are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;(7)are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2(a);(8)are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, andyour principal office and place of business is the same as the registered adviser;If you check this box, complete Section 2.A.(8) of Schedule D.(9)are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;If you check this box, complete Section 2.A.(9) of Schedule D.(10)are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);If you check this box, complete Section 2.A.(10) of Schedule D.(11)are an Internet adviser relying on rule 203A-2(e);(12)have received an SEC order exempting you from the prohibition against registration with the SEC;If you check this box, complete Section 2.A.(12) of Schedule D.(13)are no longer eligible to remain registered with the SEC.State Securities Authority Notice Filings and State Reporting by Exempt Reporting AdvisersC. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. Theseare called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with theSEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit tothe SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this andall subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receivethem, uncheck the box(es) next to those state(s).JurisdictionsALAKAZARCACOCTDEDCFLGAGUHIID ILINIAKSKYLAMEMDMAMIMNMSMOMT NENVNHNJNMNYNCNDOHOKORPAPRRI SCSDTNTXUTVTVIVAWAWVWIWYIf you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing orreport filing fee for the coming year, your amendment must be filed before the end of the year (December 31).SECTION 2.A.(8) Related AdviserIf you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviserthat is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information:Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser - SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 DaysIf you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you arerequired to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.You must make both of these representations:I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within120 days after the date my registration with the SEC becomes effective.I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Actfrom registering with the SEC.SECTION 2.A.(10) Multi-State AdviserIf you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SECregistration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the statesecurities authorities in those states.I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as aninvestment adviser with the state securities authorities of those states.If you are submitting your annual updating amendment, you must make this representation:Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15states to register as an investment adviser with the state securities authorities in those states.SECTION 2.A.(12) SEC Exemptive OrderIf you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:Application Number:803-Date of order:Item 3 Form of OrganizationIf you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.A. How are you organized? CorporationSole ProprietorshipLimited Liability Partnership (LLP)PartnershipLimited Liability Company (LLC)Limited Partnership (LP)Other (specify): If you are changing your response to this Item, see Part 1A Instruction 4.B.In what month does your fiscal year end each year? DECEMBERC.Under the laws of what state or country are you organized? State CountryDelawareUnited StatesIf you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the state orcountry where you reside. If you are changing your response to this Item, see Part 1A Instruction 4. Item 4 Successions Yes NoA. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g.,form of organization or state of incorporation)?If "yes", complete Item 4.B. and Section 4 of Schedule D.B.Date of Succession: (MM/DD/YYYY)If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.SECTION 4 Successions No Information FiledItem 5 Information About Your Advisory Business - Employees, Clients, and CompensationResponses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory policy. Part 1AInstruction 5.a.provides additional guidance to newly formed advisers for completing this Item 5.EmployeesIf you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs morethan one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.50B.(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?11(2)Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?0(3)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?0(4)Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for aninvestment adviser other than you?0(5)Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?0(6)Approximately how many firms or other persons solicit advisory clients on your behalf?0In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.ClientsIn your responses to Items 5.C. and 5.D. do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors.C.(1)To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recentlycompleted fiscal year?0(2)Approximately what percentage of your clients are non-United States persons?0%D.For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not includebusinesses organized as sole proprietorships.The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless youprovide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (d)(1) or(d)(3) below.Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the followingtype of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1). The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registeredinvestment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable.Type of Client (1) Number ofClient(s)(2) Fewer than 5Clients (3) Amount of Regulatory Assets underManagement(a) Individuals (other than high net worth individuals)$(b) High net worth individuals 343 $ 9,957,000,000(c) Banking or thrift institutions $(d) Investment companies $(e) Business development companies $(f) Pooled investment vehicles (other than investment companies and businessdevelopment companies)$(g) Pension and profit sharing plans (but not the plan participants or governmentpension plans)$(h) Charitable organizations 13 $ 243,000,000(i) State or municipal government entities (including government pension plans)$(j) Other investment advisers $(k) Insurance companies $(l) Sovereign wealth funds and foreign official institutions $(m) Corporations or other businesses not listed above $(n) Other: $Compensation ArrangementsE.You are compensated for your investment advisory services by (check all that apply):(1) A percentage of assets under your management(2)Hourly charges(3)Subscription fees (for a newsletter or periodical)(4)Fixed fees (other than subscription fees)(5)Commissions(6)Performance-based fees(7)Other (specify):Item 5 Information About Your Advisory Business - Regulatory Assets Under ManagementRegulatory Assets Under Management Yes NoF. (1)Do you provide continuous and regular supervisory or management services to securities portfolios? (2)If yes, what is the amount of your regulatory assets under management and total number of accounts?U.S. Dollar Amount Total Number of AccountsDiscretionary:(a)$ 10,200,000,000 (d)4,010Non-Discretionary:(b)$ 0 (e)0Total:(c)$ 10,200,000,000 (f)4,010Part 1A Instruction 5.b.explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item.(3)What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non-United Statespersons? $ 0Item 5 Information About Your Advisory Business - Advisory ActivitiesAdvisory ActivitiesG. What type(s) of advisory services do you provide? Check all that apply.(1) Financial planning services(2)Portfolio management for individuals and/or small businesses(3)Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the InvestmentCompany Act of 1940)(4)Portfolio management for pooled investment vehicles (other than investment companies)(5)Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investmentvehicles)(6)Pension consulting services(7)Selection of other advisers (including private fund managers)(8)Publication of periodicals or newsletters(9)Security ratings or pricing services(10)Market timing services(11)Educational seminars/workshops(12)Other(specify):Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment CompanyAct of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advicein Section 5.G.(3) of Schedule D. H.If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?01 - 1011 - 2526 - 5051 - 100101 - 250251 - 500More than 500If more than 500, how many?(round to the nearest 500)In your responses to this Item 5.H., do not include as "clients"the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes NoI.(1) Do you participate in a wrap fee program?(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:(a) sponsor to a wrap fee program$(b) portfolio manager for a wrap fee program? $(c) sponsor to and portfolio manager for the same wrap fee program? $If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b). If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program,do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). Yes NoJ.(1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments?(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets undermanagement?K.Separately Managed Account Clients Yes No(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)?If yes, complete Section 5.K.(1) of Schedule D.(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?If yes, complete Section 5.K.(2) of Schedule D.(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of thisremaining amount of regulatory assets under management?If yes, complete Section 5.K.(3) of Schedule D for each custodian.SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development CompaniesNo Information FiledSECTION 5.I.(2) Wrap Fee Programs No Information FiledSECTION 5.K.(1) Separately Managed AccountsAfter subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amountattributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If theremaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six months beforethe end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do notreport those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bankinstruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventionsof your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you reportinternally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relatingto this Section.(a)Asset Type Mid-year End of year(i)Exchange-Traded Equity Securities %%(ii)Non Exchange-Traded Equity Securities %%(iii)U.S. Government/Agency Bonds %%(iv)U.S. State and Local Bonds %%(v)Sovereign Bonds %%(vi)Investment Grade Corporate Bonds %%(vii)Non-Investment Grade Corporate Bonds %%(viii)Derivatives %%(ix)Securities Issued by Registered Investment Companies or Business Development Companies %%(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)%%(xi)Cash and Cash Equivalents %%(xii)Other %%Generally describe any assets included in "Other"(b)Asset Type End of year(i)Exchange-Traded Equity Securities 20 %(ii)Non Exchange-Traded Equity Securities 0 %(iii)U.S. Government/Agency Bonds 0 %(iv)U.S. State and Local Bonds 0 %(v)Sovereign Bonds 0 %(vi)Investment Grade Corporate Bonds 0 %(vii)Non-Investment Grade Corporate Bonds 0 %(viii)Derivatives 0 %(ix)Securities Issued by Registered Investment Companies or Business Development Companies 14 %(x)Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies)26 %(xi)Cash and Cash Equivalents 5 %(xii)Other 35 %Generally describe any assets included in "Other"OF THE "OTHER" ASSET TYPES, 17% IS ATTRIBUTABLE TO MANAGED FIXED INCOME ACCOUNTS AND THE REMAINING 18% IS ATTRIBUTABLE TO CONCENTRATEDSTOCK POSITIONS.SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand DerivativesNo information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets undermanagement attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b).(a)In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you shouldonly provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under managementfor purposes of your annual updating amendment. Mid-year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalueof all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 withrespect to each category of derivatives specified in 3(a) through (f). You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.(i) Mid-YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (ii) End of YearGross NotionalExposure (1) Regulatory Assets UnderManagement (2)Borrowings (3) Derivative Exposures(a) Interest RateDerivative (b) Foreign ExchangeDerivative (c) CreditDerivative (d) EquityDerivative (e) CommodityDerivative (f) OtherDerivativeLess than 10%$$%%%%%%10-149%$$%%%%%%150% or more $$%%%%%%Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. (b)In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets undermanagement for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to theportion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposesof this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notionalvalue of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) BorrowingsLess than 10%$$10-149%$$150% or more $$Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of theseparately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed AccountsComplete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets undermanagement.(a)Legal name of custodian:CHARLES SCHWAB & CO., INC.(b)Primary business name of custodian:CHARLES SCHWAB & CO., INC.(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:SAN FRANCISCO State:California Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 16514(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 4,440,000,000(a)Legal name of custodian:FIDELITY BROKERAGE SERVICES LLC(b)Primary business name of custodian:FIDELITY BROKERAGE SERVICES LLC(c)The location(s) of the custodian's office(s) responsible for custody of the assets :City:BOSTON State:Massachusetts Country:United States Yes No(d)Is the custodian a related person of your firm?(e)If the custodian is a broker-dealer, provide its SEC registration number (if any)8 - 23292(f)If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)(g)What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?$ 3,600,000,000Item 6 Other Business ActivitiesIn this Item, we request information about your firm's other business activities.A. You are actively engaged in business as a (check all that apply):(1) broker-dealer (registered or unregistered)(2)registered representative of a broker-dealer(3)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(4)futures commission merchant(5)real estate broker, dealer, or agent(6)insurance broker or agent(7)bank (including a separately identifiable department or division of a bank)(8)trust company(9)registered municipal advisor(10)registered security-based swap dealer(11)major security-based swap participant(12)accountant or accounting firm(13)lawyer or law firm(14)other financial product salesperson (specify): If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.Yes NoB.(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?(2)If yes, is this other business your primary business?If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.Yes No(3)Do you sell products or provide services other than investment advice to your advisory clients? If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.SECTION 6.A. Names of Your Other Businesses No Information FiledSECTION 6.B.(2) Description of Primary BusinessDescribe your primary business (not your investment advisory business):If you engage in that business under a different name, provide that name:SECTION 6.B.(3) Description of Other Products and ServicesDescribe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. PREPARE TAX RETURNS; BILL PAY FOR CLIENTS.If you engage in that business under a different name, provide that name:Item 7 Financial Industry AffiliationsIn this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you andyour clients.A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and anypersonthat is under common control with you.You have a related person that is a (check all that apply):(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)(2)other investment adviser (including financial planners)(3)registered municipal advisor(4)registered security-based swap dealer(5)major security-based swap participant(6)commodity pool operator or commodity trading advisor (whether registered or exempt from registration)(7)futures commission merchant(8)banking or thrift institution(9)trust company(10)accountant or accounting firm(11)lawyer or law firm(12)insurance company or agency(13)pension consultant(14)real estate broker or dealer(15)sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles(16)sponsor, general partner, managing member (or equivalent) of pooled investment vehiclesNote that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-dealer. Thenumber of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees who are registeredrepresentatives of a broker-dealer should be disclosed under Item 5.B.(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. inSchedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory servicesyou provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related persondoes not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have no reason to believe thatyour relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other thanany mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent under rule206(4)-2 of the Advisers Act.SECTION 7.A. Financial Industry Affiliations No Information FiledItem 7 Private Fund Reporting Yes NoB.Are you an adviser to any private fund? If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and inInstruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC-registeredadviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser),do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similardesignation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting No Information FiledSECTION 7.B.(2) Private Fund Reporting No Information FiledItem 8 Participation or Interest in Client TransactionsIn this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occurbetween you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the nextyear.Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.Proprietary Interest in Client TransactionsA. Do you or any related person:Yes No(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?(2)buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?(3)recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (otherthan those mentioned in Items 8.A.(1) or (2))?Sales Interest in Client TransactionsB.Do you or any related person:Yes No(1)as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold toor bought from the brokerage customer (agency cross transactions)?(2)recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any relatedperson serves as underwriter or general or managing partner?(3)recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of salescommissions as a broker or registered representative of a broker-dealer)?Investment or Brokerage DiscretionC.Do you or any related person have discretionary authority to determine the:Yes No(1)securities to be bought or sold for a client's account?(2)amount of securities to be bought or sold for a client's account?(3)broker or dealer to be used for a purchase or sale of securities for a client's account?(4)commission rates to be paid to a broker or dealer for a client's securities transactions?D.If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?E.Do you or any related person recommend brokers or dealers to clients?F.If you answer "yes" to E. above, are any of the brokers or dealers related persons?G.(1)Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") inconnection with client securities transactions?(2)If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of theSecurities Exchange Act of 1934?H.(1)Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?(2)Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cashcompensation in addition to the employee's regular salary)?I.Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for clientreferrals?In your response to Item 8.I., do not include the regular salary you pay to an employee.In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answeringItem 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. Item 9 CustodyIn this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940)assets and about your custodial practices.A. (1) Do you have custody of any advisory clients':Yes No(a) cash or bank accounts?(b) securities?If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from yourclients'accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that youare not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.(2)If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:U.S. Dollar Amount Total Number of Clients(a) $ 3,496,000,000 (b) 237If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients'accounts, do not include the amountof those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provideto clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.B.(2).B.(1)In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients':Yes No(a) cash or bank accounts?(b) securities?You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).(2)If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons havecustody:U.S. Dollar Amount Total Number of Clients(a) $ 11,682,000 (b) 13C.If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply:(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.(2)An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to theinvestors in the pools.(3)An independent public accountant conducts an annual surprise examination of client funds and securities.(4)An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodiansfor client funds and securities.If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal controlreport. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the privatefunds you advise in Section 7.B.(1) of Schedule D).D.Do you or your related person(s)act as qualified custodians for your clients in connection with advisory services you provide to clients?Yes No(1)you act as a qualified custodian(2)your related person(s)act as qualified custodian(s)If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must beidentified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act.E.If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide thedate (MM/YYYY) the examination commenced: 12/2019F.If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons,act as qualified custodiansfor your clients in connection with advisory services you provide to clients?8SECTION 9.C. Independent Public AccountantYou must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled investment vehiclethat you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public accountant.(1)Name of the independent public accountant:NAVOLIO & TALLMAN LLP(2)The location of the independent public accountant's office responsible for the services provided:Number and Street 1:Number and Street 2:201 MISSION STREET SUITE 650City:State:Country:ZIP+4/Postal Code:SAN FRANCISCO California United States 94105 Yes No(3)Is the independent public accountant registered with the Public Company Accounting Oversight Board?If "yes," Public Company Accounting Oversight Board-Assigned Number: 5442(4)If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in accordance with itsrules?(5)The independent public accountant is engaged to:A. audit a pooled investment vehicleB. perform a surprise examination of clients' assetsC. prepare an internal control report(6)Since your last annual updating amendment, did all of the reports prepared by the independent public accountant that audited the pooled investment vehicle or that examinedinternal controls contain unqualified opinions?YesNoReport Not Yet ReceivedIf you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is available.Item 10 Control PersonsIn this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be provided for the filingadviser only.If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers.Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) thatyou filed with your initial application or report, you must complete Schedule C.Yes NoA. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?If yes, complete Section 10.A. of Schedule D.B.If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please complete Section 10.B. of Schedule D. SECTION 10.A. Control Persons No Information FiledSECTION 10.B. Control Person Public Reporting CompaniesB. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934,please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting company):(1)Full legal name of the public reporting company:AFFILIATED MANAGERS GROUP, INC.(2)The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company):1004434Item 11 Disclosure InformationIn this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant yourapplication for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas tofocus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance with General Instruction 5 to Form ADV, "you"and "your" include the filing adviser and all relying advisers under an umbrella registration.Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers,partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a "separately identifiabledepartment or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date ofthe event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of anevent only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the finalorder, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed.You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.Yes NoDo any of the events below involve you or any of your supervised persons?For "yes" answers to the following questions, complete a Criminal Action DRP:A. In the past ten years, have you or any advisory affiliate:Yes No(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?(2)been charged with any felony?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that are currentlypending.B.In the past ten years, have you or any advisory affiliate:(1)been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy tocommit any of these offenses?(2)been charged with a misdemeanor listed in Item 11.B.(1)?If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are currentlypending.For "yes" answers to the following questions, complete a Regulatory Action DRP:C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever:Yes No(1)found you or any advisory affiliate to have made a false statement or omission?(2)found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?(3)found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, orrestricted?(4)entered an order against you or any advisory affiliate in connection with investment-related activity?(5)imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?D.Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:(1)ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?(2)ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?(3)ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended,revoked, or restricted?(4)in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?(5)ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, fromassociating with an investment-related business or restricted your or any advisory affiliate's activity?E.Has any self-regulatory organization or commodities exchange ever:(1)found you or any advisory affiliate to have made a false statement or omission?(2)found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approvedby the SEC)?(3)found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, orrestricted?(4)disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliatefrom association with other members, or otherwise restricting your or the advisory affiliate's activities?F.Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?G.Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?For "yes" answers to the following questions, complete a Civil Judicial Action DRP:H. (1)Has any domestic or foreign court:Yes No(a)in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?(b)ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?(c)ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreignfinancial regulatory authority?(2)Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?Item 12 Small BusinessesThe SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you meet the definition of"small business" or "small organization" under rule 0-7.Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under management of lessthan $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state registration, or switching from SEC tostate registration.For purposes of this Item 12 only:Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you may use the totalassets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that amount is larger).Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or otherwise. Anyperson that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the profits, of another person is presumedto control the other person.Yes NoA. Did you have total assets of $5 million or more on the last day of your most recent fiscal year?If "yes," you do not need to answer Items 12.B. and 12.C.B.Do you:(1)control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more onthe last day of its most recent fiscal year?(2)control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year?C.Are you:(1)controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) ofForm ADV) of $25 million or more on the last day of its most recent fiscal year?(2)controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recentfiscal year?Schedule ADirect Owners and Executive Officers1.Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use Schedule C toamend this information.2.Direct Owners and Executive Officers. List below the names of:(a)each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if you areregistered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions;(b)if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public reporting company (acompany subject to Section 12 or 15(d) of the Exchange Act); Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your voting securities.For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling,mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days,through the exercise of any option, warrant, or right to purchase the security.(c)if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or moreof your capital;(d)in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 5% or more of yourcapital, the trust and each trustee; and(e)if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of your capital, and(ii) if managed by elected managers, all elected managers.3.Do you have any indirect owners to be reported on Schedule B? Yes No 4.In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner or executiveofficer is an individual.5.Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and forshareholders or members, the class of securities owned (if more than one is issued).6.Ownership codes are:NA - less than 5%B - 10% but less than 25%D - 50% but less than 75%A - 5% but less than 10%C - 25% but less than 50%E - 75% or more7.(a)In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note thatunder this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.(b)In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.(c)Complete each column.FULL LEGAL NAME (Individuals: Last Name, FirstName, Middle Name)DE/FE/I Title or Status Date Title or StatusAcquired MM/YYYY OwnershipCode ControlPerson PR CRD No. If None: S.S. No. and Date of Birth, IRSTax No. or Employer ID No.COLIN, JEFFREY, WAYNE I MANAGINGMEMBER 09/2003 A Y N 2178931VANDENAKKER, MICHAEL I PARTNER 02/2004 NA Y N 4489629WILKENS, CHRISTOPHER, JOHN I PARTNER 03/2007 B Y N 2510043MILLIGAN, JAMES, EDWARD I PARTNER 01/2017 A Y N 1777332BONVECHIO, JENNIFER, LYNN I SR. VICEPRESIDENT/CCO 01/2014 NA Y N 4369926WATSON ACQUISITION, LLC DE MANAGERMEMBER 04/2015 D N N 45-1211980PELANT, HEATHER, LEIGH I PARTNER 01/2020 NA Y N 3042529UMPHREY, WENDY, ANNE I PARTNER 01/2020 NA Y N 4749938ELEGANT, ADAM, TREVOR I MANAGINGDIRECTOR 11/2019 NA Y N 3078079Schedule BIndirect Owners1.Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first complete Schedule A,which asks for information about your direct owners. Use Schedule C to amend this information.2.Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:(a)in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 25% or more of aclass of a voting security of that corporation; For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling,mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days,through the exercise of any option, warrant, or right to purchase the security.(b)in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed,25% or more of the partnership's capital;(c)in the case of an owner that is a trust, the trust and each trustee; and(d)in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25% or more of theLLC's capital, and (ii) if managed by elected managers, all elected managers.3.Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the Exchange Act) isreached, no further ownership information need be given.4.In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner is anindividual.5.Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members, the class ofsecurities owned (if more than one is issued).6.Ownership codes are:C - 25% but less than 50%E - 75% or moreD - 50% but less than 75%F - Other (general partner, trustee, or elected manager)7.(a)In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Notethat under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.(b)In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.(c)Complete each column.FULL LEGAL NAME (Individuals: LastName, First Name, Middle Name)DE/FE/I Entity in WhichInterest is Owned Status Date StatusAcquiredMM/YYYY OwnershipCode ControlPerson PR CRD No. If None: S.S. No. and Date ofBirth, IRS Tax No. or Employer ID No.AMG WEALTH PARTNERS, LP DE WATSONACQUISITION, LLC MEMBER 01/2015 E Y N 45-1211980AMG WP LP HOLDINGS, LLC DE AMG WEALTHPARTNERS, LP LIMITED PARTNER 03/2011 E Y N 46-1924266AMG WP GP HOLDINGS CORP.DE AMG WEALTHPARTNERS, LP GENERALPARTNER 12/2011 F Y N 46-0984304AFFILIATED MANAGERS GROUP, INC.DE AMG WP LPHOLDINGS, LLC SERIES A MEMBERAND MANAGER 03/2011 E Y Y 04-3218510AFFILIATED MANAGERS GROUP, INC.DE AMG WP GPHOLDINGS CORP.SOLESHAREHOLDER 12/2011 E Y Y 04-3218510Schedule D - MiscellaneousYou may use the space below to explain a response to an Item or to provide any other information.Item 5.D – Baker Street Advisors, LLC (“Baker Street”) has certain clients who have multiple accounts, including accounts for charities over which they are responsible. In such cases,to avoid double counting when determining the “type of client,” Baker Street has generally designated the type as “High Net Worth Individuals,” as the client’s primary relationship withBaker Street is personal even though the client also has charitable accounts as part of the overall relationship. Item 7.A ­ Affiliated Managers Group, Inc. (“AMG”), a publicly tradedcompany, holds an equity interest in Baker Street through its holding company Watson Acquisition, LLC (“Watson Acquisition”). AMG's equity interest in Baker Street is structured sothat Baker Street maintains operational autonomy in managing its business. The relationship between AMG , Watson Acquisition, and Baker Street is defined by an operatingagreement that provides that neither AMG nor Watson Acquisition has the authority or the ability to operate or manage Baker Street’s business in the normal course. Accordingly, AMGand Watson Acquisition are not “control persons” of Baker Street. AMG also holds equity interests in certain other investment advisers ("AMG Affiliates"). Each of the AMG Affiliates,including Baker Street, operates autonomously and independently of AMG and of each other. Baker Street does not have any business dealings with these AMG Affiliates and does notconduct any joint operations with them. Baker Street carries out its asset management activity, including the exercise of investment discretion and voting rights, independent of theAMG Affiliates. Except as described in this Form ADV, the AMG Affiliates do not formulate advice for Baker Street's clients. In certain cases, money managers selected by Baker Streetmay include AMG Affiliates and funds selected by Baker Street may be managed by AMG Affiliates. However, neither AMG nor any AMG Affiliate has any involvement or influence inBaker Street’s selection of money managers. As such, AMG’s ownership interest in Baker Street does not, in Baker Street’s view, present any potential conflict of interest for BakerStreet with respect to our clients. Consequently, information about individual AMG Affiliates is not listed in Section 7.A. of Schedule D of Part 1A of Form ADV. A list of all AMG Affiliatesis available to Baker Street’s clients upon request. Item 9 - In certain instances, Baker Street is deemed, under federal securities laws, to have custody of certain client accounts byvirtue of Baker Street’s specific Partners' roles as trustees to certain accounts, Baker Street’s authority from clients to pay bills from certain accounts, passwords to certain clientaccounts and/or the existence of standing letters of authorization (“SLOAs”) authorizing Baker Street to direct client assets from certain accounts to client­approved third parties. Insuch cases, the assets are maintained by independent, unaffiliated qualified custodians and are subject to an annual surprise custody examination in compliance with Rule 206(4)2under the Investment Advisers Act. Schedule A – The full legal names of all required individuals have been listed in Schedule A. Middle names have been omitted only for individualswho do not have a legal middle name.Schedule R No Information FiledDRP PagesCRIMINAL DISCLOSURE REPORTING PAGE (ADV)No Information FiledREGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)No Information FiledCIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)No Information FiledPart 2Exemption from brochure delivery requirements for SEC-registered advisersSEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients. If these exemptions excuse you from delivering a brochure to all of your advisoryclients, you do not have to prepare a brochure.Yes NoAre you exempt from delivering a brochure to all of your clients under these rules?If no, complete the ADV Part 2 filing below.Amend, retire or file new brochures:Brochure ID Brochure Name Brochure Type(s)323385 BSA ADV PART 2B NOVEMBER 2019 Individuals, High net worth individuals, Pension plans/profitsharing plans, Foundations/charities, Other institutional,Financial Planning Services, Selection of OtherAdvisers/Solicitors323386BSA PART 2A MARCH 2020 High net worth individuals, Pension plans/profit sharing plans,Foundations/charities, Other institutional, Financial PlanningServices, Selection of Other Advisers/SolicitorsExecution PagesDOMESTIC INVESTMENT ADVISER EXECUTION PAGEYou must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and allamendments. Appointment of Agent for Service of ProcessBy signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the state in which youmaintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such personsmay accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree thatsuch service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to thejurisdiction of the United States, if the action, proceeding, or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to thejurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust IndentureAct of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state in which youmaintain your principal office and place of business or of any state in which you are submitting a notice filing.SignatureI, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under penalty of perjury under the lawsof the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I amsigning this Form ADV Execution Page as a free and voluntary act.I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of thesebooks and records to make them available to federal and state regulatory representatives.Signature: JENNIFER BONVECHIO Date: MM/DD/YYYY 03/30/2020 Printed Name: JENNIFER BONVECHIO Title: SENIOR VICE PRESIDENT Adviser CRD Number: 128066 NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and all amendments. 1. Appointment of Agent for Service of Process By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a notice filing. 2. Appointment and Consent: Effect on Partnerships If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this irrevocable power of attorney and consent shall be in effect for any action brought against you or any of your former partners. 3. Non-Resident Investment Adviser Undertaking Regarding Books and Records By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission, correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940. This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of attorney or any of your general partners and managing agents. Signature I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act. I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of these books and records to make them available to federal and state regulatory representatives. Signature: Date: MM/DD/YYYY Printed Name:Title: Adviser CRD Number: 128066 Part 2A of Form ADV The Brochure 575 Market Street, Suite 600 San Francisco, CA 94105 BakerStreetAdvisors.com Updated: March 2020 This brochure provides information about the qualifications and business practices of Baker Street Advisors, LLC (the "Advisor," “We” or “Baker Street”). If you have any questions about the contents of this brochure, please contact us at 415.344.6180. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about the Advisor is also available on the SEC’s website at: www.adviserinfo.sec.gov. BAKER STREET ADVISORS Independent. Customized . Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 2 Table of Contents Material Changes ............................................................................................................................................... 3 Advisory Business .............................................................................................................................................. 4 Fees and Compensation .................................................................................................................................... 5 Performance-Based Fees and Side-by-Side Management ............................................................................... 7 Types of Clients ................................................................................................................................................ 7 Methods of Analysis, Investment Strategies and Risk of Loss .......................................................................... 7 Disciplinary Information ...................................................................................................................................... 9 Other Financial Industry Activities and Affiliations ............................................................................................. 9 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................... 9 Brokerage Practices ......................................................................................................................................... 11 Review of Accounts .......................................................................................................................................... 13 Client Referrals and Other Compensation ....................................................................................................... 13 Custody ............................................................................................................................................................ 13 Investment Discretion ....................................................................................................................................... 14 Voting Client Securities .................................................................................................................................... 14 Financial Information ........................................................................................................................................ 14 BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 3 Material Changes No material changes have been made to Part 2A of the Form ADV. Modifications reflected in this Part 2A of Form ADV were made for Client clarity. The Advisor’s business activities have not changed materially since the time of the update. BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 4 Advisory Business Baker Street provides investment supervisory services primarily on a discretionary basis to a variety of clients. See the “Types of Clients” section for more information with respect to our clients. Services are provided in accordance with Baker Street’s investment advisory agreement and account supervision is guided by the stated investment objectives of the Client (i.e., maximum capital appreciation, growth, etc.). As of December 31, 2019, Baker Street had assets under management of approximately $10.2 billion on behalf of approximately 356 Clients. Principal Ownership Baker Street was founded in 2003. In April 2015, Affiliated Managers Group, Inc. (“AMG”) acquired an equity interest in the Advisor. The remaining equity interests are held by Baker Street’s Partners. AMG, a publicly traded asset management company (NYSE: AMG), also holds equity interests in certain other investment management firms (“AMG Affiliates”). Further information on AMG and the AMG Affiliates is provided in the “Other Financial Industry Activities and Affiliations” section of this Brochure. In connection with the transaction, Baker Street Advisors converted from a California Limited Liability Company (LLC) to a Delaware LLC. Advisory Services As a general matter, the Baker Street does not recommend investing in specific securities. We prepare strategic plans for our Clients by determining our Client’s long-term and short-term financial needs and objectives, risk tolerance or risk-aversion, and tax status. Strategic plans are based on information provided to us by our Clients, financial records, responses to our questionnaires and personal interviews. We design each Client’s investment portfolio based on a thorough evaluation of the individual goals and objectives of the Client. We formulate an investment policy statement and/or asset allocation plan for each Client after analyzing the Client’s financial situation and understanding the Client’s individual investment objectives. The investment objectives, investment restrictions, regulatory restrictions, risk tolerances or other circumstances for each Client are generally documented by the Advisor in an investment policy statement. Following Client approval, Baker Street will implement each aspect of the strategy set forth in the investment policy statement, as appropriate. In connection with the implementation of a Client’s investment policy statement, Baker Street will typically identify unaffiliated independent, third-party investment advisors, mutual funds, or private investment pools, including hedge funds, funds of funds, private equity funds, and other similar investments (collectively “third-party investment managers and funds”) that are believed to be compatible with the Client’s investment objectives, risk tolerances and other Client criteria. As part of the process, we evaluate, select, and oversee these investment managers and funds which we utilize to manage a portion of the Client’s account. We will monitor the investment managers’ and funds’ performance, as well as the various investment markets, to determine if the allocation among these investment options is appropriate or if changes to those options are necessary due to various factors, including changes in macro-economic indicators, interest rates, fiscal policy, geo-political or other factors. Except as noted below in “Other Financial Industry Activities and Affiliations”, the Advisor typically utilizes investment managers and funds which are independent of and unaffiliated with the Advisor when managing Client portfolios. . In directing a portion of a Client’s account to be managed by an investment manager (with the approval of the Client), the investment manager will have full investment discretion and trading authority and shall have sole responsibility for the implementation of the investment program with respect to the assets delegated to the BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 5 investment manager to be managed. In such cases, we will not place orders for transactions in the delegated portion of the Client’s account or otherwise exercise trading authority over the delegated assets at any time when such assets are being managed by the investment manager. If a Client should need cash from the portion of the Client’s account managed by an investment manager, the Advisor will inform the investment manager of the amount needed by the Client, but at no time will we place orders for transactions in the Client’s account where the investment manager has trading authority. Investment managers and funds considered for our Clients will be subjected to a due diligence process. Factors considered will include, but not be limited to: reputation, performance record, philosophy, continuity of management, service to Clients, awareness of after tax performance objectives (as appropriate), minimum dollar investment requirement and fees. Information with respect to investment managers and funds (e.g., performance figures, investment style, etc.) will be obtained from tracking organizations, business publications, investment managers, personal interviews, and other sources which we believe are reliable. We may also consider other criteria, including, but not limited to, the administration, recordkeeping and reporting services provided by a manager or a fund. We may retain outside consultants to assist in preparing investment manager and fund search lists. In the event that we retain an outside consultant, we will make the final determination regarding which investment managers and funds that we will make available to our Clients. In certain cases when managing Client assets, the Advisor may select AMG Affiliates or funds managed by AMG Affiliates. Neither AMG nor any AMG Affiliate has any involvement or influence in the Advisor’s selection of investment managers or funds. As such, AMG’s ownership interest in the Advisor does not, in the Advisor’s view, present any potential conflict of interest for the Advisor with respect to our Clients. The Advisor also provides financial planning services, which may include estate and trust services, risk management and insurance services, philanthropy services, income tax consulting and compliance services, and bill paying services. These services are provided by the Advisor under a separate agreement between the Client and Baker Street. Estate and trust services may require that the Client obtain his or her own independent legal counsel. Baker Street does not provide legal advice or draft legal documents. Fees and Compensation For investment supervisory services, compensation is derived as fee income based upon a percentage of a Client’s assets under management. In each instance, the compensation method is explained and agreed with Clients in advance of any services being rendered. The compensation for our services, which include developing and implementing an investment policy and objectives, monitoring a Client’s investment results, selecting and monitoring investment managers, and reporting to the Client on a quarterly basis, is as follows: Assets Under Management Annual Fee $0 - $4,000,000 0.75%* $4,000,001 - $15,000,000 0.50% $15,000,001 - $25,000,000 0.40% $25,000,001 - $50,000,000 0.30% $50,000,001 - $75,000,000 0.20% BAKER STREET ADVISORS i11dejJende11l. Customized. Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 6 $75,000,001 - $100,000,000 0.10% $100,000,001 - $200,000,000 0.07% $200,000,001 - $500,000,000 0.05% $500,000,001 - $1,000,000,000 0.03% Above $1,000,000,000 0.01% * For amounts less than $4 million, the fee will be 0.75% not to exceed $20,000 annually. This tier does not apply to Clients with more than $4,000,000 under management. Clients that have assets under management of over $4 million dollars will be subject to an annual fee of .50% on the first $15 million of assets under management. Baker Street management fees are for advisory services only and are separate and distinct from third-party investment manager fees which include additional management fees and may include performance-based fees. Clients will also incur any applicable custodial fees, transaction fees and commissions for securities transactions recommended by Baker Street or the investment managers. Clients investing in mutual funds (including money market funds) and exchange-traded funds will typically pay management and/or other fees to each such fund. Those fees are described in each fund’s prospectus. Clients investing in private funds, including hedge funds, private equity funds and funds of funds will incur expenses associated with the pooled investment vehicle, which may include audit, legal, custodial, and other types of fees. Clients investing in private funds should refer to the private placement memorandum or limited partnership agreement for a detailed description of additional expenses incurred. Fees for Clients are billed quarterly in arrears of one fourth of the annual rate based on a percentage of the Client's assets under management at the end of the calendar quarter. Investment advisory services begin with the effective date of the Investment Advisory Agreement, which is the date the Client signs the Investment Advisory Agreement. For that calendar quarter, fees will be adjusted pro-rata, based upon the number of calendar days in the calendar quarter that the Investment Advisory Agreement was effective. Clients that have assets under management of less than $4 million will be subject to an annual fee of .75%, not to exceed $20,000 annually, calculated as described in the previous paragraph. Clients that have assets under management of over $4 million dollars will be subject to an annual fee of .50% on the first $15 million of assets under management. The portfolio value upon which the percentage fee is based will include the current fair market value of all of the Clients’ investments managed by Baker Street. These investments may include mutual funds, exchange traded funds, limited partnerships, fixed and variable annuity accounts, stocks, bonds, and other securities, selected by the investment managers. While the majority of holdings in Client portfolios are readily priced by the Clients’ custodians, certain investments, such as private funds, may require Baker Street to obtain valuations from the fund investment managers, utilize the investment cost, or utilize fair valuation based on estimates received from the investment managers. As such, valuation utilized for the purpose of reporting and fee calculation may differ from that reflected on a Client’s custodial statement. Clients should be aware of their responsibility to verify the accuracy of the fee calculation submitted to their custodians by the Advisor, as the custodian will not determine whether the fee has been properly calculated. As previously described, Baker Street also provides financial planning services, which may include estate and trust services, risk management and insurance services, philanthropy services, income tax consulting and BAKER STREET ADVISORS i11dejJende11l. Customized. Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 7 compliance services, and bill paying services. These services are provided by Baker Street under a separate agreement between the Client and Baker Street. Fees for these services are based on a retainer, hourly rate, or annual fee based on assets under management, as agreed upon between Baker Street and the Client. The Advisor's service may be terminated by either party upon written notification in accordance with the applicable contractual notice of termination. Upon termination, the fees charged for advisory services will be pro-rated. The Client can cancel the Agreement without penalty within the first five days after the signing of the Agreement. Should the Client be invested in a private fund, separate account manager or other vehicle, Baker Street will provide contact information for that investment manager so that the Client can determine with the investment manager if the Client’s funds will be/could be redeemed or if the Client will continue to work with that investment manager or remain invested in the particular investment vehicle. Fees may be negotiated for Clients where specialized investment services are needed or for family members of employees of the Advisor. The Advisor reserves the right to adjust the fee schedule for accounts depending on the size and type of account and the services required. In some cases, negotiation of fees may result in different fees being charged for similar services and may be less than the stated fees. Performance-Based Fees and Side-by-Side Management The Advisor does not charge any performance fees; however, some investment managers or funds recommended by Baker Street may charge performance fees. Types of Clients The Advisor primarily provides investment supervisory services to high-net-worth individuals and associated trusts, estates, pension and profit sharing plans, and other legal entities. The Advisor requires a minimum account size of $5,000,000; however, the Advisor has discretion to waive the account minimum. Methods of Analysis, Investment Strategies and Risk of Loss Baker Street allocates (and/or recommends that the Client allocate) the Client’s investment assets among investment managers and funds in accordance with the Client’s designated investment objectives. In such situations, the investment managers (or, in the case of funds, the fund investment managers managers) shall have day-to-day responsibility for the active discretionary management of the allocated assets. The Advisor will provide the names of the investment managers selected from the investment manager search lists after considering the compatibility of the investment managers’ investment philosophy, minimum investment requirements and other factors with the Client’s investment objectives, risk tolerances and other Client criteria. As a general matter, the Advisor expects that the factors that will be used to determine the names of investment managers and funds to be included on the investment manager and fund search lists will include, but will not necessarily be limited to: reputation, management strength, performance record, philosophy, the continuity of management, service to Clients, minimum dollar investment requirement, and fees. This determination is facilitated through a proprietary quantitative analysis, in-person meetings, and statistical screening prior to the engagement of any investment manager or the selection of any fund. In addition, periodic performance and logistical updates are conducted in order to confirm that the investment manager or fund continues to fulfill a Client’s mandate and goals. BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 8 Although the investment managers and/or fund investment managers shall have day-to-day responsibility for the active discretionary management of our Clients’ allocated assets, Baker Street shall continue to render investment advisory services to each Client relative to the ongoing monitoring and review of account performance, asset allocation and Client investment objectives. Investment Manager Risk: All investing involves risk of loss and the investment strategy offered by Baker Street could lose money over short or even long periods. Additionally, Baker Street relies on the investment expertise and day-to-day management of investments to selected investment managers, subjecting Clients to manager risk. The investment performance of each Client’s portfolio is affected by the investment performance of the underlying securities in which the portfolio invests, as selected by the investment managers. The ability of the portfolio to achieve its investment objective depends on the ability of the underlying securities to meet the Client’s investment objectives and the allocation of the portfolio’s assets among the underlying securities. There can be no assurance that the investment objective of each Client account or any underlying securities will be achieved. Through its investments in underlying securities, as selected by investment managers, each Client’s account is subject to the risks of the underlying securities’ investments and can experience losses. Certain risks of the underlying securities’ investments are described below. Market Risk: Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities, and the funds that own them, to rise or fall. Because the value of Client’s investments will fluctuate, there is the risk that the Client will lose money. Investing in securities is inherently risky: An investment in individual securities or in a portfolio of securities could lose money. The individual investments selected by Baker Street and the investment managers should be deemed speculative investments and are not intended as a complete investment program. The Advisor cannot give any guarantee that any Client will achieve the Client’s investment objectives or that any Client will receive a return of the Client’s investment. Generation of multiple levels of fees and expenses: By investing with investment managers and funds, Clients bear Baker Street fees as well as investment manager and fund fees and, in some instances, expenses. Thus, Baker Street Clients may be subject to higher fees than if the Client invested with an investment manager or in a fund directly. In addition, certain of the private funds may be subject to a performance-based fee or allocation, irrespective of the performance of other portfolio funds. Generally, fees payable to private funds’ investment managers will range from 0.625% to 3.25% (per annum). In addition, certain investment managers to private funds charge an incentive allocation or fee generally ranging from 10% to 25% of a private fund’s net profits or realized return. The performance-based compensation received by an investment manager to a private fund may also create an incentive for that investment manager to make investments that are riskier or more speculative than those it might have made in the absence of the performance-based allocation. Such compensation may be based on calculations of realized and unrealized gains made by the Advisor without independent oversight. Each portfolio fund invests independently: Each investment manager and fund will generally invest completely independently of one another and may at times hold economically offsetting positions. To the extent that investment managers and funds hold such positions, Client accounts may not achieve any gain or loss despite incurring fees and expenses in connection with such positions. In performing its services, Baker Street shall not be required to verify any information received from the Client or from the Client’s other professionals and is expressly authorized to rely on such information. Moreover, BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 9 each Client is advised that the Client retains his/her/its responsibility to promptly notify Baker Street if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Baker Street’s previous recommendations and/or services. Cybersecurity Risk: With the increased use of technologies to conduct business, Baker Street is susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyber incidents impacting Baker Street have the ability to cause disruptions and impact business operations, potentially resulting in the inability to transact business, financial losses, violations of applicable privacy and other laws, regulatory fines, penalties or reputational damage. While Baker Street has established a business continuity plan and risk management systems intended to identify and mitigate the risks associated with cyber-attacks, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. Furthermore, Baker Street cannot control the cybersecurity plans and systems put in place by third-party service providers, including recommended investment managers and issuers in which client portfolios invest. Clients could be negatively impacted as a result. Disciplinary Information The Advisor and its employees have not been involved in any legal or disciplinary events in the past 10 years that would be material to a Client’s evaluation of the company or its personnel. Other Financial Industry Activities and Affiliations As noted in “Principal Ownership” above, AMG holds an equity interest in the Advisor. AMG’s equity interest in the Advisor is structured so that the Advisor maintains operational autonomy in managing its business. AMG does not have any role in the day-to-day management of the Advisor. AMG also holds equity interests in certain other investment managers, the AMG Affiliates. In certain cases, the Advisor may select investment managers that are AMG Affiliates to manage Client assets, or may invest Client assets in funds managed by AMG Affiliates. Each of the AMG Affiliates, including the Advisor, operates autonomously and independently of AMG and of each other. The Advisor’s selection of investment managers does not include any involvement or influence from AMG or any AMG Affiliate. As such, AMG’s ownership interest in the Advisor does not, in the Advisor’s view, present any potential conflict of interest for the Advisor’s selection of investment managers or otherwise with respect to our clients. More information regarding AMG, including its public filings and a list of all AMG Affiliates is available at www.amg.com or upon the Advisor’s Clients upon request. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading The Advisor, its Partners and employees may, on a limited basis, buy or sell, for their personal accounts the same securities that may be recommended to Clients. To avoid any potential conflicts of interest involving personal trades, the Advisor has adopted a formal code of ethics (the “Code”) which includes personal securities transactions and insider trading policies and procedures. The Advisor’s Code requires, among other things, that employees: BAKER STREET ADVISORS i11dejJende11l. Customized. Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 10 • Act with integrity, competence, diligence, respect, and in an ethical manner with the public, Clients, prospective Clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets; • Place the integrity of the investment profession, the interests of Clients, and the interests of the Advisor above one’s own personal interests; • Adhere to the fundamental standard that you should not take inappropriate advantage of your position; • Avoid any actual or potential conflict of interest; • Conduct all personal securities transactions in a manner consistent with this policy; • Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities; • Practice and encourage others to act in a professional and ethical manner that will reflect positively on yourself and the profession; • Promote the integrity of, and uphold the rules governing, capital markets; • Maintain and improve your professional competence and strive to maintain and improve the competence of other investment professionals; and • Comply with applicable provisions of the federal securities laws. Baker Street’s Securities Compliance Policy requires employees to: 1) pre-clear certain personal securities transactions, 2) report personal securities transactions on at least a quarterly basis, and 3) provide the Advisor with a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such employees have a direct or indirect beneficial interest. All employees of the Advisor are also subject to the AMG Insider Trading Policy and Procedures (the “AMG Insider Trading Policy”). The AMG Insider Trading Policy broadly prohibits the use of material, non-public information, and also imposes restrictions on the trading of AMG’s stock. In addition, the Advisor’s Code of Ethics also includes policies and procedures prohibiting the use of material non-public information that are designed to prevent insider trading by an officer or employee of the Advisor. In the normal course of business, Baker Street is an allocator of Client funds to investment managers and funds. In certain circumstances, however, Baker Street and/or representatives of Baker Street may buy or sell securities that are also recommended to Clients. This practice may create a situation where Baker Street and/or representatives of Baker Street are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. Baker Street has established procedures intended to limit conflicts of interest in cases where Baker Street is a related person, or any of its employees buys or sells securities recommended by Baker Street to its Clients. These procedures include the obligation to pre-clear transactions in private placements (which include interests in private investment funds) through Baker Street’s Chief Compliance Officer and a quarterly review of investment activity within the personal accounts of Baker Street Partners and employees. BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 11 Baker Street utilizes an Advisory Committee which consults on Baker Street’s model portfolios and asset allocation. In certain instances, Baker Street recommends Clients invest with investment managers whose employees serve as members of the Advisory Committee. Baker Street’s relationship with investment managers that serve as Advisory Committee members creates a potential conflict of interest. As Baker Street receives consulting services from the Advisory Committee members, it benefits from the relationship with the investment managers. A copy of the Advisor’s Code shall be provided to any Client or prospective Client upon request. Brokerage Practices When a Client agrees to discretionary management, Baker Street will be responsible for asset allocation and selecting investment managers and funds. The only limitations on our investment authority will be those limitations imposed in writing by the Client. We may recommend that the Client retain an investment manager directly. In those cases, the Client will engage the investment manager directly, and the Advisor will not be a party to that agreement. The Client will retain discretion to engage or disengage the investment manager. The Advisor will charge the Client an advisory fee for the assets managed by the investment manager. Clients should review the disclosure document(s) of the investment managers we recommend to manage their assets for more information on their policies with regard to investment or brokerage discretion. In the course of providing our services, the investment managers we recommend to manage a portion of the Client’s assets will execute trades through broker-dealers. We expect our investment managers to trade through broker- dealers who offer the best overall execution under the particular circumstances. The Advisor will not place orders for transactions in the Client’s account or otherwise exercise trading authority over the Account at any time when a third party investment manager has trading authority over the Account. Absent an existing brokerage relationship, the Advisor will assist the Client with developing a relationship with brokers that the Advisor has a relationship with, which include: Fidelity Institutional (“Fidelity”) and Charles Schwab & Co. (“Schwab”). Baker Street may recommend that a Client establish brokerage accounts with Schwab or Fidelity to maintain custody of the Client’s assets and to effect trades for the account(s). The Advisor will make recommendations based on the needs of the Client and the services provided by the broker/custodian such as the ability to execute trades, margin rates, on-line access to accounts, transaction charges, consolidated reporting, duplicate monthly statements, access to mutual funds, including lower sales charges than for direct purchases and lower minimum purchase amounts. Baker Street has no affiliation with Schwab or Fidelity and receives no monetary remuneration from Schwab or Fidelity, either directly or indirectly. However, Schwab and Fidelity may provide services of value to our Clients and Baker Street; these are described in more detail below. As part of the programs offered by Fidelity and Schwab, the Advisor receives benefits that it would not receive if it did not provide investment advice to Clients. While there is no direct affiliation or fee sharing arrangement between Fidelity, Schwab and the Advisor, economic benefits are received by the Advisor which would not be received if the Advisor did not have an established relationship with Fidelity and Schwab. These benefits do not depend on the amount of transactions directed by the Advisor to Fidelity or Schwab. These benefits may include: a dedicated trading desk that services the Advisor’s Clients, a dedicated service group and an account services manager dedicated to the Advisor’s accounts, access to a real time order matching system, ability to block Client trades, electronic download of trades, portfolio management software, access to an electronic BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 12 interface, duplicate and batched Client statements, confirmations and year-end summaries, the ability to have advisory fees directly debited from Client accounts (in accordance with federal and state requirements), a quarterly newsletter, access to mutual funds, ability to have loads waived for the Advisor’s Clients who invest in certain loaded funds when certain conditions are met and maintained, and the ability to have custody fees waived. Schwab or Fidelity may provide Baker Street with information and services intended to help Baker Street manage and further develop our business enterprise. Schwab or Fidelity may provide these services themselves or may arrange for third parties to provide the services. These services may include educational conferences and events; consulting on various topics such as information technology, compliance, strategic, legal, and business needs; presentations, consulting, publications and conferences on various topics such as regulatory compliance, practice management, human capital, and business succession; support, including financial assistance with mailing packages; and access to employee benefits providers, human capital consultants, and insurance providers. The term “soft dollars” refers to a means of paying brokerage firms for products and services through commission revenue, based on the volume of brokerage commission revenues generated from securities transactions executed through brokers by an investment manager on behalf of advisory Clients. Section 28(e) of the Securities Exchange Act of 1934, as amended, allows Baker Street to pay broker-dealers more than the lowest commission available in order to obtain research and brokerage services without breaching its fiduciary duties to Clients or imposing a duty upon Baker Street to obtain the lowest commission if certain conditions are met and Baker Street makes a good faith determination that the commissions paid are reasonable in relation to the value of the brokerage or research services on behalf of its advisory Clients. In determining if something is research, thus falling within the safe harbor provisions, the controlling principle is whether it provides lawful and appropriate assistance to the investment manager in the performance of its investment decision-making responsibilities. Baker Street currently does not maintain formal soft dollar agreements with Schwab nor Fidelity. However, Schwab and Fidelity provide Baker Street with proprietary research. Baker Street has determined that it would obtain this service regardless of the amount of commissions it generates at Schwab and Fidelity throughout the year. Therefore, Baker Street may not be “paying-up” for proprietary research. Research services received from Schwab and Fidelity are supplemental to Baker Street’s own research efforts, and, when utilized, are subject to internal analysis before being incorporated by Baker Street into its investment process. As a practical matter, it would not be possible for Baker Street to generate all of the information presently provided by broker-dealers. Baker Street may pay cash for certain research services received from external sources and also allocate brokerage for research services, which are available for cash. While the receipt of research services from brokerage firms has not reduced Baker Street’s normal research activities, the expenses of Baker Street could be materially increased if it attempted to generate such additional information through its own staff. To the extent that broker-dealers provide research services of value, Baker Street is relieved of expenses, which it may otherwise bear. In addition, Baker Street has an incentive to select a broker-dealer based on its interest in receiving research or other products or services, rather than Client’s interests in receiving lower transaction costs. The availability to Baker Street of the foregoing products and services is not contingent upon Baker Street committing to Schwab or Fidelity any specific future amount of business (assets in custody or trading) or upon Baker Street giving any particular investment advice. However, the terms of any alternative pricing that may apply to Baker Street or our Clients may be based upon the nature and scope of business that Baker Street transacts with Schwab or Fidelity. BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 13 Trade Error From time to time, Baker Street may make an error in submitting a trade order on a Client’s behalf. When this occurs, Baker Street may place a correcting trade with the broker-dealer which has custody of the Client’s account. For the purpose of reconciling trade errors, Baker Street will keep a trade error account with each custodian. If the trade error results in a debit balance, this amount will be resolved immediately. At Schwab, if the trade error results in a credit balance, the amount can either be withdrawn or remain in the account; money market rates may be paid on credit balances. At Fidelity, effective March 1, 2016, if the trade error results in a credit balance, the amount will remain in the account for one month and can be netted against any debit balances. At the end of each month, any credit balance will be donated to charity. Review of Accounts All Client accounts are reviewed at least quarterly to ensure that an appropriate allocation is in place based on Baker Street’s assessments of market conditions and the circumstances of the Client. Baker Street will provide more frequent reviews as appropriate and as agreed with the Client. General conditions in the stock and bond markets are continuously monitored. Factors triggering reviews, and perhaps triggering buy or sell recommendations of funds or changes in investment managers, include changed circumstances of the Clients, changed general conditions in the stock and bond markets, and changes in management of investment managers. All accounts are reviewed by one of the Partners. There is no set minimum or maximum in place with regard to the number of accounts that each Partner will review. Clients are kept informed about their portfolio activity by receiving copies of transaction confirmations and monthly or quarterly statements from brokerage firms, mutual fund companies, or the custodian. Clients also receive quarterly reports prepared by the Advisor with their quarterly billing statements. The quarterly reports provided by the Advisor may vary from statements provided by brokerage firms, mutual fund companies or custodial statements based on accounting procedures, reporting dates, and/or valuation methodologies of certain securities. Client Referrals and Other Compensation The Advisor does not directly or indirectly compensate any person, other than employees, for Client referrals. Custody Baker Street does not directly or indirectly hold Clients’ funds or securities and does not have the authority to obtain possession of Clients’ funds or securities. All Clients’ accounts are held in custody by unaffiliated broker/dealers or banks, but the Advisor can access many Clients’ accounts through its ability to debit advisory fees. For this reason the Advisor is considered to have custody of Client assets. Account custodians send statements directly to the account owners on at least a quarterly basis. Clients should carefully review these statements, and should compare these statements to any account information provided by the Advisor. In certain instances, Baker Street is deemed, under federal securities laws, to have custody of certain client accounts by virtue of Baker Street’s specific Partners’ roles as trustees to certain accounts, Baker Street’s authority from clients to pay bills from certain accounts, and password access to certain client accounts. In BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 14 such cases, the assets are maintained by independent, unaffiliated qualified custodians and are subject to an annual surprise custody examination in compliance with Rule 206(4)2 under the Investment Advisers Act. Baker Street is also deemed, under federal securities laws, to have custody of certain client accounts based on the existence of standing letters of authorization (“SLOAs”) authorizing Baker Street to direct client assets from certain accounts to client-approved third parties. In such cases, the assets are maintained by independent, unaffiliated qualified custodians. In lieu of an annual custody examination, Baker Street meets certain prescribed regulatory requirements with respect to such accounts. Clients should be aware of their responsibility to verify the accuracy of the fee calculation submitted to the custodian by the Advisor, as the custodian will not determine whether the fee has been properly calculated. Investment Discretion Baker Street provides investment supervisory services on a discretionary or non-discretionary basis as stated in the investment advisory agreement. When a Client agrees to discretionary management, we will be responsible for asset allocation and selecting investment managers and funds. The Advisory Agreement between the Client’s and Baker Street allows the Advisor Limited Power of Attorney (“LPOA”) authority for discretionary and non-discretionary accounts. This LPOA grants Baker Street only trading and limited funds and fee disbursement authority. Other limitations, including investment restrictions, are those imposed in writing by the Client. Voting Client Securities The Advisor will not vote (by proxy or otherwise) in any matter for which a shareholder vote is solicited by, or with respect to, issuers of securities beneficially held in the Client’s account. With regard to all other matters for which shareholder action is required or solicited with respect to securities beneficially held by the Client’s account such as (i) all matters relating to class actions, including without limitation, matters relating to opting in or opting out of a class and approval of class settlements and (ii) bankruptcies or reorganizations, the Advisor affirmatively disclaims responsibility for voting (by proxies or otherwise) on such matters and will not take any action with regard to such matters. Financial Information The Advisor has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage Client accounts. BAKER STREET ADVISORS !11dl'/Jendr11t C11sto111i .rd. Forn11·d. Part 2B of Form ADV The Brochure Supplement 575 Market Street, Suite 600 San Francisco, CA 94105 BakerStreetAdvisors.com Updated: November 2019 This brochure supplement provides information about Jeffrey W. Colin, Adam T. Elegant, James E. Milligan, Heather L. Pelant, Wendy A. Umphrey, Michael van den Akker, and Christopher J. Wilkens. It supplements the Advisor’s accompanying Form ADV brochure. Please contact the Advisor’s Chief Compliance Officer at 415.344.6184 if you have any questions about the Form ADV brochure or this supplement, or if you would like to request additional or updated copies of either document. BAKER STREET ADVISORS Independent. Customized. Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 2 Table of Contents Jeffrey W. Colin’s Biographical Information 3 Adam T. Elegant’s Biographical Information 4 James E. Milligan’s Biographical Information 5 Heather L. Pelant’s Biographical Information 6 Wendy A. Umphrey’s Biographical Information 7 Michael van den Akker’s Biographical Information 8 Christopher J. Wilkens’s Biographical Information 9 BAKER STREET ADVISORS i ndependent. Customized . Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 3 Completion of college level study or its equivalent is generally required of the Advisor's representatives. Additionally, a thorough knowledge of economic and financial principles, modern portfolio theory, optimization techniques as well as their application must be demonstrated. This knowledge may be acquired via business experience, education, and passage of securities examinations, attainment of professional designations or a combination thereof. Jeffrey W. Colin’s Biographical Information Educational Background and Business Experience Year of Birth: 1963 Formal Education after High School: Northwestern University – BS, 1985 J.L. Kellogg Graduate School of Management – MBA, 1991 Business Background for the Preceding Five Years: October 2003 to Present Partner, Baker Street Advisors, LLC December 2002 to August 2003 Managing Director, Deutsche Bank Alex Brown May 2001 to October 2002 Managing Director, Robertson Stephens February 2000 to May 2001 Managing Director, myCFO, Inc. August 1991 to February 2000 Vice President, Goldman Sachs Disciplinary Information Mr. Colin has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Colin or of the Advisor. Other Business Activities Mr. Colin is not engaged in any other investment related business, and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Colin does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all of the Baker Street Partners and Managing Directors, Jordan Kienzle - Investment Strategy Group Vice BAKER STREET ADVISORS i ndependent. Customized . Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 4 President and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. Adam T. Elegant’s Biographical Information Educational Background and Business Experience Year of Birth: 1973 Formal Education after High School: Washington University in St. Louis – Political Science, 1995 University of Colorado, Leeds School of Business – MBA, 1999 Business Background for the Preceding Five Years: November 2019 to Present Managing Director, Baker Street Advisors, LLC April 2014 to November 2019 Director, KKR & Co. Inc. April 2013 to March 2014 Vice President, Northern Trust August 1999 to April 2013 Vice President, Goldman Sachs Disciplinary Information Mr. Elegant has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Elegant or of the Advisor. Other Business Activities Mr. Elegant is not engaged in any other investment related business, and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Elegant does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all of the Baker Street Partners and Managing Directors, Jordan Kienzle - Investment Strategy Group Vice President and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. BAKER STREET ADVISORS i ndependent. Customized . Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 5 James E. Milligan’s Biographical Information Educational Background and Business Experience Year of Birth: 1961 Formal Education after High School University of Texas at Austin – B.S. Civil Engineering 1983 Stanford Graduate School of Business – Master in Business Administration 1987 Business Background for the Preceding Five Years March 2011 to Present Managing Director, Baker Street Advisors, LLC February 1999 to March 2008 Managing Director & Regional Manager Private Wealth Management (PWM), Goldman Sachs April 1997 to January 1999 Managing Director, Regional Manager (PWM), Goldman Sachs August 1987 to April 1997 Vice President and Private Client Advisor (PWM), Goldman Sachs Disciplinary Information Mr. Milligan has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Milligan or of the Advisor. Other Business Activities Mr. Milligan is not engaged in any other investment related business, and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Milligan does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all of the Baker Street Partners and Managing Directors, Jordan Kienzle - Investment Strategy Group Vice President and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. BAKER STREET ADVISORS i ndependent. Customized . Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 6 Heather L. Pelant’s Biographical Information Educational Background and Business Experience Year of Birth: 1968 Formal Education after High School: University of Victoria – BA, 1991 University of Hawaii – MA, 1996 J.L. Kellogg Graduate School of Management – MBA, 2009 Business Background for the Preceding Five Years: December 2016 to Present Managing Director, Baker Street Advisors, LLC January 2003 to August 2016 Managing Director, BlackRock January 1997 to January 2002 Vice President, Morgan Stanley Disciplinary Information Ms. Pelant has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Ms. Pelant or of the Advisor. Other Business Activities Ms. Pelant is not engaged in any other investment related business, and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Ms. Pelant does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all of the Baker Street Partners and Managing Directors, Jordan Kienzle - Investment Strategy Group Vice President and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. BAKER STREET ADVISORS i ndependent. Customized . Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 7 Wendy A. Umphrey’s Biographical Information Educational Background and Business Experience Year of Birth: 1971 Formal Education after High School: University of Michigan – BA, 1993 Business Background for the Preceding Five Years: April 2007 to December 2016 Vice President, Baker Street Advisors, LLC January 2017 to Present Managing Director, Baker Street Advisors, LLC Disciplinary Information Ms. Umphrey has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Ms. Umphrey or of the Advisor. Other Business Activities Ms. Umphrey is not engaged in any other investment related business, and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Ms. Umphrey does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all of the Baker Street Partners and Managing Directors, Jordan Kienzle - Investment Strategy Group Vice President and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. BAKER STREET ADVISORS i ndependent. Customized . Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 8 Michael van den Akker’s Biographical Information Educational Background and Business Experience Year of Birth: 1952 Formal Education after High School: San Francisco State University – BA, 1976 Business Background for the Preceding Five Years: February 2004 to Present Partner, Baker Street Advisors, LLC October 2005 to April 2015 Director and Chair of the Asset/Liability Committee, New Resource Bank September 1999 to February 2004 Managing Director, myCFO, Inc. January 1985 to September 1999 Partner, Price Waterhouse, LLP Disciplinary Information Mr. van den Akker has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. van den Akker or of the Advisor. Other Business Activities Mr. van den Akker is not engaged in any other investment related business, and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. van den Akker does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all of the Baker Street Partners and Managing Directors, Jordan Kienzle - Investment Strategy Group Vice President and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. BAKER STREET ADVISORS i ndependent. Customized . Focused. Baker Street Advisors, LLC 575 Market Street Suite 600 San Francisco, CA 94105 9 Christopher J. Wilkens’s Biographical Information Educational Background and Business Experience Year of Birth: 1971 Formal Education after High School University of Wisconsin, Madison – BA 1993 Business Background for the Preceding Five Years March 2007 to Present Partner, Baker Street Advisors, LLC April 2003 to February 2007 Principal, VERITY Wealth Advisors, LLC April 1997 to April 2003 Director, Merrill Lynch & Co. April 1996 to April 1997 Associate, Barclays de Zoete Wedd Securities, Ltd. July 1993 to April 1996 Analyst, Goldman Sachs Disciplinary Information Mr. Wilkens has not been involved in any legal or disciplinary events that would be material to a client’s evaluation of Mr. Wilkens or of the Advisor. Other Business Activities Mr. Wilkens is not engaged in any other investment related business, and does not receive compensation in connection with any business activity outside of the Advisor. Additional Compensation Mr. Wilkens does not receive economic benefits from any person or entity other than the Advisor in connection with the provision of investment advice to clients. Supervision All investment recommendations at Baker Street Advisors are collaboratively agreed upon and overseen by the Baker Street Investment Committee. The Baker Street Investment Committee is comprised of all of the Baker Street Partners and Managing Directors, Jordan Kienzle - Investment Strategy Group Vice President and Jennifer Bonvechio - Chief Compliance Officer. Any of these members can be reached at the number on the cover of this brochure supplement. BAKER STREET ADVISORS i ndependent. Customized . Focused. Exhibit H: Grant Ave Project Website and Community Outreach ~ ~ C a ~31 rant.org H: Apps G iGoogle M Gmail 6 Facebook 0 Pin It E-mail Accounts WebHostlng & Desi ... Social Media Media cato investments -Google Search G * College an\_ goog!e.com J Family I' Other bookmarks 0 0 • 4:17 PM Friday 5/14/2021 Note: the Grant Ave developers have sent out mass mailings to surrounding neighborhoods inviting feedback, notifying them of multiple ways to provide feedback, and setting out schedule for community input meetings--in stark contrast to Cato's avoidance of College Terrace residents seeking to give input about their dissatisfaction with the developer's misconduct. Exhibit I: Flyer sent to residents to make sure everyone knows about on- going outreach, so different from the hide=II apporach used by Cato Investments. mercyHOUS ING ~m£~i~ 231 GRANT EDUCATOR WORKFORCE HOUSING Neighborhood Community Design Workshop Session 2: Community Input Follow-up Wednesday, May 26th, 2021 5:30 PM to 7 PM RSVP REQUIRED: Please go to www.231grant.org to register. Any questions or concerns with registering, please contact Isaac Cruz at isaac.cruz@mercyhousing.org or call (415) 355-7100. Special Guests: Development Team: Mercy Housing and Abode Communities Design Team: Van Meter Williams Pollack and Plural 3/12/2021 Community Meeting I Wellesley Housing Exhibit M: Billed as Community Meeting, Note Save the Date doesn't give a Date ! WELLESLEY HOUSING Vision About FAQ Community Meeting SAVE THE DATE Community Meeting: Link to R.S.V.P. is now open. We hope you'll have the opportunity to join our community meeting as we share the proposed project to the c ommunity prior to the City of Palo Alto's formal Pre-Screening. If you can't make it, don't worry, we will post a recording of the meeting. Upcoming Events Wellesley Project Community Meeting RSVP info@wellesleyhousing .com ©2020 by Wellesley Housing. Proudly created with Wix.com htlps://www.wellesleyhousing.com/community-meeting 1/2 Exhibit N: Gaslighting -False framing of opposition, making it about the protestors when in fact the opposition is to the misconduct of the developer exemplified by this event. WELLE SLEY HO US ING Vision About FAQ Community Conversation WHAT'S SO SCARY ABOUT APARTMENTS? A Community Conversation 7 Baumb, Nelly From:Karlette Warner <karlette46@sbcglobal.net> Sent:Tuesday, May 18, 2021 1:49 PM To:Council, City Subject:Public comment on tonight's Council meeting topic: Wellesley Apartment complex CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  I may not be able to join tonight’s meeting but I wish to submit the following comment:    I am in complete agreement with the College Terrace Residents’ Association letter of March 10, 2021, to the Palo Alto  City Council, opposing the Wellesley Apartment proposal.  Further, I believe that in order to achieve Palo Alto’s housing  goals, it will require dense housing, best put in commercial zones or along transit corridors.  A 24‐unit apartment  building would be very disruptive to the architecture and character of the College Terrace neighborhood, and would do  little to ease the housing shortage and even less to meet the below‐market‐housing need.       Thank you.     Karlette Warner  College Avenue  Palo Alto     Sent from Mail for Windows 10    8 Baumb, Nelly From:Melanie Grondel <mel.grondel@gmail.com> Sent:Tuesday, May 18, 2021 11:39 AM To:Council, City Cc:Melanie Grondel Subject:CATO/ WELLESLEY DEVELOPMENT in College Terrace. CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Major Dubois and City Council Members, Dense Developments need to be built in spaces that can accommodate the new community. Large underused commercial, city, county or state properties offer opportunity to create space for a livable solution. Dense Development on single family lots in neighborhoods of relatively modest lots, an average of 6000 sf, hurts those who live in these large clusters of small units as well as the neighbors who have to live with these dense developments. This is a nightmare for individuals to live in and those who have to live with this dense development. This development project is a nightmare for the community striving for a livable and cool city. Live in. To put 24 units in the place where 2 average houses just stood, makes for a large and dense cluster of very small to tiny units. Having just downsized to one of the smaller house in College Terrace, I can assure you that a single person needs a minimal space too and a standard one bedroom unit is no luxury. These can hardly be called units fit for a family. For that reason these units do not solve the problem of the Missing Middle, as misleadingly claimed by Cato. Every square inch possible has been turned into space that brings in a profit. Parking spaces have been limited so cars will need to be parked along the streets wherever a space can be found on this extremely short block. The back and forth traffic will increase 24 fold. A space for parking one car per unit is necessity. Without a car, shopping for well priced products to stretch the family dollar and family trips of hikes in nature, are not possible with the current limited transit. Cooped up in a small or even tiny unit in a building without amenities of common space, and green planting, and right on the streetraffic due to severely reduced setbacks without trees serving as green zone between housing and traffic, the residents are subject all the disadvantages of overcrowding, anxiety, depression and a target for disease, as just demonstrated during the pandemic. Nearby there are small apartment buildings of between 4 to 8 units with balconies for each. They are placed in a garden setting with trees and shrubs, at 1/4 the density of the Cato development; there is parking on site so that street parking is left for services and visitors on this very short street of half a block. Kids ride their bike to the Library safely. That is an example of sustainable apartment development. The Cato development is the antithesis of livability. Live with. The neighbors have to deal with a 3 stories high concrete block usurping every inch of the property and more, usurping the mandated setbacks as well. No green planting as the customary green zone between building and street. This 3 story block of concrete heating up in sunlight without any of the green technologies, is the perfect example of heating up the city instead of the cool city, the City of Palo Alto strives for. The back and forth traffic will increase 24 fold, overcrowding the short Street to the Library and Childcare facility, very unsafe especially for children on their bikes and older residents. The traffic situation will be further complicated by the street parked full of cars since the new apartments are planned short of parking spaces. The 3 story building that looks like a bank or commercial development, dominates the heart of College Terrace, the access to the beloved CT Library and the gentle blocks of eclectic architecture set back in green planting and trees; it sticks out like a sore thumb and is offensive to the eye. This building spoils the heart of College Terrace to live with and to live in. The financial benefits go to the developer, owner or investment consortium. Contrary to their sweetly sounding propaganda during their community outreach that they are a few older gentlemen with some cash to spare to help with the housing shortage and create affordable housing, CATO LLP is a real estate investment firm with substantial assets. This misrepresentation 9 alone gives reason to mistrust the presentation of this project and the intentions proclaimed. All parties stand to loose except for the developer/investors. If this Cato recipe works, we will see it repeated all over the College Terrace, Barron Park, Ventura and Evergreen neighborhoods as well as in the Downtown and Crescent Park neighborhoods whenever a full size parcel opens up. Also a Channinghouse can be duplicated, do not forget; it may take a little longer, but there is SB35 that can be invoked as the City of Los Altos found out. The large houses along University Avenue can be converted; I lived in one many years ago. To provide price-efficient and livable housing, we need to build on large underused commercial, lots where there is space for a properly developed housing community along cool city guidelines. Thank you for your consideration, Melanie Grondel, Resident of College Terrace, Palo Alto.           10 Baumb, Nelly From:Amie Ashton <aashton@gmail.com> Sent:Tuesday, May 18, 2021 10:25 AM To:Council, City Subject:Support for HOUSING! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Honorable City Council,     I am writing in support of the housing projects that are on the agenda tonight, the 36 units on Alma (microunits are  amazing, after all ‐ half of Paris lives quite happily in small units like this) and the 24 apartments on Wellesley.    I support a community that is diverse and providing a diversity of housing is the first step in that journey. Housing also  supports our vital retail areas by creating more customers and supporting longer business hours for sales to occur. Our  downtown areas cannot survive as malls (which are dying by the hundreds right now). We need more residents to  provide retail and restaurant demand.    I also urge the removal of barriers to housing on all fronts, from removing parking requirements to lessening fees. We cannot simultaneously support affordable housing while creating additional barriers for housing developers.     Thank you,    Amie Ashton  236 MIddlefield Road  11 Baumb, Nelly From:Ted O'Hanlon <tedohanlon@gmail.com> Sent:Monday, May 17, 2021 10:37 PM To:Council, City Cc:Lait, Jonathan; Gerhardt, Jodie Subject:5/18/21, CC Agenda, Study Session Item 2. 2239 Wellesley (21PLN-00045) CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Councilmembers:     I write to provide observations related to the Prescreening to Rezone R‐1 properties at 2239 & 2241 Wellesley.     Several weeks ago, the council heard and approved the subdivision of a "jumbo" R‐1 parcel into two R‐1 parcels, such  that it required City Council approval for a subdivision into 2 lots > 10,000 square feet. I have included my similar  observations from 4/16/21 on this application below this memo.     Now, the subject properties for Item 2 on Wellesley contemplate a rezone of a combined area >15,000 square and have  presented plans for a 24‐unit multi‐family project. Given this and the previous consideration, I would state similarly  related to the subdivisions of large lots:     The City of Palo Alto should study and encourage guidelines where large parcels zoned R‐1 might be subdivided  into lots that are less than 6,000 square feet. The City has a "Village Residential" code applicable to RM‐15 (and  greater) zoned land that also contains "gentle density" components more suitable to R‐1 zoned sites and  neighborhoods (i.e. cottage clusters, duplex, triplex, fourplex). This could provide differentiated housing  outcomes (smaller lots, smaller homes, more units) where there are existing "jumbo" lots of >10,000 square feet  that yield more housing creation in both primary and ADU dwellings on lots of 2,500 to 5,999 square feet, rather  than fewer  homes on large lots that are built to the greatest size possible.     Based on data from Santa Clara County, 19.3% of single family home parcels are <6,000 square feet, thus smaller lots are  not uncommon in Palo Alto, actually quite ordinary. At the same time, 14.9% of single family home parcels are >10,000  square feet, providing some reasonable, organic, over‐the‐passage‐of‐time opportunity for new housing units. The rest  of and majority of R‐1 property in Palo Alto is the more customary single family lot size between 6,000 and 10,000  square feet which could remain as‐is and limited to focus on the ADU provisions that City Council has approved in the  last year or so.     As previously referenced, the Planning & Transportation Committee has made commendable and reasonable  observations regarding smaller lot formats as does the Housing Work Plan from 2018 which states:   "A key component of a diverse, inclusive community, allow and encourage a mix of housing types and sizes  integrated into neighborhoods, and designed for greater affordability, particularly smaller housing types, such  as studios, co‐housing, cottages, clustered housing, accessory dwelling units and senior housing."    "Consider zoning changes to allow additional cottage clusters, duplexes, and fourplexes where appropriate."  Thank you for your time and consideration of these observations.     Best Regards  Ted O'Hanlon  12     ‐‐‐  Ted O'Hanlon   tedohanlon@gmail.com  415.317.5070 mobile/text  CA DRE #01868277    ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐  Ted O'Hanlon <tedohanlon@gmail.com>     to city.council, Jonathan, Jodie  To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.    4/19/21 Council Agenda Item #6, Subdivision Councilmembers: Item #6 on the 4/19 City Council agenda discusses a property at 640 Fairmede Avenue that seeks to subdivide an ~23,000 sq ft property into 2 lots of 11,000+ sq ft for which I have no issue. Rather, I would like to utilize this to present a housing creation opportunity for Palo Alto when these situations arise in the future. In February 2021 640 Fairmede was heard by PTC and the transcript quotes both Commissioners Templeton and Summa remarking on the potential for a cottage cluster subdivision rather than the 2 larger lots proposed (which are also non-conforming since >9,999 sq ft). Commissioner Summa continues noting that the Comprehensive Plan cites wanting to encourage housing type mixes, like cottage clusters. This notion can be seen in the Housing Work Plan from 2018:  "A key component of a diverse, inclusive community, allow and encourage a mix of housing types and sizes integrated into neighborhoods, and designed for greater affordability, particularly smaller housing types, such as studios, co-housing, cottages, clustered housing, accessory dwelling units and senior housing."  "Consider zoning changes to allow additional cottage clusters, duplexes, and fourplexes where appropriate." I believe the City of Palo Alto should establish guidelines where large parcels zoned R-1 could be subdivided into smaller lots that are less than 6,000 sq ft and utilize driveway easements. Since the City already has the Village Residential code applicable to RM-15 and denser zoned land, I would propose enabling certain Village Residential components for R-1 zoned lots with a lesser density allowances to maintain a harmonious fit within existing R-1 neighborhoods. This could provide differentiated housing outcomes on larger lots that yield greater housing unit creation in both primary and ADU dwellings on lots of 2,500 to 5,999 sq ft. Thank you for your time and consideration of these observations. Best Regards Ted O'Hanlon --- Ted O'Hanlon 14 Baumb, Nelly From:Richard Such <wrichardsuch@gmail.com> Sent:Monday, May 17, 2021 4:46 PM To:Council, City; Raybould, Claire Subject:May 18 Prescreening of Wellesley Street Cato rezoning project CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  We have lived at the corner of College Ave. and Oberlin St. since  1969.   In 1978 we subdivided the 8625 s.f. lot and built a new house on  Oberlin, and in 2006 we re‐built the 1896 duplex on College.  During this  time, we have seen a lot of houses torn down and rebuilt in the R‐1 zone,  but we don’t believe that any new multi‐unit buildings have been built in  the R‐3 zone, except within a block of El Camino.  The line between the  two zones protects us from the gradual encroachment of apartment  buildings from El Camino that began, probably in the 1940s, surrounded  some Victorian‐ and Queen Anne‐style buildings from the 1890s and early  1900s, and threatened to creep all the way up the Terrace.    We strongly oppose approval of the 24‐unit building at the corner of  College and Wellesley St. – or of any building on the existing lots, other  than replacements for the two existing single‐family dwellings or a duplex  on the vacant lot.  Our opposition is based on five factors:    • One: the “domino” effect.  It is true that on the same block and across  the street from that corner, there are several 4 to 6‐unit apartment  buildings.  But if the 24‐unit building – or anything more than 4 units –  were to be built, there would be an incentive to build more such units on  adjacent lots – and then on lots adjacent to and across the street from  them. The value of lots near multi‐unit buildings as sites for single‐family  homes would decrease, and the pressure to sell them as sites for more  multi‐unit buildings would increase.      15 • Two: the “failure to keep faith” with R‐1 homeowners.  Many people –  ourselves included – have bought and built houses in the neighborhood,  considering it to be mainly of single‐family homes and counting on its  remaining as such, based on enforcement of the R‐1 zoning.  The new  and relatively new houses and re‐models next‐door to and across the  street from the projected 24‐unit building are examples of this.  To put  them in the shadow of that building or to subject them to the many  parked vehicles that would accompany it (one or two for every unit?),  would be to betray their trust in a stable, uncrowded environment.    • Three: the “disincentive to re‐build” effect.  There are many old,  substandard houses in College Terrace, built more than 60 years ago,  which need re‐modeling and up‐grading.  Our original house at the corner  of College and Oberlin was an example of this: plumbing and electrical  systems that were installed when electrical lines and sewers first became  available, termite and dry‐rot damage, in‐floor gas heaters, etc.  We  spent hundreds of thousands to re‐build a modern house, but we would  never have done this if we had seen multi‐unit buildings coming up the  street.    • Four: the “degradation of the environment.”  Gone are the days of the  seasonal ponds that were found where the Stanford Industrial Park is  now, the creek that flowed down Stanford Avenue and through culverts  under the neighborhood, and the opossums, raccoons, skunks, frogs, and  other wildlife that inhabited them – their habitats destroyed, frankly, by  Stanford.  But we still have abundant bird life, such as titmice and  mockingbirds that sing from the tree‐tops all Spring and Summer.  That is  thanks to the variety of trees that line our streets, border our parks, and  grow in almost all yards.  The lot at the corner of College and Wellesley  used to be a garden, with fruit trees that have been allowed to die in  recent years.  The 24‐unit building would have no place for trees.  It  doesn’t even provide for a lawn on which the children of residents could  16 play.  We do not want a paved‐over desert like a city south of  here.  Instead, we expect protection like neighborhoods on the other side  of the Caltrain tracks enjoy.    • Five: the “quality of construction and management.”  This is more a  matter of questions than of issues and is not unique to multi‐unit  buildings.  If the proposed building is not built according to high  standards, including design and materials, people who can afford to do so  will choose to live elsewhere, and those who choose to rent may be  short‐term tenants who are not motivated to maintain apartments and  exteriors, and they will deteriorate and become even less attractive to  future renters.  We live next door to a single‐family house that was built  shabbily, then reconfigured to add bedrooms (e.g., a laundry room  turned into a bedroom), and for several years was rented to a series of  rowdy student groups who disturbed the neighbors to the extent that the  police were called.  Their disused belongings were allowed to pile up in  the unattended front yard.  Is there any assurance that tenants of the  proposed 24‐unit building will be carefully screened for “good  neighborliness” and that housekeeping rules that most individual  landlords would make will be enforced?  If the Cato developers provide  such assurance but then sell it to some other entity, would there be any  way to make sure that they maintained the same standards?  Richard and Jane Such, 1120 College Ave., Palo Alto, CA  17 Baumb, Nelly From:Eileen Stolee <estolee@gmail.com> Sent:Monday, May 17, 2021 2:31 PM To:Hank Edson Cc:Council, City; Ingrid Rulifson; Andrew Fetter; Jeff Stoen; Sukhi Nagesh; Kara Davis; Carol Li; Cook, James F.; mattydavis139@gmail.com; Annawork Lembke; Berkeley Revenaugh; Clara Stoen; Colin Born; Daniel Kaleba; Valerie Sarma; Al Gianotti; Andrea Cook Fleming Subject:Re: Wellesley St. Proposed Project - Developer's Recent Misconduct CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  This is the letter I wrote to CC.     Dear City Council Members,     The Wellesley housing project is not about a three-story apartment building, It's not even about the Wellesley project itself. This is about a Trojan Horse, a billion-dollar Investment firm, up-zoning valuable land in an R1 neighborhood in order to make millions for their investors while providing a pittance of affordable rentals. If you do some research you will understand that Cato Investments has the same CEO, Jeffrey Colin, as Baker Street Advisors which has assets over 1 BILLION dollars. Cato is not a developer and is not interested in building true, affordable, and LIVABLE, housing. They are interested in gaining more wealth for their developer friends and million-dollar investors. If the Wellesley project is approved, then all the property Cato owns in College Terrace and elsewhere can be developed under PHZ zoning. Plus, you will open up the flood gates all over Palo Alto for all the other investment firms who always OUTBID regular individual families who want to put down roots here.    Only a "small fraction" of affordable housing has to be built under a PHZ up-zone. After a project is built the land under it will go up in value which is what these investment firms want. In a few years, the land will be sold and all the million-dollar investors will make a profit. Cato will be out of the picture and go on to outbid other buyers for more valuable land and the money-making cycle continues. Leaving a blighted, treeless landscape like the ugly Cato project!    In the meantime very little, if any affordable housing will be built. Ugly, monastic size rental units, at market rate, will replace TREES, landscaping, and the charm of R1 neighborhoods.  Affordable Housing advocates should be spending their time trying to raise money to buy up land instead of helping companies like Cato who is not interested in building affordable and livable homes.   Small, 347 sq. ft. rental housing will not help the many families and couples looking for affordable housing. Don't be fooled! We all know that affordable housing is very expensive to build unless it is subsidized by private and state funding.     Wealth management firms like Cato/Baker Street Advisors are not going to build the housing we really want and need in Palo Alto. If we let these global investment firms, LLCs, and Stanford, outbid and buy up our valuable land, there will never be a chance for real affordable homeownership, which is one way to gain wealth, for the average working family.   18   Tech companies want to house their workers but not create affordable housing. Stanford University wants to house its workers, medical interns, grad students but does not want to build affordable homes.    Residents of Palo Alto are looking at their elected City Council members to reject this project outright!     Sincerely,  Eileen Stolee   984 S California Ave  PA, 94306    On Mon, May 17, 2021 at 2:13 PM Hank Edson <hank.edson@gmail.com> wrote:  Dear Council Members,  I want to thank you for recently affirming the limited application of the PHZ tool and say that ‘incentivizing’  private developers to achieve a public policy goal of building affordable housing is the wrong  approach.  Instead, city council should take on the leadership of developing a citywide map and plan for  achieving the needed increase in affordable housing units through a process that brings all stakeholders to  the table and applies affordable housing industry standards.   I also want to alert you to Cato Investment’s outrageous conduct this past week in its deceitful staging of a  “community conversation” in which the actual community was prohibited from offering untampered  input.  Cato’s “conversation” consisted of five panelists, four of whom were not Palo Alto residents, who  spoke at the audience for nearly an hour falsely representing themselves and the issue at hand.  No  comments from the public were allowed.  Only at the end could questions be asked but these were forced to  accept Cato’s falsely asserted premises, and were kept hidden from the public.  Panelists only answered  questions they wanted to answer, and these were edited and falsely represented to the audience.  (See  Exhibit 1 through 4)  In particular, I draw your attention to the way Cato used Josh Zimke, a first‐year law  student at Stanford with an admirable commitment to progressive activism, inducing him to emcee a  dishonest event with no regard for its impact on his reputation.  (See Exhibit 4 for further description)  This  bad behavior stands in stark contrast to the outreach being conducted by Mercy Housing and Abode  Communities in the 231Grant Avenue project.  (See Exhibits H, I, M & N)  But Cato Investments is also unacceptable for two other reasons.  First, its economic activity purchasing numerous lots around Palo Alto, especially in College Terrace, actually  drives up prices for families trying to get into the housing market.  (See Exhibit 5)  This activity is for  profit.  Likewise, Cato’s proposed development dedicates a mere 20% of its units to affordable housing, and  these are studios and one bedrooms.  Such a paltry contribution would not offset the inflationary effect of  increasing unit density by twelve times on a residential lot.  The proposed project would not lower housing  costs.  It would increase them.  (See UBC's Professor Patrick Condon presenting his research at https://www.youtube.com/watch?v=24vf2c9AIwQ)  Attendees who could not share their emotional upset during the event due to the tight control and  manipulation of the “conversation” by Cato and its panelists, later described the event as insulting, inspiring  outrage, out of the George Orwell novel 1984, exploding their head in its brazen and shocking dishonesty, as  a tooth fairy story, and falsely accusing opposition as in violation the law.  One attendee noted:  19 “I’ve been on multiple Zoom all hands meetings at my company and the Q&A stream is seen by all  attendees. Uncomfortable and even inappropriate questions scroll by but they try to answer them all.  This meeting was a joke. I submitted questions, tried to chat with the panelists ... not one thing got  answered even privately. If this is their way of connecting with the community, with a one way lecture  cheery picking questions from their constituents, they failed miserably!”    Second, Cato’s proposal fails to meet affordable housing industry standards embodied in the Grant Avenue  project, namely: 1. It should be 100% affordable housing, 2. The land should be owned by the city, county or other  public agency, 3. The developer should demonstrate financing‐obligation and tax‐benefit transparency and rigorous  accounting practices before claiming non‐profit status, 4. The developer should be chosen through a strictly  scrutinized public bidding process, and 5. The developer should engage in extended, open, democratic, authentic  community dialog free of manipulation.  In my opinion Cato, which has no experience in building non‐profit affordable housing, and which, at the same  time, is headed by Jeff Colin, who also heads Baker Street Investments, which manages over $10 billion in assets, is  partially owned by Affiliated Fund Management, which manages over $700 billion in assets, should be blacklisted  from receiving any permits from the city of Palo Alto.  (See Exhibits B, C, and D for information about these  entities)  Cato's conduct has been dishonest and counter to city resident’s interest in both affordable housing and  zoning protections.  City council is here to serve and protect the people who live in our city, not outside corporate  interests of concentrated wealth that dishonestly portray themselves as serving affordable housing goals while  simultaneously running a business that offers billionaires tax‐advantageous investments.  These two activities are  irreconcilable and it is the city council’s responsibility to protect the residents of Palo Alto from Cato’s abusive  misconduct.    Thank you.      Hank Edson  2106 Oberlin Street,  Palo Alto, CA  94306  20 Baumb, Nelly From:Malcolm Slaney <malcolmslaney@gmail.com> Sent:Monday, May 17, 2021 2:21 PM To:Council, City Subject:2239 Wellesley: PHZ Prescreening CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear City Council,    I am writing to you to express my strong objection to the proposal by Cato to replace two single family homes in College  Terrace with a three story building with room for 24 families.  This is dramatically out of scale for the neighborhood. It  does not provide adequate parking.    If Palo Alto desires more housing then there are numerous areas in town, especially along El Camino, that are not  developed, and where the size of the proposed project is more consistent with the neighborhood.    If Cato really wants to add more housing then they can develop the existing parcels with a house and a detached cabin,  doubling the existing housing on these lots.    — Malcolm Slaney  College Terrace Resident    21 Baumb, Nelly From:Annette Ross <port2103@att.net> Sent:Monday, May 17, 2021 6:46 AM To:Council, City Subject:Proposed CATO projection - corrected letter to CC CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Somewhere along the way, Council’s intentions regarding the PHZ were “misunderstood” with the result that CATO seeks to build a 3-story, 24-unit, under-parked apartment building that requires approval to merge 2 lots. JUST SAY NO.  Consider, if you will, how you would feel about such an over-sized building going up next to your home. This is not a good precedent to set in Palo Alto’s R1 zones. Far from being the “right project in the right location” (per CATO spokesperson Gildea) the proposed project is an insult to the neighborhood. There are multiple ways in which the two lots can, separately, be built more densely than single family. The City does not need to - and should not - pervert PHZ to permit what CATO’s existing plan requests.  Also, despite what was written about this project in January, the corner of Wellesley and College is not two blocks away from a Caltrain stop. Nor is it two blocks from Stanford. Campus property may begin on the other side of Stanford Ave, but the core campus is not two blocks away. Twisting facts to suit a narrative does nothing to engender neighborhood trust or support.   College Terrace has been through the Planned Community (“PC”) game once before when a developer manipulated affection for a neighborhood grocery - and CC - to gain approval of an over-sized development. That project contributed greatly to the community’s opposition to PC zoning and the eventual suspension of PC zoning. Let’s not make a similar mistake here.  Annette Ross  College Terrace  22 Baumb, Nelly From:Annette Ross <port2103@att.net> Sent:Sunday, May 16, 2021 8:33 PM To:Council, City Subject:CATO’s proposed project for Wellesley Street in College Terrace. CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Somewhere along the way, Council’s intentions regarding the PHZ were “misunderstood” with the result that CATO seeks to build a 3-story, 24-unit, under-parked apartment building that requires approval to merge 2 lots. JUST SAY NO.  Consider, if you will, how you would feel about such an over-sized building going up next to your home. This is not a good precedent to set in Palo Alto’s R1 zones. Far from being the “right project in the right location” (per CATO spokesperson Gildea) the proposed project is an insult to the neighborhood. There are multiple ways in which the two lots can, separately, be built more densely than single family. The City does not, and should not, pervert PHZ to permit what CATO’s existing plan requests.  Also, despite what was written about this project in January, the corner of Wellesley and College is not two blocks away from a Caltrain stop. Nor is it two blocks from Stanford. Campus property may begin on the other side of Stanford Ave, but the core campus is not two blocks away. Twisting facts to suit a narrative does nothing to engender neighborhood trust or support.   College Terrace has been through the Planned Community (“PC”) game once before when a developer manipulated affection for a neighborhood grocery - and CC - to gain approval of an over-sized development. That project contributed greatly to the community’s opposition to PC zoning and the eventual suspension of PC zoning. Let’s not make a similar mistake here.  Annette Ross  College Terrace  23 Baumb, Nelly From:slevy@ccsce.com Sent:Sunday, May 16, 2021 5:02 PM To:Council, City; Planning Commission Cc:Lait, Jonathan; Wong, Tim Subject:Study session items 1 and 2 5/18/21 CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Mayor DuBois and council members, The council has a chance to give positive feedback to am mixed use, mainly housing project on Alma on a site close to jobs, services, shopping and transit and at the same time correct a premature decision with regard to the application of PHZ projects in R-1 neighborhoods. The Alma project would add housing and reduce office space on a desirable site. The Wellesley project would add housing oriented to both the missing middle and low income residents. That site, like the Alma site, is close to jobs, services, shopping and both freeways and public transit. Both projects meet a city goal of projects with 20% BMR units. Taking any housing options off the table either with regard to PHZ zoning or the NVCAP area before the housing element site review process even begins strikes me as reckless and irresponsible and puts the city at legal risk since it is very likely that we will easily find suitable sites and policies to incentivize 6,000 units or even a bit smaller if the city wins an appeal. One of the requirements of the housing element is to identify and overcome challenges to meeting our housing goal. I understand that there is political pressure to to oppose state law and many projects but your job as the Mayor has said is to proceed with a good faith effort to meet ALL of the housing element update requirements. Please let the housing element process develop findings before taking housing options off the table. Stephen Levy 24 Baumb, Nelly From:Eileen Stolee <estolee@gmail.com> Sent:Sunday, May 16, 2021 2:21 PM To:Council, City Subject:The Cato, Wellesley Housing project CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council Members,     The Wellesley housing project is not about a three story apartment building, It's not even about the Wellesley project itself. This is about a Trojan Horse, billion dollar Investment firm, up-zoning valuable land in an R1 neighborhood in order to make millions for their investors while providing a pittance of affordable rentals.. If you do some research you will understand that, Cato Investments has the same CEO, Jeffrey Colin, as Baker Street Advisors which has assets over 1 BILLION dollars. Cato is not a developer and is not interested in building true, affordable, and LIVABLE, housing. They are interested in gaining more wealth for their developer friends and million dollar investors. If the Wellesley project is approved, then all the property Cato owns in College Terrace and elsewhere can be developed under PHZ zoning. Plus, you will open up the flood gates all over Palo Alto for all the other investment firm who always OUTBID regular individual families who want to put down roots here.    Only a "small fraction" of affordable housing has to be built under a PHZ up-zone. After a project is built the land under it will go up in value which is what these investment firms want. In a few years the land will be sold and all the million dollar investors will make a profit. Cato will be out of the picture and go on to outbid other buyers for more valuable land and the money making cycle continues. Leaving a blighted, treeless landscape like the ugly Cato project!    In the meantime very little, if any affordable housing will be built and instead ugly, monastic size rental units, at market rate, will replace TREES, landscaping and the charm of R1 neighborhoods.  Affordable Housing advocates should be spending their time trying to raise money to buy up land instead of helping companies like Cato who is not interested in building affordable and livable homes.   Small, 347 sq. ft. rental housing will not help the many families and couples looking for affordable housing. Don't be fooled! We all know that affordable housing is very expensive to build unless it is subsidized by private and state funding.     Wealth management firms like Cato/Baker Street Advisors are not going to build the housing we really want and need in Palo Alto. If we let these global investment firms, LLCs, and Stanford, outbid and buy up our valuable land, there will never be a chance for real affordable home ownership, which is one way to gain wealth, for the average working family.     Tech companies want to house their workers but not create affordable housing. Stanford University wants to house their workers, medical interns, grad students, but does not want to build affordable homes.    25 Residents of Palo Alto are looking at their elected City Council members to reject this project outright!     Sincerely,  Eileen and Richard Stolee  984 S California Avenue  94306  1 Baumb, Nelly From:Ann Balin <alafargue@mac.com> Sent:Sunday, May 16, 2021 5:21 PM To:Council, City Subject:CATO LLC Investment firm's proposal CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear Mayor Tom DuBois, Vice Mayor Pat Burt and fellow Council Members,    Please stand by your reasoned vote regarding PHZ zoning and do not accept the proposition by the CATO LLC investment  firm’s application before you Tuesday night, May 18th. This firm is ONLY about investment and profit. They claimed last  May 15th at their ‘outreach’ that profit is not their goal but rather to benefit society with affordable housing. When one  takes a cold fish eye look at the proposal one sees clearly that there are only four BMR units. This project is NOT about  affordable housing. It is insulting to the community and to you for them to state otherwise.    You have received a letter from the College Terrace Residents’ Association earlier in 2021 detailing why this  development is unsuitable for R1. I ask that you now take the time to exclude RMD‐NP from this PC zoning as well. The  character of the College Terrace neighborhood will be forever altered should you not exclude RMD‐NP.    I applaud your thoughtful investigation into housing in Stanford’s Research Park. I do not agree that housing should go at  the Town & Country Village Shopping Center. I also believe that the zoning for that shopping center should not include  medical ‘retail’ and services.    Thank you for your diligence in examining all of these zoning issues before you.    Respectfully yours,    Ann Lafargue Balin      2 Baumb, Nelly From:Hank Edson <hank.edson@gmail.com> Sent:Saturday, May 15, 2021 1:18 PM To:Council, City Subject:Cato Investments Scandalous and Insulting "Community Conversation": — Nextdoor CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  From my neighborhood: https://nextdoor.com/p/JwYqGYWyMK‐c?utm_source=share&extras=MzQzNDE3  Sent from Mail for Windows 10    1 Baumb, Nelly From:Paul B Goldstein <marmot@stanford.edu> Sent:Thursday, May 13, 2021 2:40 PM To:Council, City Subject:Meeting Tuesday May 18 Agenda Item #4 Attachments:CIty Council 181 Addison.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  To: Honorable Members of the Palo Alto City Council Re: City Council Meeting Tuesday May 18, Agenda Item #4 I live on Emerson Street, just 2 houses away from this property. I urge you to deny the request to subdivide the parcel at 181 Addison Avenue. Because subdividing this parcel requires a variance, it is appropriate for you to consider alternative uses of the property. This property, although not currently zoned for multi-family housing would make an ideal location for a small multifamily structure. If it is subdivided, that opportunity would be lost. I believe that because the opportunity for a denser use of the property would be lost, the proposed subdivision is NOT consistent with these policies in the Comprehensive Plan: B. Policy L-1.6 Encourage land uses that address the needs of the community and manage change and development to benefit the community. The need for additional housing in the community is well established. This lot could accommodate a multifamily building. It could not if subdivided. C. Policy L-2.4 Use a variety of strategies to stimulate housing, near retail, employment, and transit, in a way that connects to and enhances existing neighborhoods. Creative thinking about uses for this property could stimulate denser development on the site. D. Program H2.1.2: Allow increased residential densities and mixed-use development only where adequate urban services and amenities, including roadway capacity, are available. The location being near downtown, and near transit, etc., makes it ideal for increased density E. Policy H1.4: Ensure that new developments provide appropriate transitions from higher density development to single-family and low-density residential districts to preserve neighborhood character A multifamily use would be appropriate in this transition zone. Immediately next-door on Emerson are small bungalows, a school, a dry cleaner, offices and other commercial. On Addison, offices and commercial uses. F. Goal H2: Support the construction of housing near schools, transit, parks, shopping, employment and cultural institutions. By eliminating the possibility of multifamily use, this does not support this policy. I do not believe that your hands are tied in this decision, and that you can keep this parcel available as an opportunity for denser housing in the SOFA district. Respectfully, Paul Goldstein Emerson Street 1 Baumb, Nelly From:Greg Schmid <gregschmid@sbcglobal.net> Sent:Monday, May 17, 2021 8:24 AM To:Council, City Subject:letter for May 18 meeting Attachments:May 17 PASZ letter.docx CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Palo Altans for Sensible Zoning PO Box 305, Palo Alto, CA 94302 http://sensiblezoning.org May 16, 2021 Palo Alto City Council Agenda Item # 5 May 18, 2021 “RHNA Appeal Discussion” Honorable Council Members: The Palo Alto City Council should reject the Regional Housing Needs Allocation numbers assigned to Palo Alto. ABAG and RHNA have not followed the California Government Codes in formulating these numbers and they will bring unprecedented damage to our City. Plan Bay Area 2050 proposes that jobs should grow in “already jobs-rich areas”. This means that a very small section of Silicon Valley will get twice the number of new jobs of any of the other 32 equally sized geographical units that make up the Bay Area and build twice the level of new housing units. This concentration of job growth in a single area has already caused significantly negative consequences for residents: --Some of the highest land prices in the country; --Very expensive housing costs that are continuing to grow rapidly; --Income inequality that is one of the highest in the county and growing the fastest; --Transit usage that is declining over time; --Dispersion of families away from job centers; --Increasing tax burden on residents to pay for expensive infrastructure; --End of the mobility of workers and ideas through Silicon Valley; --Challenge to our sustainability goals; --Basic questions about the future of local democracy. THE CODES At the heart of the matter is the fact that the Plan Bay Area 2050/RHNA process has not followed the relevant California Government Codes regulating the actions of both ABAG and HCD. Section 65890.5 of the Code on Planning requires HCD to prepare and publicly distribute a Guidebook that would present “methodologies for measuring the balance of jobs and housing” and identifying “incentives which local, regional and state agencies may offer the private sector to encourage developments which will facilitate an improved balance between employment generating land use and residential land use”. HCD has not produced this Guidebook either before or during the Plan Bay Area 2050 process. Without the Guidebook, we need to take a more detailed look at why the RHNA allocation process described in Section 65584 is relevant. The most relevant parts include: Section 65584 (d) states that the regional government body should look for incentives that will “promote an improved intraregional relationship between jobs and housing”. Section 65584.04 (d) states that the data used shall include “each jurisdiction’s existing and projected jobs and housing relationship” and that “public participation and access shall be required in the development of the methodology of the allocation of regional housing needs”. To date there has been no effective public participation or access in the development of this methodology. 65584.01 (a) mandates that HCD’s housing projection “shall be based upon the Department of Finance and regional forecasts in consultation with each council of governments”. Further 65584.01 (c) states that HCD consult with the council of governments…who shall provide assumptions on the relationship between jobs and housing, including any imbalances between jobs and housing”. To date there has been no effective consultation outside of ABAG’s Technical Committee. Section 65584.04 (i) states that HCD should have a written report on whether the methodology is “promoting an improved intraregional relationship between jobs and housing”. To date there has been no such written analytic report. Section 65584.04 (a) states that “each council of government shall develop in consultation with HCD a proposed methodology for distributing the existing and projected regional housing needs to the cities”, while 65584.04 (d) states that “public participation and access shall be required in the development of the methodology of the allocation of regional housing needs”. Again—no effective public participation in exploring alternate means of dealing with imbalances. DISCUSSION The Codes explicitly mention again and again the need for “cooperation” and “public participation”. This clearly means that each of the parties—HCD, DOF, and MTC/ABAG—must engage directly with each other and with the public. But all the key decisions on the allocation methodology of both jobs and housing have been made by ABAG’s self-appointed technical committee that has representatives of both HCD and DOF but no public participation. Code 65980 clearly states that a Guidebook be prepared by HCD for use by cities and local government agencies to help explore other means of creating better balances between jobs and housing. But HCD has no records of the existence of a Guidebook and there is no record of MTC/ABAG requesting the Guidebook from HCD despite their close cooperation in working on population and housing projections together. MTC/ABAG have worked together with HCD and DOF on their jobs and housing forecast projections but all the work has been done in meetings of their self-appointed technical committee with no public participation. They have used their own in-house modeling programs based on aggressive job growth assumptions and have disregarded data that questions these assumptions. MTC/ABAG are moving ahead on their current model. Their approved methodology retains the ‘jobs driven model’ in priority development areas. This seems hard to reconcile with the Codes calling for public participation “promoting an improved intraregional relationship between jobs and housing”. For example: The Horizon project public outreach in 2019 did acknowledge that one strategy that might be looked at included placing office caps in eleven cities with more jobs than residents (Strategy V-7). But without any real or meaningful public participation or examination of “improving intraregional job- housing balances”, MTC/ABAG announced in October 2019 that Strategy V-7 was “Not recommended to move forward”. This leaves the Horizon strategies discussion involving “intraregional jobs-housing relationship” solely in the hands of an in-house staff process. The final decision on the RHNA options before you have been made in a closed Technical Committee despite the California Code calling for “public participation. CONCLUSION MTC/ABAG’s Plan Bay Area 2040 (2013) and their current update Plan Bay Area 2050 have failed to identify the emerging huge intraregional imbalances in jobs and housing that have negatively affected the West Bay and the whole of the nine county Bay Area during the last decade. MTC/ABAG failed to respond in detail to formal complaints raised in detail by West Bay citizen groups about the impacts of those imbalances. Further, they have not followed the Government Codes that have stressed the need for public discussion of alternative means of dealing with intraregional balances and have not acknowledged their joint commitment to cooperate in such activities with full public participation. We ask that the Palo Alto City Council halt the process of updating the jobs and housing projections in the plan Bay Area 2050. To date this process has not followed the California Government Codes that require the participation of local citizens groups in developing an effective course of action. Please act tonight on the steps that need to be taken in order to “promote an improved intraregional relationship between jobs and housing”. Direct the City Attorney to tell HCD and ABAG that the City of Palo Alto refuses to go along illegal misuse. We demand the opportunity to participate in the making of these decisions, as mandated by law. Sincerely, PASZ (Palo Altans for Sensible Zoning) Contact: Greg Schmid Palo Alto gregschmid@sbcgobal.net 701-32 DOCUMENTS IN THIS PACKET INCLUDE: LETTERS FROM CITIZENS TO THE MAYOR OR CITY COUNCIL RESPONSES FROM STAFF TO LETTERS FROM CITIZENS ITEMS FROM MAYOR AND COUNCIL MEMBERS ITEMS FROM OTHER COMMITTEES AND AGENCIES ITEMS FROM CITY, COUNTY, STATE, AND REGIONAL AGENCIES Prepared for: 06/01/2021 Document dates: 05/12/2021 – 05/19/2021 Set 4 Note: Documents for every category may not have been received for packet reproduction in a given week. 2 Baumb, Nelly From:Patty Irish <irishpw@gmail.com> Sent:Tuesday, May 18, 2021 11:38 AM To:Council, City Subject:Affordable housing in Palo Alto CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Palo Alto needs to build more affordable housing for the many people who work here but cannot afford to live here.    It adds to the richness of our community to have residents who are in lower paying jobs.   I live at Channing House where we have 125 employees. They are nurses, maintenence workers, dining and  housekeeping. Many have worked here over 10 years. People like them need to have the opportunity to live here.   Please work with affordable housing experts to plan ways to achieve this for our city.   Thank you,   Patty Irish     850 Webster #628  Palo Alto, CA 94301  650 324 7407  650 245 3906 cell        3 Baumb, Nelly From:Gina Dalma <gina@dalma.org> Sent:Tuesday, May 18, 2021 10:22 AM To:Council, City Subject:Today. Several questions for you. CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Dear Mayor DuBois and Palo Alto City Council,  I am so glad that you proclaimed this month ‐ as Affordable Housing Month‐ and calling our community to support  housing for everyone. The question is now, what will you do to turn words into action. I ‐ and many of our community  members believe that having a home is a human right. Big or small.  Fancy or not. A home that provides shelter and a  place to thrive. The more we intentionally make this a reality for our diverse community ‐ the more we will have a  vibrant and inclusive Palo Alto. We must demonstrate a willingness to meet our affordable housing needs.  Unfortunately, so far in 2021, the Palo Alto City Council has taken a number of steps which are detrimental to affordable  housing (new affordable and below  market rate homes), and the question is why.    You disproportionately increased impact fees for multi‐family housing projects from $5,557/unit to $47,707/unit (over  850%) ‐ why?  You limited the Planned Home Zone applications and restricted new affordable housing proposals on single family lots  (This action limited the possibility of even  hearing about innovative housing proposals) ‐ why?  You signaled non‐support or created roadblocks for housing project proposals (all including below market rate homes)  totalling almost 600 needed housing units ‐ why?  Don't you want  more economic diversity in our community, shorter commutes for essential workers, to support  sustainability goals, and help the region reduce homelessness and overcrowding in existing units?    Kindly,    ‐‐   Gina D. Dalma  e: gina@dalma.org   p: (980) 722.2660  t: @ginadalma  l: www.linkedin.com/pub/gina‐dalma/0/53/b47/en  4 Baumb, Nelly From:Gail Price <gail.price3@gmail.com> Sent:Monday, May 17, 2021 10:08 PM To:james.eggers@sierraclub.org Cc:Council, City; Planning Commission; Gail Price Subject:Letter to Sierra Club and cc: Palo Alto City Council. Praising letter supporting In-fill Housing and link to Climate Change CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.      May 17, 2021 Mr. James Eggers Executive Director Sierra Club : Loma Prieta Chapter Dear Mr. Eggers, Palo Alto Forward would like to commend you for your strong letter of 4/29/21 to Mayor DuBois and Palo Alto City Council Members regarding the lack of sufficient affordable housing in our community and the importance of infill-housing as a means to address documented climate change, sustainability, and environmental goals. It was a needed statement reiterating the importance of infill-housing as a documented means of reducing our carbon footprint and green house gas emissions. You reiterated the importance and value of infill-housing, especially adjacent to transit and jobs, and its importance to creating inclusive communities. The Sierra Club Board of Directors’ adopted Urban Infill Policy is exemplary. It reads: The Sierra Club believes affordable house is a human right. Further, all neighborhoods should be open to people of all income levels and backgrounds. As you further noted, the City’s history of not approving and building enough housing is well known; by the end of 2019, the City of Palo Alto has met only about 25% of our RHNA assigned housing totals. Housing adjacent to transit is especially critical. The jobs-housing imbalance continues to exacerbate traffic congestion, parking demand, air pollution and respiratory impacts. Addressing these impacts would also decrease our carbon footprint. The lack of housing supply for workers of various incomes drives up rental and housing prices and directly impacts the recruitment and retention of restaurant, hotel and service industry public sector workers. We could not agree more that “If Palo Alto wants to continue to be seen as a champion of climate action and positive social change, it needs to be more flexible in the types of housing it allows in many of its neighborhoods.” Your stated position on this issue is important to the thoughtful and comprehensive discussion of climate change problems and ways to make a difference. I hope you will continue to speak up on these issues in partnership with other community members, environmental and housing advocates. It’s needed. Sincerely Gail A. Price President, Palo Alto Forward Cc: Mayor DuBois and Palo Alto City Council Members 5 Baumb, Nelly From:Nancy Martin <nancy.martin@mac.com> Sent:Monday, May 17, 2021 11:53 AM To:Council, City Subject:Stop the madness CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear Palo Alto City Council,    You would be hard‐pressed to find anyone in our city who wants the massive housing growth being forced upon us by  the state. The only approving voices for this excessive development would be those of the developers, who stand to  make millions from this horrendous proposal and most do not even live in city of Palo Alto.    You represent OUR voice, not theirs, so we ask that the city attorney and all of you STOP the HCD /ABAG process today  so the people who elected you to represent them can actively participate in the decision that affects their future and  that of their families.    If stopping is not an option, please respond with your explanation.    We thank you for your service and know you’ll do the right thing and allowing us to work with you for a controlled  growth that takes our infrastructure into consideration as well as our quality of life.    Thank you,  Nancy Martin        .  1 Baumb, Nelly From:Jeff Hoel <jeff_hoel@yahoo.com> Sent:Tuesday, May 18, 2021 12:17 PM To:Council, City Cc:Hoel, Jeff (external); UAC Subject:COMMENTS -- 05-24-21 staff report on Fiber Network Expansion Project (including FTTP) CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Council Members and UAC Commissioners, On 05-24-21, Council will consider an item about the Fiber Network Expansion Project (including FTTP). Agenda: https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/city-council-agendas- minutes/2021/05-24-21-ccm-agenda.pdf Staff report (14 pages): https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/reports/city-manager-reports-cmrs/2021/id- 12117.pdf Please see detailed comments below the "######" line. GENERAL COMMENTS: ### UAC recommended that Council not consider public-private partnerships going forward, but the staff report continues to talk about them. Why? ### To me, the most important point disclosed at UAC's 04-21-21 meeting is that citywide municipal FTTP could be financially successful if it got a take rate of 24 percent. And that most municipal FTTP networks actually get a take rate of more like 40 percent. ### Since citywide municipal FTTP is affordable, I think it's the best network to use not only for FTTP but also for other uses, such as AMI, SCADA, etc. Thanks. Jeff =================== Jeff Hoel 731 Colorado Avenue Palo Alto, CA 94303 =================== ############################################################################################# COMMENTS: --- page 1 --- --- page 2 --- 2. Establish City-operated ISP model providing FTTH service within five years. ### UAC didn't really question staff's estimate that it would take 5 years. Council should ask staff about that. Other municipalities, e.g., Longmont, CO, took more like 3 years. 2 ### UAC said the municipal FTTP network should be citywide. --- page 3 --- The FTTH trial passed 230 homes and included 66 participants in the Community Center neighborhood. ### The FTTH Trial did NOT "pass" 230 homes." In order to "pass" a premises, you have to provide the infrastructure necessary to "connect" to the premises easily in the future. --- page 4 --- --- page 5 --- --- page 6 --- --- page 7 --- --- page 8 --- ▪ Full buildout to 100% of homes in the City ### This means 100% of homes and businesses in the City will be "passed," but a premises will be connected only if the premises takes service. --- page 9 --- --- page 10 --- --- page 11 --- Comcast reports 100% homes passed in Palo Alto using Cable based broadband. ### It's not really 100%. For example, at the 08-05-20 UAC meeting, the Palo Alto Hills Broadband Working Group said Comcast was not available in their neighborhood. https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2020/08-05-2020-special/final-uac-minutes-august-5- 2020.pdf ### Comcast's HFC product offers at most "up to" 1 Gbps down and "up to" 35 Mbps up. If the FCC changes the definition of "broadband" to "at least 100 Mbps down and 100 Mbps up," Comcast's HFC product won't even be broadband. AT&T reports up to 28% FTTH availability within Palo Alto. ### BroadbandNow says, based on Form 477 data AT&T reported to the FCC, that in 28.2 percent of Palo Alto's census blocks, at least one home had access to AT&T Fiber. https://broadbandnow.com/California/Palo-Alto Both AT&T and Comcast offer up to 1 Gigabytes download speeds ### Not true. Both AT&T Fiber and Comcast offer download speeds of "up to" 1 gigabit per second (not 1 gigabyte per second, which would be 8 gigabits per second). and up to 25% upload speeds. ### I suppose this means "up to" 25 Mbps upload speeds. Comcast’s strong suit is its use of DOCSIS.1, a technology that allows them to serve customers over conventional copper wire at fiber speed, but a reduced operational cost to the carrier. 3 ### I believe Comcast is using DOCSIS 3.1 technology in Palo Alto. (There has never been a DOCSIS.1 technology. DOCSIS 1.0 technology is ancient.) https://en.wikipedia.org/wiki/DOCSIS ### DOCSIS 3.1 technology uses coax cable (not "conventional copper wire") to connect to premises. By national standards, Palo Alto is well served by AT&T and Comcast .... ### What exactly are these "national standards"? In any case, there's no reason Palo Alto has to be limited by "national standards." 1 Baumb, Nelly From:Ginnie Noh <ginniecaselli@msn.com> Sent:Monday, May 17, 2021 6:13 PM To:Council, City Cc:Mesterhazy, Rosie; Bimpson, K; Jennifer DiBrienza; daustin@pausd.org Subject:Juana Briones PTA - Budget Cut Concerns CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  TO:      Office of the City Mayor and City Council              250 Hamilton Avenue              Palo Alto, CA 94301                                                          City.Council@cityofpaloalto.org    FROM:  Juana Briones Elementary School PTA    SUBJECT:  Proposed Budget Cuts      Dear Honorable City Council Members:    This letter is from the Juana Briones Elementary School PTA on behalf of the entire Palo Alto community.  We  ask you to re‐consider the reduction of Crossing Guard staff and PAPD Patrol staff, which impacts the  immediate safety to our children and the community as a whole. Stripping away the Crossing Guard safety mechanism for our already vulnerable pedestrians and cyclists is an alarmingly dangerous move.  Commuters in the community are already facing changing bell schedules,  increased traffic, recently changed bike and traffic routes, and over a year of not even physically going to school!  The changing bell schedules will cause an influx of walking and cycling students on our City streets, during times drivers are not accustomed to dealing with them.  The precautions and safety plans that were needed to be in place to get kids back to school post‐Covid need to include getting them there safely. Your current 2022 budget proposal will remove 5 PAPD Patrol positions.  The PAPD Traffic Team is critical to the Juana Briones Community. The avenues and roads that directly cross our school (Los Robles Avenue, Maybell Avenue, and Coulombe Drive) are high traffic bike areas.  The neighboring Arastradero Road is one of the busiest commuter roads in Palo Alto!  Children from the ages of 6 and older ride these lanes to and from Juana Briones Elementary School, Barron Park Elementary School, Fletcher Middle School, and Gunn High School.  It’s nearly  a daily critical mass in Palo Alto. • 4-100 Ormie 'Street., Palo Al~,, C 94306 2 Our very own Juana Briones PTA President had their child hit by a car and run over,  on his way home from  school, which resulted in two broken bones.  We are thankful he is still with us.  We all know other families have not been as lucky.  Palo Alto parents are a tight community, and Juana Briones' parents have called 911 on several occasions when finding children laying on the side of the road bloody, disoriented, in tears, after being hit by a car or just falling off their bike on their way to or from school.  While we need our crossing guards for basic safety, we need our traffic officers for actual compliance, as the streets will be filled again in the 2021 school year.  It is essential for us to keep our kids safe, and not lose one more child to an accident.  Bike lanes and well‐intended committees are not enough. We need a team of professionally trained crossing guards and police who can keep our kids safe.    We urge you to retain full funding for crossing guards.  This is imperative for our children’s safety.  Should you have any questions, concerns, or require additional information, please do not hesitate to reach out to me directly via email at ptajuanabriones@gmail.com.  Thank you for your time.     Sincerely,  Ginnie Noh Ginnie Noh  Juana Briones Elementary School PTA President      cc:  Rosie Mesterhazy (Juana Briones Safe Routes to School Coordinator)         Katy Bimpson (Juana Briones Principal)         Jennifer DiBrienza (Juana Briones School Board Representative)         Dr. Don Austin (PAUSD Superintendent)  3 Baumb, Nelly From:Haluk Konuk <haluk_konuk@yahoo.com> Sent:Monday, May 17, 2021 6:12 PM To:Council, City Subject:Crossing guard budget cut CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Council Member,       I heard that there is a plan to cut the number of crossing guards for our students. Please  note that the safety of our students should be primary in the budget, and the small savings  of about $300k do not justify the sacrifice in safety.       Sincerely,  Haluk Konuk   Palo Alto homeowner and resident since 2007.         Sent from Yahoo Mail for iPhone  4 Baumb, Nelly From:Catherine Reed-Beaudouin <creedfire7@gmail.com> Sent:Monday, May 17, 2021 8:03 PM To:Council, City Subject:Crossing Guards CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear Council Members:    I implore you to preserve the safety and welfare of our children by retaining ALL of the current school Crossing Guard  positions.  Please do not cut the number of school Crossing Guards as part of upcoming budget cuts.    Thank you,  Catherine Reed‐Beaudouin  Parent of two PAUSD students    Sent from my iPhone  5 Baumb, Nelly From:JB <jbegallo@gmail.com> Sent:Monday, May 17, 2021 10:53 PM To:Tanaka, Greg Cc:Council, City Subject:Please stop wasting Palo Alto's time CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Hello Greg,     Despite being on the City Council since 2016, it is clear you do not understand the basic workings of this City. This job is  obviously out of your league and you should let the grown ups handle it. Being moderate, conservative or a fiscal hawk is  one thing, being outsmarted by everyone in the Council and the City staff and not being able to learn simple concepts  after 5 years is not what this City needs. Although you did your homework compared to last year, your "span of control"  analysis was just laughable and an embarrassment.    Please stop wasting Palo Alto's time! Thank you,    Jean‐Baptiste Gallo  6 Baumb, Nelly From:power mac g5 <smayfie14@gmail.com> Sent:Tuesday, May 18, 2021 2:49 PM To:Council, City Subject:Finance Committee, City of Palo Alto CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    My great thanks to Finance Committee Members Pat Burt, Alison Cormack and Eric Filseth for reconsidering cuts in the  2020 budget process for the Palo Alto Art Center during this challenging, fiscal time.The Palo Alto Art Center is a gem on  the San Francisco Peninsula and merits whatever funding may be awarded for its preservation.    Sincerely  Signe Mayfield  Barron Park, CA    7 Baumb, Nelly From:Sue Purdy Pelosi <sueppr@gmail.com> Sent:Wednesday, May 19, 2021 9:55 AM To:Council, City Subject:Completely disagree with funding the Palo Alto history museum CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Please focus on using the least possible to serve the most possible.     I agree with the revised budget under consideration. Our city should fund existing services like fire, police, libraries and  services for youth and elders.      The proposed Palo Alto History Museum will not add any value to those services. The history of Palo Alto is well  documented by a variety of sources. Creating an entire museum is not necessary. I agree that the archives are very  extensive and should be given appropriate storage and access. I also wonder how it will contribute to an accurate  narrative about the ways that ALL of the workers in Silicon Valley were included AND excluded from the companies that  made this area famous. I don’t think our city’s funds should be used to tell the story of a limited number of private ( and  VERY WEALTHY) citizens success.     Thank you     Sue     Sue Purdy ྘ྙྚ Pelosi    Be kind whenever possible. It is always possible.  Dalai Lama      https://www.linkedin.com/in/suepurdypelosi/  8 Baumb, Nelly From:Betty Howell <betty@anderwell.com> Sent:Wednesday, May 19, 2021 10:47 AM To:Council, City Subject:Downtown Library CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council,  We seniors who live downtown in walking distance of 270 Forest Street have been missing our library.  Please be sure  it’s properly funded and now that Palo Alto’s in the yellow tier, encourage it to open.    Hopefully and thanks,  Betty Howell  850 Webster #639  Palo Alto, CA  94301      “Not everything that is faced can be changed,   but nothing can be changed until it is faced.”  —James Baldwin    9 Baumb, Nelly From:Elizabeth Garr <elizabethgarr@gmail.com> Sent:Monday, May 17, 2021 5:30 PM To:Council, City Subject:Please restore the Children's Theater funding! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council members,      I was raised in Palo Alto, and am now raising my own children here.  From when I was a child in the 1970s and 1980s  until now, the Children's Theater has brought magic and light to this community‐‐whether your family participates  onstage, behind the scenes, or as part of the audience.  The Children's Theater is one of those gems that makes Palo Alto  special.  Especially in times like these, we need creativity and arts in our lives.     Please restore the Children's Theater budget in full, so it can continue to bring joy to generations to come.    Thank you.    Sincerely,  Elizabeth Pearson Garr  Hilbar Lane  10 Baumb, Nelly From:Phyllis Smith <binkyblu920@gmail.com> Sent:Monday, May 17, 2021 8:36 AM To:Council, City Subject:Support of Children's Theater CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Please DO NOT cut funding to the Children’s Theater.  It is one of the few theaters that is for children by children.   I have  lived in Palo Alto for over 50 years.  In 5th grade my sons’ school wanted to do a play so we went to the theater and they  came to the school, auditioned students and brought in costumes and sets and that was the beginning of the School  Outreach Program in about 1979.  I was a member of the Friends of the Children’s Theater for many years and my son  worked as a volunteer through high school then after college was hired by the theater to to set design and tech work.  I have seen the impact the funding has had on the theater and has allowed ALL STUDENTS access to participation  regardless of family financial background.    PLEASE support continued funding for the CHILDREN’S THEATER.        Phyllis Smith  920 Boyce Avenue  Palo Alto, CA. 94301    As a side note:  My daughter lives up in Washington on Whidbey Island.  They have a Children’s Theater based on ours  that is a theater for children by children that was established by a Hollywood producer who lived in Palo Alto and moved  to Washington and help establish their theater (which my grandson acts in).  11 Baumb, Nelly From:Kimberley Wong <sheepgirl1@yahoo.com> Sent:Monday, May 17, 2021 4:05 PM To:Council, City; DuBois, Tom; Burt, Patrick; Kou, Lydia; Stone, Greer; Cormack, Alison; Tanaka, Greg; Shikada, Ed; Filseth, Eric (Internal) Subject:Support for the Palo Alto Museum CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Mayor, Vice Mayor and Members of the Palo Alto City Council,    I’m sure you have heard my story before as I have spoken about my family’s history in Palo Alto from the turn of the century. I proudly hail myself as a product of the school system in Palo Alto and active member of my community be it engaging in city issues, neighborhood activism, or connecting others to the rich history of Palo Alto. I write to you again to fully support the development of the Palo Alto Museum in the Roth Building for its important historic and cultural ties to the history of Palo Alto. My grandfather immigrated to Palo Alto in1900 and owned the first legal Palo Alto Chinese-run restaurant, which Dr Lee, founder of PAMF, was a loyal customer! Sam Ying Mock married and had 7 children, including my mom, who were all delivered by Dr. Edith Johnson, the first woman doctor of Palo Alto also known as the "White Angel." She was well known for her work during the 1918 Influenza pandemic. As have experienced another pandemic which has hit us locally and globally, and tested the financial health of our establishments and mental health of our citizens as we had to shelter in place, we had learned about how it is important to work together with our friends, neighbors and even strangers to get through this. During this major disruption of our routines the importance of staying rooted and establishing a stronger community is vital more than ever to the health of our city as we work our way to some sort of normalcy and come back together as a community. I see the building of the Palo Alto History Museum as a community center that will serve as an anchor for us all. It will showcase our stories of this community from its inception as a University town to the growth of Palo Alto as a powerhouse of Silicon Valley to the present. It will help make sense of where we were, how we became, and what we can become through a collection of experiences that we not only share with our community, our children, but the rest of the world. Please I ask for your help to support the History Museum in its vision to become a unique and living experience for all the world to enjoy. Kimberley Wong 3rd generation Palo Altan 12 Baumb, Nelly From:Kathy Chen <kathytchen@gmail.com> Sent:Monday, May 17, 2021 5:51 PM To:Council, City Subject:No cuts to city crossing guards at elementary middle and high schools!! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  As a parent of three active bikers who navigate the streets from our house to Ohlone elementary and Greene Middle  School, reducing the number of crossing guards at intersections is a bad move. They regularly are able to get to and from  school with ease because of the safety provided by crossing guards. Numerous mishaps have been avoided on the  occasions that I've picked with them because of the crossing cards presents. Those short yet busy times of day during  school start an end times must be well protected for our cyclist, pedestrians and increasingly distracted driving parents. I  urge you to please reconsider any cuts to this vital yet small portion of the Palo Alto budget for the upcoming year.  Protected intersections mean more bicyclists and pedestrians and less drivers on our narrow streets!     Signed,    Kathy Thielke Chen parent of three children at Ohlone Elementary and Greene Middle School  1 Baumb, Nelly From:Arlene Goetze <photowrite67@yahoo.com> Sent:Monday, May 17, 2021 3:09 PM To:Council AnswerPoint; info@rokhanna.com Subject:-- F-A-uci--Shots AT CDC Very Low CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Every Friday, VAERS makes public all vaccine injury reports received as specified date, usually about a week prior to the release date. Today’s data show that between Dec. 14, 2020 and May 7, a total of 192,954 total adverse events were reported to VAERS, including 4,057 deaths — an increase of 220 over the previous week — and 17,190 serious injuries, up 1,176 since last week.The Defender, childrenshealthdefense.org May 16, 2021 Dr Fauci admits to Congress 40-50% at CDC do not take a vaccine. NIH and FDA agree with similar rate of refusals. (Many news reports) Past news says 40% of women police refuse 1/3 of caregivers and 1/3 of military refuse vaccines. To help prprivacy, Mprevented download from the In 2 Baumb, Nelly From:Loran Harding <loran.harding@stanfordalumni.org> Sent:Monday, May 17, 2021 3:22 AM To:Loran Harding; alumnipresident@stanford.edu; antonia.tinoco@hsr.ca.gov; David Balakian; fred beyerlein; bballpod; beachrides; Leodies Buchanan; bearwithme1016@att.net; boardmembers; Council, City; Chris Field; Cathy Lewis; Doug Vagim; dennisbalakian; Daniel Zack; Dan Richard; david pomaville; esmeralda.soria@fresno.gov; eappel@stanford.edu; Steven Feinstein; fmerlo@wildelectric.net; francis.collins@nih.gov; grinellelake@yahoo.com; George.Rutherford@ucsf.edu; Gabriel.Ramirez@fresno.gov; huidentalsanmateo; hennessy; Irv Weissman; jerry ruopoli; Joel Stiner; kfsndesk; kwalsh@kmaxtv.com; leager; mthibodeaux@electriclaboratories.com; Mayor; margaret-sasaki@live.com; Mark Standriff; newsdesk; news@fresnobee.com; nick yovino; russ@topperjewelers.com; Steve Wayte; tsheehan; terry; vallesR1969@att.net Subject:Fwd: Dr. John Campbell, Friday, May 14, 2021. UK v. US approach to opening up. CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    ‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐  From: Loran Harding <loran.harding@stanfordalumni.org>  Date: Mon, May 17, 2021 at 2:22 AM  Subject: Fwd: Dr. John Campbell, Friday, May 14, 2021. UK v. US approach to opening up.  To: Loran Harding <loran.harding@stanfordalumni.org>      ‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐  From: Loran Harding <loran.harding@stanfordalumni.org>  Date: Sun, May 16, 2021 at 5:54 PM  Subject: Fwd: Dr. John Campbell, Friday, May 14, 2021. UK v. US approach to opening up.  To: Loran Harding <loran.harding@stanfordalumni.org>      ‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐  From: Loran Harding <loran.harding@stanfordalumni.org>  Date: Sun, May 16, 2021 at 4:59 PM  Subject: Fwd: Dr. John Campbell, Friday, May 14, 2021. UK v. US approach to opening up.  To: Loran Harding <loran.harding@stanfordalumni.org>      ‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐  From: Loran Harding <loran.harding@stanfordalumni.org>  Date: Sun, May 16, 2021 at 12:47 AM  3 Subject: Fwd: Dr. John Campbell, Friday, May 14, 2021. UK v. US approach to opening up.  To: Loran Harding <loran.harding@stanfordalumni.org>      ‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐  From: Loran Harding <loran.harding@stanfordalumni.org>  Date: Sat, May 15, 2021 at 5:14 PM  Subject: Dr. John Campbell, Friday, May 14, 2021. UK v. US approach to opening up.  To: Loran Harding <loran.harding@stanfordalumni.org>          Sunday, May 16, 2021              To all‐             Different rules for the fully vaccinated in the UK v. US.  He says the differences are "interesting". By that, he  probably means "barbaric". He points out the obvious‐ how are businesses etc. in the US  to know which of the  unmasked are fully vaccinated and which are not? How would their customers know? (Me, e.g. Recall, the vaccines are  not 100% effective).  The honor system? In this country?!. You're lucky if you can get your groceries out to the car  without being shot.                 Rule changes for fully vaccinated ‐ YouTube                Dr. Campbell shows results for Ivermectin. Prophylaxis for Covid 19. They love it in India. They know it works. He  said recently that governments around the world should actively consider it. It can save a lot of lives. That would include  the US government, run by bunglers, so don't hold your breath.                             Dr. Campbell on Tuesday, May 11, 2021 in the link below. The horrors in India. Here important medical groups  urge the Indian government to use Ivermectin widely to prevent cases of Covid 19 and to treat mild cases of  it.  Governments around the world should take note of the evidence presented here, he says.                                             He talks a lot about the India variant. The WHO has just now labeled it a "variant of concern". He excoriates  (eviscerates?) them for that. What have they been doing for a month? Over and over we see that the WHO is infested  with bunglers. They probably move back and forth between the WHO and the WH.                 Ivermectin advised for India ‐ YouTube                 The Ivermectin discussion begins here at 8:30. It is very compelling. He is convinced. It is a prophylaxis and a  treatment. It can prevent the infection. Newest recommendation in India is 12 gm per 60 kg of body weight, weekly. It is  a cheap med and has been used by 3.7 bilion people safely. It is an anti‐parasitic. It is antiviral and anti‐inflamatory, what  you want with Covid. We should give it to millions of people in the US who are still not vaccinated and the FDA should  not require a six month, 30,000 person trial of it. Dr. Fauci should weigh in here, after he reads the reports the links to  which Dr. Campbell gives.              KCBS‐SF said tonight that two‐thirds of Californians now have some immunity, i.e., have had at least one shot. They  are saying that 70% vaccinated could be herd immunity. Does that mean both shots?  A doctor at Stanford said tonight  that 90 or 95% would be preferable. The positivity rate in California is now 1%, KCBS said twice. There are today 55 pts.  4 in intensive care for Covid in the SF Bay Area, the lowest number since late May, 2020. The ABC TV  network said on May  14, 2021 that 64% of Americans are not fully vaccinated.               For weeks after the new India variant was identified, the UK allowed unrestricted flights in from India. Now there  are hot spots of the variant in the UK, oddly enough in places where lots of Indians reside. They try to do isolation of  those areas, lots of genomic sequencing.  Some people from India have flown into the Phillipines with the variants. We  have some cases in the US, due to the Biden administration's bungling and lying. We halted flights from India about four  days after the UK halted them there.             What have the Australians done about the horror in India? Draconian actions:  For weeks, they have not let even  their own nationals enter Australia from India. Now they have set up very strict quarantine facilities in northern Australia  for a few to come in. They have one of the lowest infection rates in the world. Until two weeks ago, we were letting  anybody and everybody fly into the US from India. Maybe some self‐isolation. Money talks, I've heard. Indians were  paying big money to get a flight from India to the UK to get in before the announced cut‐off there, Friday, April 30, 2021  at 4AM. They were probably doing that to beat the announced deadline here too, which was the following Tuesday, May  4, 2021.                  After the Ivermectin discussion, Campbell moves on to a fungal infection, mucormycosis, that is a real horror, and  can befall Covid pts. The mold is the mucor mold. If you've run out of things to worry about, watch this, starting at 17:00  in the above link. The fungus causes tissue death, necrosis, and the only treatment is surgery to cut out the dead tissue.  The anti‐inflammatories, steroids, that Covid pts. are given as standard treatment for Covid raise sugar levels, just what  the fungus thrives upon. Steroids also cause immuno‐compromise. If the pts. are diabetic, it is worse. Uncontrolled  diabetes is rampant in India so they fall victim to this. Also, high BS prevents the migration of WBCs to the fungal  infection site to fight the infection. ANY infection raises BS, he says. This typically befalls Covid pts. two weeks after  recovery. The fungal infection is also called "black mold disease".  The mortality rate is 50%, higher without medical  treatment.  Dr. Campbell says he has seen maybe one case of this in his career‐  in the UK I assume he means.               There are not enough surgeons in all of India to treat all of these cases. And to do surgery, one needs O2, and that  is in short supply there.                Let us now hear from Dr. Fauci and the heads of the FDA and CDC about Ivermectin. It should be rolled out now  massively for the unvaccinated, or at least be made available to them. Perhaps made available to those who are vaccine‐ hesitant. Can doctors in the US Rx it as a Covid prophylaxis? The FDA should allow it. Again, 64% of Americans are not  fully vaccinated as of May 14, 2021.                 Note:  As part of my years at Stanford to get the B.A. in Biological Sciences there, I took a course entitled "Algae  and Fungi". It was taught by a famed Biologist there named Dr. Page. His brother was a professor at Stanford too. I saw  this in one class: The black board in front of the class was maybe 30 feet wide. Dr. Page started at the left end and  worked his way to the right hand end with various colors of chalk. He drew and labeled, without notes, maybe 50 or  75  species of algae and fungi. I'll never forget it. Maybe three students in the class remembered what he drew and said.  They would all be famous Biologists now. Dr. Page, as I recall, later died of a massive heart attack, having driven himself  to death.                 But what I am conveying here is that the world of algae and fungi is huge. I took a long, back‐breaking course in it  at Stanford, and we would only have touched on the highlights.                                          L. William Harding                Fresno, Ca.                         6 Baumb, Nelly From:Pc User <pc77user@aol.com> Sent:Sunday, May 16, 2021 11:16 PM To:Council, City; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; Dave Young; Global Research News; Patriots Package; PatriotsWithGuns; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY Subject:genetically engineered Magneto proteins at DuckDuckGo CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    https://duckduckgo.com/?q=genetically+engineered+Magneto+proteins&t=iphone&ia=web      Best Regards, & Stay Healthy, Wealthy & Wise.  RJS  7 Baumb, Nelly 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seguridadinformatica@americamovil.com; infoconfidencial@americamovil.com; privacidad@americamovil.com; clientes@americamovil.com Subject:Fwd: Texas Deep Freeze: Restarting Oil and Gas Will Be an Emissions Mess - Bloomberg CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.          Begin forwarded message:  From: "." <alfaro.nancy@gmail.com>  Date: May 15, 2021 at 10:03:05 PM PDT  To: sbarragan@aristeguinoticias.com, redaccion@aristeguinoticias.com, careyshenkman@riseup.net,  courage.contact@couragefound.org, transportandoamichoacan@live.com,  periodicooficial@michoacan.gob.mx, buzon@poderjudicialmichoacan.gob.mx,  Comercializacion@telesurtv.net, Albinocm6502@gmail.com, JuanJosedelCastillo@gmail.com,  Borderlinebeat@gmail.com, Charropoliticoenvivo@gmail.com, Conexiononline1@hotmail.com,  wells@wsws.org, autoworkers@wsws.org, sep@socialistequality.com, Norissa@socialism2020.org,  joe@socialism2020.org, Christine.s.Richard@gmail.com, Aaron.Greenspan@plainsite.org,  realitycheck@plainsite.org, VeritasTIPS@protonmail.com, richard.clayton@ctwinvestmentgroup.com,  noe.cruz@eluniversal.com.mx, denuncia@eluniversal.com.mx, contacto@eluniversal.com.mx,  atiempomx@gmail.com, indicepolitico@gmail.com, Investigacion@elpais.es, jlsc.ua@gmail.com,  8 WorldsApart@rttv.ru, charles@russia‐insider.com, moderator@russia‐insider.com,  radio@sputniknews.com, mediapartners@sputniknews.com, advertising@sputniknews.com,  media@sputniknews.com  Cc: urgent‐action@ohchr.org, ethicsoffice@who.int, ethicsoffice@un.org, cdhdf@cdhcm.org.mx,  quejas@cdhcm.org.mx, cdhm@tlachinollan.org, aclupreferences@aclu.org,  communications@aclusocal.org, press@ccrjustice.org, info@insyde.org.mx, info@amnistia.org.mx,  carlos.mendoza@amnesty.org, duncan.tucker@amnesty.org, daniella.gac@ulagos.cl,  tribunalpazecuador@yahoo.com, Victor.cabezas@estud.usfq.edu.ec, asuntoscorporativos@clarochile.cl,  marcel.theza@ulagos.cl, aorozco@utla.net, albert.lowe@utla.net, acaputopearl@utla.net,  alau@utla.net, Management@usfca.edu, silvanoaureoles@michoacan.gob.mx,  Marco.Lagunas@cocotra.michoacan.gob.mx, manuel.valencia@cocotra.michoacan.gob.mx,  Transparecia@cocotra.michoacan.gob.mx, FOM.2@hotmail.com, tribuno_alfa@hotmail.com,  gobiernodemorelia@morelia.gob.mx, GobiernoMichoacan2.0@gmail.com,  transparenciamorelia@morelia.gob.mx, Fiscal@morelia.fiscaliamichoacan.gob.mx,  fiscalgeneral@fiscaliamichoacan.gob.mx, pgjecomsoc@michoacan.gob.mx,  sectec.despacho@michoacan.gob.mx, sectec_segob@michoacan.gob.mx,  denuncialosaqui@ssedomex.gob.mx, denuncia.regulacionsanitaria@edomex.gob.mx,  Glozano@queretaro.gob.mx, Sedesu@queretaro.gob.mx, rebelcapitaladvisors@gmail.com  Subject: Fwd: Texas Deep Freeze: Restarting Oil and Gas Will Be an Emissions Mess ‐ Bloomberg           Thomas Flannery (EY, Sr. Audit Partner)   Co‐leader, Americas Wealth and Asset Management, EY Boston    This is Email 4 out four emails sent on May 8, 2021 to the same group shown in the email  below. The Email distribution list at the end of this email trail was added  on May 12, 2021, the day I  intended to forward the four emails below. Today is the first day I was able to start forwarding it .  When anyone receives it,is a separate matter.      First Email (1/4)  Cyberattack Forces Shutdown Of Largest Gasoline Pipeline In United States | ZeroHedge    Second Email (2/4)  Illicit Financial Flows, Trade Misinvoicing, and Multinational Tax Avoidance: The Same or Different? ‐ EY‐ Wal‐Mart as an model ‐    Third Email 3 (3/4)  Fwd: Lights Out For Indian Point As NYC Sources More Fossil Fuels For Power Generation | ZeroHedge    Fourth Email 4 (4/4)  Fwd: Texas Deep Freeze: Restarting Oil and Gas Will Be an Emissions Mess ‐ Bloomberg        Begin forwarded message:  From: "." <alfaro.nancy@gmail.com>  Date: May 9, 2021 at 4:26:56 AM PDT  To: thomas.flannery@ey.com, tfflannery@gmail.com, susan.cote@ey.com,  susan.rothfels@uk.ey.com, tracy.koh@my.ey.com, kelly.musmanno@ey.com,  9 Alexis.Lucas@ey.com, kathryn.tominovich@ey.com, carmine.disibio@ey.com,  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comsegsocial@senado.gob.mx, crpp@senado.gob.mx,  seguridadpublica@senado.gob.mx, seguridad.nacional@diputados.gob.mx,  defensanacional@senado.gob.mx  Subject: Texas Deep Freeze: Restarting Oil and Gas Will Be an Emissions Mess ‐  Bloomberg        Thomas Flannery (EY, Sr. Audit Partner)   Co‐leader, Americas Wealth and Asset Management, EY Boston    With a little of knowledge of atoms electric charges, physics and weather patters one  can play pool with a laser beam and atoms in the atmosphere. With these basic facts  (which I learned In elementary school) I can hit atoms in the wind currents in the  Ecuador and make them blow in any direction I want to create extreme weather  conditions for any reason.  Its called an Extreme weather Event. The technology exists  since around the 1970s. Ask Sarah Palin in Alaska what toys she has out there.    What do Climate Change Agenda parrots have to say about the actual environmental  impact if the methane emissions resulting from the Extreme Weather Event in Texas,  which shut down oil and gas plants, exposing the clean energy scam of wind farms and  solar in Texas in February 2021. Offshore wind farms were on sale right after Texas was  frozen according to Bloomberg.   10   Toyota moved its enormous complex in Torrence, CA (near Herbalife), located a few  miles south Los Angeles Airport to Texas. As a car company, I would know I depend on  oil and gasoline and would rush to be in the same local ecosystem as oil, gas and petro‐ chemical plants. Staying in CA to wait and see what horror show goes on looney‐toon  land where BigTech and Silicon Valley think Tesla is worth the entire Auto  industry.  Apple thinks its going to turn itself from a phone into a Car company or that it  is the oil industry because it owns oil shares.  BigTech such as Amazon, Google,  Microsoft own oil shares.  Why do the BigTech own oil shares for? What about Climate  Change?     Just ban all plastics ‐ Petrochemicals, from Car components  and plastic food containers  being deliver by Amazon Prime Service and Wal‐Marts food delivery service. As the elite  Public Accountant, I  am  100% sure that making people pay for bags at the grocery  stores  and eliminating straws but leaving the entire plastic cup behind wasn't about  Climate Change but cutting expenses (no straws) and earning  "revenues" from charging  bag fees. Typical Accounting trick.     When Americans get worried about the environment,  they would stop cutting the  forests every year just buy a fresh tree for a Christmas decoration, which is trashed a  couple of weeks later. Trees take years to grow not 12 months. Trees take in Carbon  dioxide from the environment and return Oxygen back to environment. Solution:  Reforestation.      https://www.bloomberg.com/news/articles/2021‐02‐21/texas‐deep‐freeze‐restarting‐ oil‐and‐gas‐will‐be‐an‐emissions‐mess     Restarting Texas’s Frozen Energy Heartland Will Be a Climate Mess Turning petrochemical plants off and on again requires flaring and other large sources of pollution Eric Roston To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. Like a cold-blooded animal—a lizard or a snake—the petrochemical hub that is the state of Texas went dormant during the deep freeze. Eventually, it’ll wake up again, and when it does the damage will be worse than if it never went to sleep. Filings submitted in recent days to the Texas Commission on Environmental Quality, or TCEQ, already show significant emissions 11 related to stopping and restarting fossil fuel infrastructure. It’s an indication of what’s to come in a state that’s home to a quarter of U.S. natural gas production as well as half the oil production. An Exxon Mobil Corp. ethylene plant in Baytown, one of the world's biggest, reported the release of nearly a ton of the carcinogen benzene and 34 tons of carbon monoxide, which contributes to air pollution. Shutting off Valero Energy Corp.’s Port Arthur Refinery resulted in the release of more than 2 tons of sulfur dioxide, another pollutant. Events at two facilities belonging to Pioneer Natural Resources Co. led to the escape of more than 12 tons of natural gas; methane, main component of natural gas, has many times the global warming potential of carbon dioxide. “This is an environmental disaster on top of a public safety and human health disaster,” said Luke Metzger, executive director of Environment Texas, an advocacy group. To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.U.S. Gas Futures Fluctuate As Energy Crisis in Texas Eases A Cheniere Energy Inc. facility in Portland, Texas, on Feb. 19. Photographer: Eddie Seal/Bloomberg Refineries must flare off or otherwise release trapped pockets of gas when starting up or shutting down. While weather-based shutdowns are often unavoidable and done in the interest of safety, they can result in emissions that go far above allowable levels. “These events are not exempt from pollution laws,” Metzger said. “It’s likely the events at these facilities could have been avoided.” Read More: After Texas Crisis, Biden’s Climate Plan Hangs on Fragile Power Grid Exxon spokesman Todd Spitler emphasized that the shutdowns were due to the freezing weather and curtailment of natural gas supplies. “Any units that remain in operation are dedicated to exporting electricity back into the grid,” he said. Representatives from Valero didn’t respond to a request for comment; a spokesperson for Pioneer declined to comment. 12 This is the second time in less than six months the Texas oil industry has dealt with mass shutdowns due to extreme weather. The 12 hours after Hurricane Laura hit Port Arthur in August saw the release of more than 2,000 tons of emissions. “I expect the oil industry is going to have numerous problems restarting, similar to what they encounter after a hurricane, such as damaged cooling towers and other equipment,” said Andy Lipow, president of Lipow Oil Associates in Houston. “The industry also has to be wary of water freezing and cracking pipes, which could release hydrocarbons into the atmosphere and cause an explosion and fires.” As of Monday, at least seven Texas refineries were attempting to restart; all of them sustained some weather-related damage, and some still lacked sufficient power to begin the process. More challenges will likely emerge in the coming days, and it may take a few weeks for operations to return to normal. The heightened risk of explosions are a grim reminder of what followed the onslaught of Hurricane Harvey in 2017. Floods at an Arkema SA chemical plant about 25 miles east of Houston knocked the refrigeration system offline, which imperiled the facility’s store of heat- sensitive organic peroxides. People living within 1.5 miles of the facility evacuated a day before trailers holding the chemicals “spontaneously combusted,” according to a Chemical Safety Board investigation. Arkema did not respond to questions. The full scope of pollution from restarting petrochemical facilities following the freeze won't be clear until next month. Companies must file final reports within two weeks, and TCEQ evaluates the disclosures against its rules governing emissions. TCEQ is responsible for both the state’s air and water, the latter of which is also a concern for leadership. “We’ll examine what worked, what didn’t work so well, and what we can do to make things better next time—or, better yet, prevent it from happening again,” said Toby Baker, the agency’s executive director. Environmentalists fault the state’s political leadership and oversight agencies with extending the industry too much leeway, potentially 13 endangering people and property as a result. They’re also concerned that this week’s failures won’t be properly investigated to document their causes. The state regulatory agencies’ approach “means we aren’t going to find out because they’re aren’t going to look,” said Sharon Wilson, Texas organizer for Earthworks, an environmental nonprofit. “We have no reason to believe that they’re going to try to find the pollution fallout from this extreme weather.” — With assistance by Kevin Crowley (Adds new ninth paragraph describing attempts to restart refineries.) Before it's here, it's on the Bloomberg Terminal. 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FairHousing@usdoj.gov, Voting.Section@usdoj.gov, commandcenter@doj.ca.gov,  keeperofrecords@doj.ca.gov, recordreview@doj.ca.gov    OIGcompl@lapd.online, dale.bonner@lapd.online, n4967@lapd.lacity.org, N5449@lapd.online,  n6220@lapd.online, n4964@lapd.online, bopc@lapd.online, lapdcms@lapd.online,  bopcuseofforcepolicy@lapd.online, calganginput@lapd.online, communityrelationsoig@lacity.org,  16 contact.lapdonline@gmail.com, ethics.commission@lacity.org, info@santamonica.gov,  info@asp.arkansas.gov, sfpd.commission@sfgov.org, sfdpa@sfgov.org,     LASERS.services@lacers.org, erb@lacity.org, info@insyde.org.mx, pra@calbar.ca.gov,  clientsecurityfund@calbar.ca.gov, manager@cityofberkeley.info, kworthington@cityofberkeley.info,  BARcomm@calbar.ca.gov,     Mayor.Garcetti@lacity.org, Mayor@fresno.gov, Daniel.Zack@fresno.gov, Mark.Standriff@fresno.gov,  Esmeralda.Soria@fresno.gov, Paul.Caprioglio@fresno.gov, Robert.Andersen@fresno.gov,  Leager@fresnoedc.com, City.Council@cityofpaloalto.org, OfficeoftheCIO@cityofpaloalto.org,  TomforCouncil@gmail.com, Judy.Ng@cityofpaloalto.org, LydiaKou@cityofpaloalto.org,  Kane@cityofpaloalto.org, David.Carnahan@cityofpaloalto.org, Stephanie.Douglas@cityofpaloalto.org,  Albert.Yang@cityofpaloalto.org, Raj.Patel@cityofpaloalto.org, Tom.Auzenne@cityofpaloalto.org    Assesor@sfgov.org, Arun.Bhatia@sfdwp.org, Board.of.Supervisors@sfgov.org,  Commissions.Secretary@sfgov.org, Sotf@sfgov.org, Ethics.Commission@sfgov.org,  glambing@fppc.ca.gov, CommAssist@fppc.ca.gov, Advice@fppc.ca.gov, Cpra@fppc.ca.gov,  CHackert@fppc.ca.gov, Bridget.Hicks@sfgov.org, JFleming@metricus.net, Jreichental@gmail.com,  jreichental@hotmail.com, Treichental@hotmail.com, Complaint@fppc.ca.gov, Hatchact@osc.gov,  Lobby@sec.senate.gov, LobbyInfo@mail.house.gov, OIG@fec.gov, Pubrec@fec.gov,  StateInfo@state.ca.gov, Secretary.Padilla@sos.ca.gov, WPEAOmbuds@stateoig.gov, DCA@dca.ca.gov,  Kimberly.Kirchmeyer@dca.ca.gov, Alexis.Podesta@dca.ca.gov, SIUMailbox@scif.com,  Enforcement@cslb.ca.gov, Classifications@cslb.ca.gov, Licensing@cslb.ca.gov, Info@cslb.ca.gov,  Sheila.Daniels@cba.ca.gov, Enforcementinfo@cba.ca.gov, ComplianceUnit@cba.ca.gov,  CitationsUnit@cba.ca.gov, patti.bowers@cba.ca.gov, deanne.pearce@cba.ca.gov,  nooshin.movassaghi@cba.ca.gov, oponline@nysed.gov, OldInetInfo@dos.ny.gov, OPDPLS@nysed.gov,  CommitteeMeetings@scif.com, BoardofDirectors@scif.com,hbpadua@scif.com    Silvanoaureoles@michoacan.gob.mx, Marco.lagunas@cocotra.michoacan.gob.mx,  Manuel.valencia@cocotra.michoacan.gob.mx, Transparecia@cocotra.michoacan.gob.mx,  FOM.2@hotmail.com, Tribuno_alfa@hotmail.com, Gobiernodemorelia@morelia.gob.mx,  GobiernoMichoacan2.0@gmail.com, Transparenciamorelia@morelia.gob.mx,  FISCAL@morelia.fiscaliamichoacan.gob.mx, FiscalGeneral@fiscaliamichoacan.gob.mx,  PGJecomsoc@michoacan.gob.mx, Sectec.despacho@michoacan.gob.mx,  Sectec_segob@michoacan.gob.mx, Denuncialosaqui@ssedomex.gob.mx,  Denuncia.regulacionsanitaria@edomex.gob.mx, Glozano@queretaro.gob.mx,  Sedesu@queretaro.gob.mx    Contacto@senadomorena.com, SINDICATO@senado.gob.mx,  SINDICATO969.transparencia@senado.gob.mx, Gobernacion@senado.gob.mx,  Transparecia@senado.gob.mx, puntosconstitucionales@senado.gob.mx,  derechoshumanos@senado.gob.mx, Anticorrupcion@senado.gob.mx, hacienda@senado.gob.mx,  Justicia@senado.gob.mx, Marina@senado.gob.mx, webmaster@semar.gob.mx, cni@cni.gob.mx,  asuntosindigenas@senado.gob.mx, ninezyadolescencia@senado.gob.mx, Economia@senado.gob.mx,  Salud@senado.gob.mx, Educacion@senado.gob.mx, Trabajoyprevision@senado.gob.mx,  reformaagraria@senado.gob.mx, agriculturayganaderia@senado.gob.mx, energia@senado.gob.mx,  comunicacionesytransportes@senado.gob.mx, asuntosfronterizos@senado.gob.mx,  comsegsocial@senado.gob.mx, crpp@senado.gob.mx, seguridadpublica@senado.gob.mx,  seguridad.nacional@diputados.gob.mx, Defensanacional@senado.gob.mx,  derechos.arco@funcionpublica.gob.mx, carmina.jasso@sociales.unam.mx,  alternativedevelopment@unodc.org, cristobal.arias@senado.gob.mx,  alejandro.gonzalezy@senado.gob.mx, nestora.salgado@senado.gob.mx, ruben.rocha@senado.gob.mx,  17 felix.salgado@senado.gob.mx, lcalderonh@senado.gob.mx, webmaster@congreso.gob.mx,  secretaria_direccion@centroprodh.org.mx, defensa@centroprodh.org.mx,  educacion@centroprodh.org.mx, comunicacion@centroprodh.org.mx,  administracion@centroprodh.org.mx, desarrollo2@centroprodh.org.mx,  internacional@centroprodh.org.mx, crmichoa@pfp.gob.mx, csmoreli@pfp.gob.mx,  cslazaro@pfp.gob.mx, cspiedad@pfp.gob.mx, crguadal@pfp.gob.mx, cdguzman@pfp.gob.mx,  cstepati@pfp.gob.mx, csatlaco@pfp.gob.mx, sumit2006@gmail.com, ed‐del‐rev@nic.in,  molegangwar@yahoo.com, secy‐labour@nic.in, farida.samsul@gov.in, igkonwar.acs@assam.gov.in,  bopb1.clb@nic.in, registrar‐mum@nclt.gov.in, secretary@nclt.gov.in, registrar.jpr@nclt.gov.in,  response‐nis@pib.gov.in    FRAUD@insurance.ca.gov, Ombudsman@insurance.ca.gov, CAB‐SF‐Intake@insurance.ca.gov,  ElectronicSubmissionFD‐1@insurance.ca.gov, pushpa.uttamchandani@insurance.ca.gov,  RECRUITMENT@insurance.ca.gov, RSBCovid19PR@insurance.ca.gov,  CustodianofRecords@insurance.ca.gov, StateFarmfireClaims@statefarm.com, Privacy@statefarm.com    Ethics.Officers@jll.com, Laura.Locks@lasalle.com, John.Carlson@lasalle.com, klynch@icsla.us,  S.Mercer@festivalcos.com, T.Killeen@festivalcos.com, D.Whitt@festivalcos.com,  S.Brown@festivalcos.com, F.Insurance@festivalcos.com, Celia.shibata.iyhc@statefarm.com,  Nicole.HillSmidt@roberthalf.com, Samantha.figueroa@roberthalf.com, sherri.agganis@rhmr.com,  anjali.chandel@rhmr.com, chelsea.jongewaard@rhmr.com, julia.person@roberthalf.com,  carmen.romero‐eberle@roberthalf.com, tony.uyehara@roberthalf.com,  zoya.naumchik@roberthalf.com, tala.moussouras@roberthalf.com, cawagenotice@roberthalf.com,  pay.timereporting@roberthalf.com, OnlineTimeReporting@roberthalf.com, quality.manager@rhi.com    SMangum@smwb.com, JRobb@smwb.com, jsweeney@smwb.com, rmason@smwb.com,  sschmidt@smwb.com, colson@smwb.com, kwilson@smwb.com, REB@smwb.com,  wkaufman@smwb.com, dlee@smwb.com, rthomson@smwb.com, LLGinn@smwb.com,  TJacobson@smwb.com, lbalke@smwb.com, WStanger@smwb.com, Parul@giulianiconstruction.com,  Vince@giulianiconstruction.com, Tiffany@giulianiconstruction.com,  Antoinette@giulianiconstruction.com, Ashley@giulianiconstruction.com, AR@giulianiconstruction.com,  Claudia@giulianiconstruction.com, Erik@giulianiconstruction.com, SLG@sghoalaw.com,  TMiller@constructionsdefects.com, Sara@constructiondefects.com, Sbrown@constructiondefects.com,  Linda@constructiondefects.com, Rachel@constructiondefects.com, Joseph@constructiondefects.com,  State@constructiondefects.com, Asha@constructiondefects.com, EHillier@washblaw.com,  THones@washblaw.com, Jknight@berdingweil.com, Cthomas@berdingweil.com,  Lolona@berdingweil.com, Bhirsch@berdingweil.com, Tnocco@berdingweil.com, Kpolk@cahill‐sf.com,  JPalmer@cahill‐sf.com, Rmartini@cahill‐sf.com, Aelizabethcostello@gmail.com,  Donklingbeil@gmail.com, Arun.Bhatia@sfdwp.org, Ngueylay@gmail.com,     CynthiaC@partnerscm.com, CarmenH@partnerscm.com, Karolo@partnerscm.com,  RebCohen999@sbcglobal.net, Kathlineking@yahoo.com, Cbretzin@gmail.com,  Cristin.morneau@gmail.com, Rebelcapitaladvisors@gmail.com, Maddydominick@hotmail.com,  HHW7878@yahoo.com, KristyandAlvin@gmail.com, kyle.algeo@gmail.com, Balog@climbsf.com,  Kevans@gmail.com, renee@hrhrealestate.com, Steven.Sheh@gmail.com,  Steven.sheh.300ivy@gmail.com, Cathy.edwards@gmail.com, Cathy300ivy@gmail.com,  Ariel_zach@yahoo.com, Sabrina.300ivy@gmail.com, Michele.300ivy@gmail.com,  300ivy305@gmail.com, William.e.russell.jr@gmail.com, Larrykern300@gmail.com,  KRISTYWEN@gmail.com, Audreycervantez15@gmail.com, Amanda.cifarelli@gmail.com,  Aditi.joshi34@gmail.com, Atishay.jain89@gmail.com, alankarchang@gmail.com,  alexandraliss@gmail.com, alinashah@gmail.com, achiu7@gmail.com, ann.lutzker@gmail.com,  anna.kolontyrsky@gmail.com, alehr1723@gmail.com, avnish.sabharwal@gmail.com,  18 Natalie.choy@gmail.com, Benchoy@gmail.com, Blake.m.osborn@gmail.com, bty200@gmail.com,  Brenns10@gmail.com, Cairokim@gmail.com, Clairekjackson@gmail.com, cxie08@gmail.com,  ctstraub@gmail.com, Crbarry17@gmail.com, ctunno@gmail.com, cyinglee44@gmail.com,  Danoosh.kapadia@gmail.com, Davelu@gmail.com, Davidsha@gmail.com, dygandcompany@gmail.com,  Eleanorlee@gmail.com, Erin.pettigrew@gmail.com, Gracezwho1@gmail.com, Hanshc@gmail.com,  jjstern14@gmail.com, Jacquelinefurrier@gmail.com, Jamison.fox@gmail.com, jasonpkriese@gmail.com,  jasonmok@gmail.com, jpcolaco1@gmail.com, jefferyhungsf@gmail.com, jslee7765@gmail.com,  jwheywood@gmail.com, jambajoyce@gmail.com, kalynyang@gmail.com, KHSU0720@gmail.com,  k8battles@gmail.com, kkoning5514@gmail.com, kihopkins@gmail.com, kunalakumar@gmail.com,  Laura.nelson.ca@gmail.com, Laiboon@gmail.com, leoylee@gmail.com, Markgrossman@gmail.com,  Matthew.fong@gmail.com, mehrdad.mobasher@gmail.com, Miko2005tw@gmail.com,  missyunilee@gmail.com, mina.dresden@gmail.com, Nckiwang@gmail.com, Nihalani.rahul@gmail.com,  Oliviavort@gmail.com, Pearlman.andrew@gmail.com, Rhkreger@gmail.com, radhika513@gmail.com,  radhikac1210@gmail.com, Rosalin49@gmail.com, shehkay@gmail.com, scotter1030@gmail.com,  SHERMEEN.PAVRI@gmail.com, sfchef12@gmail.com, Sirong.liang@gmail.com,  shyla.batliwalla@gmail.com, Spencer.uttley@gmail.com, stcady054@gmail.com, SGLutzker@gmail.com,  Taylormarcus@gmail.com, Tony.h.liu@gmail.com, Tracyc863@gmail.com, Uma105@gmail.com,  Vmalhi@gmail.com, Vyomesh.joshi@gmail.com, Wccheng@gmail.com, Yadathi@gmail.com,  Justchar@outlook.com, Whstuart@googlemail.com, Llazar@google.com, Joykao2000@icloud.com,  Rilely@icloud.com, Alags10@hotmail.com, Carlos_cm86@hotmail.com, Erickjvn@hotmail.com,  lianayingsu@hotmail.com, Maria_chiossi@hotmail.com, numazer@hotmail.com,  smekhalfa@hotmail.com, Aplutino@yahoo.com, al_laxman@yahoo.com, ethankan@yahoo.com,  gauravbhasin@yahoo.com, souhil.zaim@yahoo.com, terichappell@yahoo.com,  UshaTumkur@yahoo.com, tzippi_zach@yahoo.com, Fred.Hsu@3rdstone.ws,  JMoran@parksconservancy.org, David@ellnerconsulting.com, Atidman@mac.com, Vellner@mac.com,  Dennischang@alumni.stanford.edu, Vinodhini.lakshman@ucsf.edu, Brennan.spellacy@sonder.com,  chikodi@moonshotpr.com, ckwan@chokwancpa.com, JSmith@test.com, lauren@edgertons.com,  manonpaquet@live.fr, hillpropmanager@sbcglobal.net, mponce@alse.com.mx, serfriaz@live.com.mx,  William.Livermore@fsresidential.com, Todd.Caniglia@fsresidential.com, Natalie.valdez‐ smith@fsresidential.com, Jeanette.Zamora@fsresidential.com, Marco.Pulido@yahoo.com,  irmavillalobos@hotmail.com, curlysue713@yahoo.com, ramartinez@gmail.com, rapransky@gmail.com,  ms.ra.martinez@gmail.com, Cordon.Lucky@gmail.com, Paoneill@asu.edu, shaoyun925@hotmail.com,  Atsuko_Nakamura@hotmail.com, Paul.Ryan.201@hotmail.com, Hvchowdhary@gmail.com,  Neng1983@gmail.com, Amacrine67@icloud.com, WexlerSecretary@2730wilshire.com,  info@ericwexlermd.com, pialigeti@gmail.com, Geotff@outlook.com, Marcos.f.carrillo@gmail.com,  Victoriav561@gmail.com, Joe.Cicalo@wholefoods.com, Andyperez23@yahoo.com,  Bebelovesbo76@hotmail.com, Tribuno_alfa@hotmail.com, Jessicaflores05@gmail.com,  ymo73@hotmail.com    RecordsAccessOfficer@trs.nyc.ny.us, Investments@ocers.org, CalSTRSCIO@calstrs.com,  Compliance@calstrs.com, Sustainability@calstrs.com, ADACoordinator@calstrs.com,  NewsRoom@calstrs.com, Sbutler@calstrs.com, Crapolla@calstrs.com, WShuckell@calstrs.com,  Stong@calstrs.com, CAilman@calstrs.com, JDiedesch@calstrs.com, Atran@calstrs.com,  mtoepel@calstrs.com, vchitchakkol@ci.irvine.ca.us, vbeatley@sealbeachca.gov,  smontano@newportbeachca.gov, smontano@newportbeach.ca.gov, mmatsumoto@pico‐rivera.org,  Jeremy.Wolfson@ladwp.com, Fiona.Ma@treasurer.ca.gov, Ben.Meng@calpers.ca.gov,  Jason.Perez@calpers.ca.gov, Lisa.Middleton@calpers.ca.gov, Erania.Ortega@calpers.ca.gov,  Mona.PasquilRogers@gov.ca.gov, Mona.PasquilRogers@spb.ca.gov, ajohnson@treasurer.ca.gov,  bfowler@treasurer.ca.gov, bgrajski@treasurer.ca.gov, dallen@treasurer.ca.gov,  dcarrillo@treasurer.ca.gov, dbrown@treasurer.ca.gov, egorman@treasurer.ca.gov,  gpalmertree@treasurer.ca.gov, jwurm@treasurer.ca.gov, jmartinez@treasurer.ca.gov,  jgiordano@treasurer.ca.gov, kjohantgen@treasurer.ca.gov, mpaxson@treasurer.ca.gov,  19 rwebster@treasurer.ca.gov, tconnelly@treasurer.ca.gov, tpaine@treasurer.ca.gov, vau‐ yeung@treasurer.ca.gov, Kselenski@sto.ca.gov, InvestorRelations@treasurer.ca.gov,  Audrey.Noda@treasurer.ca.gov, Christina.SARRON@treasurer.ca.gov, Frank.Ruffino@treasurer.ca.gov,  Frank.Moore@treasurer.ca.gov, Gloria.Li@treasurer.ca.gov, Gloria.Pulido@treasurer.ca.gov,  Genevieve.Jopanda@treasurer.ca.gov, Judith.Blackwell@treasurer.ca.gov,  Jovan.Agee@treasurer.ca.gov, Kristin.Szakaly@treasurer.ca.gov, Kathryn.Asprey@treasurer.ca.gov,  Kasey.O'Connor@treasurer.ca.gov, Mark.Desio@treasurer.ca.gov, Noah.Starr@treasurer.ca.gov,  Robert.Berry@treasurer.ca.gov, Seth.Doulton@treasurer.ca.gov, Tracey.Paine@treasurer.ca.gov,  Tim.Schaefer@treasurer.ca.gov    AuditorGen@paauditor.gov, Budget@pa.gov, RA‐ethicsRTKL@pa.gov, achristman@nelp.org,  bchen@nelp.org, dberkowitz@nelp.org, gwentworth@nelp.org, krole@nelp.org,  Inspectorgeneral@cpsoig.org, Cmoreno@aft.org, BlackwellJ@ctpf.org, ReillyM@ctpf.org,  RedfeairnG@ctpf.org, CavalleroJ@ctpf.org, WardJ@ctpf.org, Jwaddell@aft1521.org,  lmarzillier@aft1521.org, sharonaft1521@gmail.com, lahc1521@gmail.com, parkcj@lacitycollege.edu,  robbdm@piercecollege.edu, mindy@post.harvard.edu, shewfeo@wlac.edu, russeltm@wlac.edu,  coloche@lahc.edu, fenyesm@laccd.edu, lees@lasc.edu, guerrij@lattc.edu, theodore@uic.edu,  gcities@uic.edu, AGREDAFE@elac.edu, JesseSharkey@ctulocal1.org, ChristelWilliams@ctulocal1.org,  MariaMoreno@ctulocal1.org, StacyDavisGates@ctulocal1.org, nmonteiro@mac.com,  drmarcelm@gmail.com, cofercw@gmail.com, jamesmckeever101@gmail.com,  joseph.guerrieri@gmail.com, phoenixmountain2@gmail.com, Zknorr@gmail.com,  Olgashewfelt@gmail.com, mcdowelljr@gmail.com, Pkallen3717@yahoo.com, Kyasuda62@hotmail.com,  rubybrou@hotmail.com, mmoon13956@aol.com, Sandraleephd@aol.com, sufiserf@aol.com,  sanpsych@aol.com, wder@social.rr.com, wdelarton@socal.rr.com    dorkin@oaktreecapital.com, Westcoastorkin@gmail.com, Shaoyun925@hotmail.com,  dkirchheiner@oaktreecap.com, jarnold@oaktreecapital.com, arnoldmd@aol.com,  Lsilva@canyonpartners.com, MCulp@oaktreecapital.com, Losorio@oaktreecapital.com,  NRedington@colonyinc.com, Jplaga@canyonpartners.com, Smansfeld@canyonpartners.com,  Pprak@canyonpartners.com, Lsilva@canyonpartners.com, Mpage@canyonpartners.com,  Dmillman@canyonpartners.com, Purrutia@clearlakecapital.com, Peter.Viles@tcw.com,  Lynn.kalbach@tcw.com, Fiona.huang@twc.com, Lindsey.Lennon@carlyle.com,  Elizabeth.gill@carlyle.com, Irina.Rudnitsky@tcw.com, PRivera@shamrockcap.com,  CPark@shamrockcap.com, AHoward@shamrockcap.com, SRoyer@shamrockcap.com,  LHeld@shamrockcap.com, MDiLorenzo@shamrockcap.com, Rohit.Subramaniam@duffandphelps.com,  Rohit.venkatasubban@gmail.com, investorrelations@marriott.com, IR@invesco.com,  Company.Secretary@invesco.com, Contactus@invescomortgagecapital.com, Patty.Dow@cbre.com,  Bonnie.m.wong@jpmorgan.com, edwin.k‐w.chin@jpmorgan.com, REA_Finance_‐ 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Johnson@barkerpacific.com, Wsueiro@statestreet.com, Nathan@standishmanagement.com,  20 G.hill@standardinvestment.com, Jwurtz@pathfinderfunds.com, George.rupp@carioncapital.com,  anna.marie.lopez@hwcm.com, t.duanne@pefco.com, Ethics.Helpline@wal‐mart.com,  Luis.kolster@walmart.com, Alberto.mora@walmartlegal.com, Rainlay@walmart.com,  inversionistas@walmart.com, mjafern@outlook.com, Jessicaamassey@gmail.com,  claudia.delavega@walmart.com, Gabriela.buenrostro@walmart.com, Mario.Gonzalez@walmart.com,  Jimena.Rodriguez@walmart.com, Adriana.Garza@walmart.com, Mario.González@walmart.com,  miopinion@wal‐mart.com,  donativosenespecie@walmart.com, Juanf.torreslanda@hoganlovells.com,Michael.Mctiernan@hoganlo vells.com, bill.flanagan@hoganlovells.com, richard.climan@hoganlovells.com,  Jaime.espinosa@hoganlovells.com, james.banks@hoganlovells.com, Erin.brady@hoganlovells.com,  maria.durant@hoganlovells.com, tjmckenna@gme‐law.com, gegleston@gme‐law.com,  dkreml@willkie.com, mweinstein@willkie.com, mmottesi@milbank.com, calbarracin@milbank.com,  rgordon@milbank.com, ron@ammonslaw.com, patrick.luff@ammonslaw.com,  miriah@ammonslaw.com, joy@ammonslaw.com, james@epinjury.com, davidglenn@glennlawfirm.com,  jesse@zambranolawfirm.com, edgar@zambranolawfirm.com    InvestorRelations@herbalife.com, Ericm@herbalife.com, CorporateSecretary@herbalife.com,  jlinder@mayerbrown.com, JuliaBa@herbalife.com, HenryW@herbalife.com, julieti@herbalife.com,  octaviomor@herbalife.com, juanfu@herbalife.com, josemic@herbalife.com, RonR@herbalife.com,  ReneT@herbalife.com, liag@herbalife.com, jarrellj@herbalife.com, patti@herbalife.com,  Aimeea@herbalife.com, lisashee@herbalife.com, reinas@herbalife.com, solomonb@herbalife.com,  roxanan@herbalife.com, juliap@herbalife.com, evali@herbalife.com, alinef@herbalife.com,  albertvil@herbalife.com, almao@herbalife.com, natalian@herbalife.com, valeriec@herbalife.com,  shareej@herbalife.com, fredh@herbalife.com, ryanb@herbalife.com, georger@herbalife.com,  bharris@kc.rr.com,  michaelj@herbalife.com, Benjamro@herbalife.com,  rbarbosa@barbosahuerga.com.mx,  ghuerga@barbosahuerga.com.mx, lortiz@ohoabogados.com.mx, ghernandez@ohoabogados.com.mx,  nieto@basham.com.mx, barrera@basham.com.mx, mbarajas@basham.com.mx,  zenteno@basham.com.mx, rswilloughby@pomlaw.com, pdahlstrom@pomlaw.com,  mvl@kerrwagstaffe.com, clune@kerrwagstaffe.com, nabity@kerrwagstaffe.com,  clune@kerrwagstaffe.com, law.west@gmail.com, kprendergast@raiglobal.com,  disputes@raiglobal.com, asmith@raiglobal.com, lisa.strickel@hireright.com, csmail@hireright.com,  Rohit.Subramaniam@duffandphelps.com, Rohit.venkatasubban@gmail.com, Emorton@ycst.com,  jbarry@ycst.com, rbartley@ycst.com, nlabovitz@debevoise.com, jball@debevoise.com,  cabruens@debevoise.com, info@equifaxbreachsettlement.com    jmatty@kpgm.com, inovak@kpmg.com, cneyra@kpmg.com, sjeffery@kpmg.com, kaitlynmoore@kpmg,  joannewilliamson@kpmg.com, Robert.moritz@us.pwc.com, DChrencik@hotmail.com,  Scott.w.tornberg@pwc.com, Tomoko.nagashima@us.pwc.com, Laurie.Endsley@us.pwc.com,  colm.r.kelly@pwc.com, mary.c.monfries@pwc.com, david.j.ryan@us.pwc.com,  anna.tantoco@pwc.com, frank.graziano@pwc.com, scottrhuff@gmail.com, irina.artem@us.pwc.com,  mitra.m.best@us.pwc.com, Kimberley Oloffson/US/ABAS/PwC, Barry P.  Benjamin/US/ABAS/PwC@Americas‐US, Michele L. Godvin/US/ABAS/PwC@Americas‐US, Karen  Stuckey/US/ABAS/PwC@Americas‐US, Derrick T Stiebler/US/ABAS/PwC@Americas‐US, Karen  Sierra/US/HR/PwC@Americas‐US, Kari B Henry/US/HR/PwC@Americas‐US, Richard  Ancona/US/GTS/PwC@Americas‐US    Susan.cote@ey.com, susan.rothfels@uk.ey.com, tracy.koh@my.ey.com, kelly.musmanno@ey.com,  alexis.lucas@ey.com, kathryn.tominovich@ey.com, carmine.disibio@ey.com, Patrick.niemann@ey.com,  thomas.flannery@ey.com, tfflannery@gmail.com, mark.weinberger@uk.ey.com,  michael.serota@ey.com, mark.gutierrez@ey.com, michael.odonnell@ey.com, joost.hendriks@ey.com,  david.cormack@ey.com, jim.mccaulley@ey.com, marc.roberts@ey.com, gabriel.marquez@ey.com,  21 roger.yang@ey.com, sandra.burns@ey.com, gregory.feng@ey.com, greg.glater@ey.com,  david.statman@ey.com, troy.jones@ey.com, allen.freeman@ey.com, keith.lupton@ey.com,  michael.johnson4@ey.com, garrett.behling@ey.com, jason.lin@ey.com, alex.borden@ey.com,  marie.buteauferland@ey.com, mariano.borges@ey.com, cynthia.ding@ey.com, ross.cockrell@ey.com,  jamey.p.johal@ey.com, elliot.kim@ey.com, helen.kim@ey.com, lynn.kim@ey.com,  james.kim1@ey.com, cathy.lai@ey.com, sara.lo@ey.com, franky.low@ey.com, kurt.rieck@ey.com,  michael.mendoza@ey.com, rob.masi@ey.com, marcus.marbrey@ey.com, mongwei.wee@ey.com,  brittney.watson@ey.com, janet.wang@ey.com, chloe.shen@ey.com, shawn.simmons@ey.com,  christopher.kearley@ey.com, kurt.neidhardt@ey.com, edwin.pisani@ey.com, joanne.dunbar@ey.com,  arthur.tully@ey.com, william.schlich@ey.com, alfredo.alvarez@mx.ey.com, oscar.santos@mx.ey.com,  rodrigo.ochoa@mx.ey.com, mario.karim@mx.ey.com, arturo.hernandez@mx.ey.com,  german.vega@mx.ey.com, francis.grab@ey.com, danielle.ryea@ey.com, joon.kim@ca.ey.com,  alan.thom@ca.ey.com, ana.johnson@mx.ey.com, pamela.mable@ey.com, ashley.giles@ey.com,  ben.carter@ey.com, dan.karen@ey.com, zoi.koutsogiannakopoulou@gr.ey.com,  Rohan.Small@ky.ey.com, Jeffrey.Short@ky.ey.com, Dan.Scott@ky.ey.com, Baron.Jacob@ky.ey.com,  Bill.Bailey@bm.ey.com, ashley.horne@ey.com, ey.fsotax@ey.com,  ey.fso.wealthassetmanagement@ey.com, fergus.mcnally@ie.ey.com, sinead.colreavy@ie.ey.com,  donal.osullivan@ie.ey.com, Muntasir.Khaleik@ie.ey.com, Cormac.Kelly@ie.ey.com,  Kieran.Daly@ie.ey.com, souza@ie.ey.com, Fergus.McNally@ie.ey.com, Ailbhe.MacManus@ie.ey.com,  Lisa.Kealy@ie.ey.com, michele.walker@ey.com, brian.mcilhinney@ey.com, brenda.betts@ey.com,  joseph.bianco@ey.com, samer.ojjeh@ey.com, dave.racich@ey.com, robert.mulhall@ey.com,  michael.estock@ey.com, jacqueline.bloom@ey.com, paul.kangail@ey.com,  michael.lee@ey.com, michel.kapulica@ey.com, scott.odahl@ey.com, joseph.n.micallef@ca.ey.com,  fraser.t.whale@ca.ey.com, dan.scott@ky.ey.com, jeffrey.short@ky.ey.com, fatima.de‐windt‐ ferreira@an.ey.com, bryan.irausquin@an.ey.com, christine.jha@ey.com, adrienne.main@ey.com,  matthew.koenig@ey.com, alex.johnson1@ey.com, shaun.real@ey.com, robert.glassman@ey.com,  tiffany.norris@bs.ey.com, jessel.mendes@bm.ey.com, flavio.s.peppe@br.ey.com,  pedro.custodio@br.ey.com, rohan.small@ky.ey.com, mike.mannisto@ky.ey.com,  marchello.gelashvili@ru.ey.com, petr.avramenko@ru.ey.com, ton.daniels@nl.ey.com,  remco.bleijs@nl.ey.com, mauro.iacobucci@it.ey.com, stefano.cattaneo@it.ey.com,  paolo.zucca@it.ey.com, karl.mercieca@mt.ey.com, ronald.attard@mt.ey.com, adam.miller@lu.ey.com,  michael.ferguson@lu.ey.com, helena.noren@se.ey.com, fredrik.stigerud@se.ey.com,  peter.franks@se.ey.com, monserrat.turradoalonso@es.ey.com, roberto.diezcerrato@es.ey.com,  anthony.cadman@za.ey.com, christian.soguel@ch.ey.com, fcarpenter@uk.ey.com,  mprice1@uk.ey.com, jyoung2@uk.ey.com, raitchison@uk.ey.com, ryaad.owodally@mu.ey.com,  daryl.csizmadia@mu.ey.com, matthieu.dautriat@ey‐avocats.com, hermin.hologan@fr.ey.com,  michelle.kotze@ae.ey.com, anthony.osullivan@ae.ey.com, dmoore@uk.ey.com,  ashwani.siotia@bh.ey.com, oliver.heist@de.ey.com, rosheen.dries@de.ey.com, mbane@uk.ey.com,  pduffy@im.ey.com, aegilmore@im.ey.com, jong‐yeol.park@kr.ey.com, jeong‐hun.you@kr.ey.com,  amy.ang@sg.ey.com, matthew.hanley@nz.ey.com, graeme.bennett@nz.ey.com,  kazuhiro.ebina@jp.ey.com, Sameer.gupta@in.ey.com, viren.mehta@in.ey.com, gavin.tang@cn.ey.com,  yeeckle.zhou@cn.ey.com, aj.lim@cn.ey.com, paul.ho@hk.ey.com, george.saffayeh@hk.ey.com,  antoinette.elias@au.ey.com, rohit.khanna@au.ey.com, jon.pye@au.ey.com    groa@deloittemx.com, knishimura@deloittemx.com, rgajdzik@deloittemx.com,  nalfaro@deloittemx.com, Sukahouaty@deloittemx.com, Surenkk@gmail.com,  migmillan@deloittemx.com, marellano@deloittemx.com, rtraconis@deloittemx.com,  jorgflores@deloittemx.com, brmaloney@deloitte.com, apdavis.com@deloitte.com,  stelarson@deloitte.com, snegangard@deloitte.com, kbernard@deloitte.com, lagarg@deloitte.com,  seprince@deloitte.com, Izagal@deloittemx.com, saradams@deloitte.com, saraadams@deloittemx.com,  fmaciasjasso@deloittemx.com, jcortina@deloittemx.com, jmatorres@deloittemx.com,  jegonzalezarellano@deloittemx.com, jgonzalezsaravia@deloittemx.com, sangutierrez@deloittemx.com,  22 corta@deloittemx.com, miggarcia@deloittemx.com, rimorales@deloittemx.com,  abaez@deloittemx.com, pberthely@deloittemx.com, mestrada@deloittemx.com,  oaguirre@deloittemx.com, argarciachavez@deloittemx.com, aanaya@deloittemx.com,  gmorenovega@deloittemx.com, joramirez@deloittemx.com, jotapia@deloittemx.com,  gondelatorre@deloittemx.com, robmorales@deloittemx.com, jrcarcano@deloittemx.com,  fcabanas@deloittemx.com, fcuahuencos@deloittemx.com, lpereda@deloittemx.com,  rosfuentes@deloittemx.com, jpalomino@deloittemx.com, lvalle@deloittemx.com,  victormedinagallo@deloittemx.com, jgarcia@deloittemx.com, gonzalezrodriguez@deloittemx.com,  jgarciavillalobos@deloittemx.com, nmerino@deloittemx.com, adcampos@deloittemx.com,  mariatorres@deloittemx.com, jocrivera@deloittemx.com, cachavez@deloittemx.com,  isdelgado@deloittemx.com, vdiaz@deloittemx.com, ensoriano@deloittemx.com,  cesagalvez@deloittemx.com, realonso@deloittemx.com, epozos@deloittemx.com,  adelcallejo@deloittemx.com, dhernandezfrontan@deloittemx.com,  egutierrezlegorreta@deloittemx.com, yteran@deloittemx.com, acolchado@deloittemx.com,  eshernandez@deloittemx.com, anagarcia@deloittemx.com, gosreview@deloittemx.com,  algonzalez@deloittemx.com, dgarcialozano@deloittemx.com, globalchair@deloitte.co.uk,  punit@deloitte.com, bseoane@deloittemx.com, jeguethoff@deloitte.com, mahmed@deloitte.com,  drheder@deloitte.com, centrodecontacto@deloittemx.com, eticayconducta@deloittemx.com,  anticorrupcion@deloittemx.com, JohnRussell@deloitte.ie, JoKehoe@deloitte.ie,  luismiguel@independencia.com.mx, bpacheco@independencia.com.mx,  jgarciamadr@independencia.com.mx, sergio.dominguez@ica.com.mx, guadalupe.torres@ica.com.mx,  bernardo.sepulveda@ica.com.mx, alejandro.gracida@ica.com.mx, nora.barbosa@ica.com.mx,  jose.guerrero@ica.com.mx, luis.romandia@ica.com.mx, paloma.grediaga@ica.com.mx,  juan.carlos.palomar@pemex.com, maricarmen.montano@pemex.com, Areli.perez@playaresorts.com,  paola.schilman@playaresorts.com, jm.ribas@playaresorts.com, ssastre@playaresorts.com,  rdiogo@playaresorts.com, PSaif@playaresorts.com, ir@playaresorts.com, press@playaresorts.com    Michael.Mctiernan@hoganlovells.com, Cbode@tpg.com, Doug.warner@weil.com,  Chris.machera@weil.com, Kyle.Krpata@weil.com, Nelsonj@gtlaw.com, Saylea@gtlaw.com,  brunoespindola@paulhastings.com, gonzalogutierrez@paulhastings.com,  emilywinston@paulhastings.com, elenapoleganova@paulhastings.com, joygallup@paulhastings.com,  leopoldogomezgrassi@paulhastings.com, pvelasco@s‐s.mx, theather@ritch.com.mx,  ldanton@ritch.com.mx, cobregon@ritch.com.mx, gdelvalle@ritch.com.mx, jpfarah@ritch.com.mx,  jberrueta@ritch.com.mx, lnicolau@ritch.com.mx, pperezalonso@ritch.com.mx, efreedman@cgsh.com,  ggaleotti@cgsh.com, fgaray@cgsh.com, ngrabar@cgsh.com, jcardona@cgsh.com,  apaul@whitecase.com, andrew.choe@balm.com, filo.fiorani@balm.com,     Joseph.Mazza@mcgladrey.com, Ron.kent@mcgladrey.com, Craig.Wickwire@mcgladrey.com,  Christine.Jung@mcgladrey.com, Tom.leyden@mcgladrey.com, Tracy.whetstone@mcgladrey.com,  Steven.Johnson@mcgladrey.com, Paige.Kuroyama@mcgladrey.com, Scott.Mackey@rsmus.com,  karen.jong@mcgladrey.com, Ericka.Foster@mcgladrey.com, Ellen.Burns@mcgladrey.com,  Michelle.McKenzie@mcgladrey.com, Leroy.Dennis@mcgladrey.com, allison.hovey@mcgladrey.com,  Byron.Whittlinger@mcgladrey.com, jack.rominger@mcgladrey.com, Tselby@wc.com,  BRobb@shilepsky.com, CNeff@foxrothschild.com, BRodos@foxrothschild.com,  PConnolly@foleyhoag.com, JLQ@foleyhoag.com, Marc.maselli@morganpartners.com,  JRudd@solutionsiq.com, Gmorein@gmail.com, George.Schlitz@gmail.com, Jamesiracundiff@gmail.com,  Garson@soelaw.com, Darrin_Ladd@hotmail.com, Stalley333@gmail.com, Stalley@kcrlegal.com,  Kelvin.Tetz@mossadams.com, Dkouame@bdo.com  23 Baumb, Nelly From:Nancy Alfaro <alfaro.nancy@gmail.com> Sent:Sunday, May 16, 2021 5:44 PM To:OIGCounsel@oig.treas.gov; hotline@oig.treas.gov; SIGTARP-GC@treasury.gov; sigtarp.hotline@do.treas.gov; Complaints@tigta.treas.gov; WhistleblowerProtection@tigta.treas.gov; FRC@fincen.gov; EDI.crd.ra@irs.gov; EDI.civil.rights.division@irs.gov; ofac_feedback@treasury.gov; oig@sec.gov; FRAudGroup@sec.gov; 10aletters@sec.gov; oca@sec.gov; NYROBankruptcy@sec.gov; DERA@sec.gov; sanfrancisco@sec.gov; publicinfo@sec.gov; losangeles@sec.gov; chicago@sec.gov; newyork@sec.gov; INFO@secwhistle.com; KaneP@sec.gov; KarrT@sec.gov; ReicherE@sec.gov; ShimpK@sec.gov; tips@pcaobus.org; ethics@pcaobus.org; DwyerE@pcaobus.org; director@fasb.org; baumannm@pcaobus.org; randj@pcaobus.org; wattsj@pcaobus.org; wiedemannk@pcaobus.org; bozhkovae@pcaobus.org; diznae@pcaobus.org; vinellia@pcaobus.org; Info@pcaobus.org; Speeches@pcaobus.org; PublicAffairs@pcaobus.org; asksipc@sipc.org; whistleblower@finra.org; ChairmanOffice@sec.gov; CommissionerJackson@sec.gov; CommissionerLee@sec.gov; CommissionerRoisman@sec.gov Cc:Mayor.Garcetti@lacity.org; mayor@fresno.gov; Daniel.Zack@fresno.gov; Mark.Standriff@fresno.gov; Esmeralda.Soria@fresno.gov; Paul.Caprioglio@fresno.gov; Robert.Andersen@fresno.gov; Leager@fresnoedc.com; Council, City; Office of the CIO; TomforCouncil@gmail.com; Ng, Judy; LydiaKou@cityofpaloalto.org; Kane@cityofpaloalto.org; Carnahan, David; Stephanie.Douglas@cityofpaloalto.org; Yang, Albert; Patel, Raj; Auzenne, Tom; Investor@gruposantander.com; Fidelity.Investments@mail.fidelity.com; reportphish@wellsfargo.com; ofsrep.rumbbgw@wellsfargo.com; contacto@gmxt.mx; ri@telmex.com; info@grupobmv.com.mx; vfueyo@homex.com.mx; ir@gruma.com; daniela.lecuona@americamovil.com; investor.relations@americamovil.com; anticorrupcion@americamovil.com; asuntoscorporativos@clarochile.cl; codigoetica@americamovil.com; derechoshumanos@americamovil.com; conflictointeres@americamovil.com; valores@americamovil.com; seguridadinformatica@americamovil.com; infoconfidencial@americamovil.com; privacidad@americamovil.com; clientes@americamovil.com Subject:Fwd: Lights Out For Indian Point As NYC Sources More Fossil Fuels For Power Generation | ZeroHedge CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.                Begin forwarded message:  From: "." <alfaro.nancy@gmail.com>  Date: May 15, 2021 at 9:53:03 PM PDT  To: sbarragan@aristeguinoticias.com, redaccion@aristeguinoticias.com, careyshenkman@riseup.net,  courage.contact@couragefound.org, transportandoamichoacan@live.com,  periodicooficial@michoacan.gob.mx, buzon@poderjudicialmichoacan.gob.mx,  Comercializacion@telesurtv.net, Albinocm6502@gmail.com, JuanJosedelCastillo@gmail.com,  Borderlinebeat@gmail.com, Charropoliticoenvivo@gmail.com, Conexiononline1@hotmail.com,  wells@wsws.org, autoworkers@wsws.org, sep@socialistequality.com, Norissa@socialism2020.org,  joe@socialism2020.org, Christine.s.Richard@gmail.com, Aaron.Greenspan@plainsite.org,  24 realitycheck@plainsite.org, VeritasTIPS@protonmail.com, richard.clayton@ctwinvestmentgroup.com,  noe.cruz@eluniversal.com.mx, denuncia@eluniversal.com.mx, contacto@eluniversal.com.mx,  atiempomx@gmail.com, indicepolitico@gmail.com, Investigacion@elpais.es, jlsc.ua@gmail.com,  WorldsApart@rttv.ru, charles@russia‐insider.com, moderator@russia‐insider.com,  radio@sputniknews.com, mediapartners@sputniknews.com, advertising@sputniknews.com,  media@sputniknews.com  Cc: urgent‐action@ohchr.org, ethicsoffice@who.int, ethicsoffice@un.org, cdhdf@cdhcm.org.mx,  quejas@cdhcm.org.mx, cdhm@tlachinollan.org, aclupreferences@aclu.org,  communications@aclusocal.org, press@ccrjustice.org, info@insyde.org.mx, info@amnistia.org.mx,  carlos.mendoza@amnesty.org, duncan.tucker@amnesty.org, daniella.gac@ulagos.cl,  tribunalpazecuador@yahoo.com, Victor.cabezas@estud.usfq.edu.ec, asuntoscorporativos@clarochile.cl,  marcel.theza@ulagos.cl, aorozco@utla.net, albert.lowe@utla.net, acaputopearl@utla.net,  alau@utla.net, Management@usfca.edu, silvanoaureoles@michoacan.gob.mx,  Marco.Lagunas@cocotra.michoacan.gob.mx, manuel.valencia@cocotra.michoacan.gob.mx,  Transparecia@cocotra.michoacan.gob.mx, FOM.2@hotmail.com, tribuno_alfa@hotmail.com,  gobiernodemorelia@morelia.gob.mx, GobiernoMichoacan2.0@gmail.com,  transparenciamorelia@morelia.gob.mx, Fiscal@morelia.fiscaliamichoacan.gob.mx,  fiscalgeneral@fiscaliamichoacan.gob.mx, pgjecomsoc@michoacan.gob.mx,  sectec.despacho@michoacan.gob.mx, sectec_segob@michoacan.gob.mx,  denuncialosaqui@ssedomex.gob.mx, denuncia.regulacionsanitaria@edomex.gob.mx,  Glozano@queretaro.gob.mx, Sedesu@queretaro.gob.mx, rebelcapitaladvisors@gmail.com  Subject: Fwd: Lights Out For Indian Point As NYC Sources More Fossil Fuels For Power Generation |  ZeroHedge       Thomas Flannery (EY, Sr. Audit Partner)   Co‐leader, Americas Wealth and Asset Management, EY Boston    This is Email 3 out four emails sent on May 8, 2021 to the same group shown in the email  below. The Email distribution list at the end of this email trail was added  on May 12, 2021, the day I  intended to forward the four emails below. Today is the first day I was able to start forwarding it. If  and when anyone receives it,is a separate matter.      First Email (1/4)  Cyberattack Forces Shutdown Of Largest Gasoline Pipeline In United States | ZeroHedge    Second Email (2/4)  Illicit Financial Flows, Trade Misinvoicing, and Multinational Tax Avoidance: The Same or Different? ‐ EY‐ Wal‐Mart as an model ‐    Third Email 3 (3/4)  Fwd: Lights Out For Indian Point As NYC Sources More Fossil Fuels For Power Generation | ZeroHedge    Fourth Email 4 (4/4)  Fwd: Texas Deep Freeze: Restarting Oil and Gas Will Be an Emissions Mess ‐ Bloomberg          25   Begin forwarded message:  From: "." <alfaro.nancy@gmail.com>  Date: May 9, 2021 at 2:39:21 AM PDT  To: thomas.flannery@ey.com, tfflannery@gmail.com, susan.cote@ey.com,  susan.rothfels@uk.ey.com, tracy.koh@my.ey.com, kelly.musmanno@ey.com,  Alexis.Lucas@ey.com, kathryn.tominovich@ey.com, carmine.disibio@ey.com,  Patrick.niemann@ey.com, thomas.flannery@ey.com, mark.weinberger@uk.ey.com,  michael.serota@ey.com, mark.gutierrez@ey.com, michael.odonnell@ey.com,  joost.hendriks@ey.com, david.cormack@ey.com, jim.mccaulley@ey.com,  marc.roberts@ey.com, gabriel.marquez@ey.com, roger.yang@ey.com,  sandra.burns@ey.com, gregory.feng@ey.com, greg.glater@ey.com,  david.statman@ey.com, troy.jones@ey.com, allen.freeman@ey.com,  keith.lupton@ey.com, michael.johnson4@ey.com, robert.moritz@us.pwc.com,  groa@deloittemx.com, sbarragan@aristeguinoticias.com, dchrencik@hotmail.com,  Benjamro@herbalife.com, Glozano@queretaro.gob.mx, Sedesu@queretaro.gob.mx  Cc: silvanoaureoles@michoacan.gob.mx, Marco.Lagunas@cocotra.michoacan.gob.mx,  manuel.valencia@cocotra.michoacan.gob.mx,  Transparecia@cocotra.michoacan.gob.mx, FOM.2@hotmail.com,  tribuno_alfa@hotmail.com, gobiernodemorelia@morelia.gob.mx,  GobiernoMichoacan2.0@gmail.com, transparenciamorelia@morelia.gob.mx,  Fiscal@morelia.fiscaliamichoacan.gob.mx, fiscalgeneral@fiscaliamichoacan.gob.mx,  pgjecomsoc@michoacan.gob.mx, sectec.despacho@michoacan.gob.mx,  sectec_segob@michoacan.gob.mx, denuncialosaqui@ssedomex.gob.mx,  denuncia.regulacionsanitaria@edomex.gob.mx, contacto@senadomorena.com,  SINDICATO@senado.gob.mx, SINDICATO969.transparencia@senado.gob.mx,  gobernacion@senado.gob.mx, Transparecia@senado.gob.mx,  puntosconstitucionales@senado.gob.mx, derechoshumanos@senado.gob.mx,  anticorrupcion@senado.gob.mx, hacienda@senado.gob.mx, justicia@senado.gob.mx,  marina@senado.gob.mx, webmaster@semar.gob.mx, cni@cni.gob.mx,  asuntosindigenas@senado.gob.mx, ninezyadolescencia@senado.gob.mx,  economia@senado.gob.mx, salud@senado.gob.mx, educacion@senado.gob.mx,  trabajoyprevision@senado.gob.mx, reformaagraria@senado.gob.mx,  agriculturayganaderia@senado.gob.mx, energia@senado.gob.mx,  comunicacionesytransportes@senado.gob.mx, asuntosfronterizos@senado.gob.mx,  comsegsocial@senado.gob.mx, crpp@senado.gob.mx,  seguridadpublica@senado.gob.mx, seguridad.nacional@diputados.gob.mx,  defensanacional@senado.gob.mx  Subject: Lights Out For Indian Point As NYC Sources More Fossil Fuels For Power  Generation | ZeroHedge     Thomas Flannery (EY, Sr. Audit Partner)   Co‐leader, Americas Wealth and Asset Management, EY Boston    When the US has a Labor force that can understand basic organic chemistry  (Carbon)then it can sell the rest of the world on its Ponzi Scheme that the US can shut  down the US only possible sources to generate electricity Coal  +  Natural Gas (High  Emissions US fracking = LGN) and Nuclear Power. There isn't anything Natural about  Natural Gas.     26 Climate Change isn't about the environment (one can't decarbonize human life, period)  and we don't have the resources or skilled Labor to claim we have found a credible  source of alternative energy. Why are the Global Climate Change Parrots desperately  rushing to closing sources of energy and jobs Americans don't have.      Once again, Enron Texas corporate criminal  took down Arthur Andersen (the Big 5  Accounting Cartel ) and  California's Governor with it over the shenanigans in electricity  markets shenanigans (alleged issues at the power plants) rolling black outs to jack up  prices to California tax payers, the gullible CA winy snowflakes. Climate Change isn't a  new scheme.     CA governor Gavin Newson is being thrown out in the process. Only stupid  criminal  Governors (i.e. CA and New York Andrew Cuomo) let  Herbalife, Wal‐Mart and  EY, you (Tom Flannery), issues escalate to the magnitude of taking down the BigTech  and Silicon Valley's innovation Ponzi and Wall Street Ponzi Scheme down with them. You  will pay for it too shit‐head not just winy CA snowflakes.     The winy snowflakes can keep buying Telsa's with their cryptocurrency, neither has  value. They will  find out how much they will be paying to Mexicans to ship them  electricity, if any, or whether Mexico and Bolivia give them their lithium deposits.  Lithium should be under Military protection by now in Mexico and around the world just  as rear earths are being protected by China. Apple or Telsa ain't coming back after their  Shenanigans against China and Oil.    I am who wants to build a China Wall  and put Russian S‐400 pointing at the US along  with Mexico's Military across the US‐Mexican Border and its coasts to keep any  Americans from crossing into Mexico and South America. I am  livid at the Israelis being  in Mexico and I want to drop a nuclear bomb ( from Los Alamos in Texas) to wipe out  Israeli Terrorist Jews  from this planet. Criminal psychopaths who solely exist to create  conflict and inflict unimaginable pain,  violence and despicable crimes to those around  them don't get second chances nor re‐educated.     Its always about appropriation, theft, of  Energy and Natural Resources not about  democracy. The US doesn't even give a shit about its own citizens in the US. much less  gives a crap elsewhere.        https://www.zerohedge.com/commodities/lights‐out‐indian‐point‐nyc‐sources‐more‐ fossil‐fuel‐power‐generation  Lights Out For Indian Point As NYC Sources More Fossil Fuels For Power Generation The nuclear power plant known as Indian Point Energy Center (IPEC) is slated for closure Friday, fulfilling Gov. Andrew Cuomo's multi-year plan to shutter the aging facility. IPEC is a 2,000-megawatt nuclear 27 power plant located 24 miles north of New York City and presents numerous safety threats to the people of NYC and the environment. "Since my time as Attorney General, I have been deeply concerned with the safety of the Indian Point nuclear power facility. It does not belong on the Hudson River and in close proximity to the most densely populated area in the country," Cuomo said. "After years of relentless work together with federal, state, and local officials, we found a path to safely and responsibly close Indian Point, ending the threat the plant has long‐posed to an area that is vitally important to our state, the nation, and the world. This is a victory for the health and safety of New Yorkers, and moves us a big step closer to reaching our aggressive clean energy goals." To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet. But closing IPEC could create new problems for the state's power grid that will have to resort to more natural gas plants, which emit pollution until the state's renewable energy comes online. The nuclear power plant produces about a quarter of NYC's energy. 28 State officials told NYTimes the closing of IPEC "will be a step in the wrong direction, but say that it will be made up by a leap forward in clean energy sources, like wind and solar." Tom Congdon, the chairman of Cuomo's Indian Point Task Force, said, "once the large-scale renewable and offshore wind farms are complete, more than half of New York's electricity will come from renewable sources, putting the state ahead of schedule toward reaching its goal of 70 percent renewable energy by 2030." However, those megaprojects will take years to construct and means the city will soon be sourcing more power from gas-burning plants. Expect a bump in natural gas demand after the IPEC is closed. Source: Bloomberg To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet. The closure of the plant ahead of the summer season when energy demand rises due to millions in the metro area lowering their thermostats could spark blackouts on peak demand days. NYPost warned: 29 In reality, the final shutdown of Indian Point is yet another milestone in the governor's ongoing assault on the state's energy infrastructure. He has refused to allow new gas pipelines to be built that would allow residents to enjoy the benefits of low‐cost natural gas. Yet that new pipeline capacity will be sorely needed now: to deliver additional natural‐gas supplies to the power plants needed to replace the roughly 16 trillion kilowatt‐hours of electricity that Indian Point generated every year. That's a lot of natural gas. Without it, Gotham is facing blackouts during the sweltering days of summer, especially on hazy, windless days. Cuomo's clean energy push is merely virtue signaling, and today's IPEC closure will force even more significant amounts of fossil fuel generation for NYC even though the governor promotes renewable energy. Who knows when those green projects come online. As for now, the city and state are moving in the wrong direction.   Email distribution list [added  May 12, 2021]  SBarragan@aristeguinoticias.com, redaccion@aristeguinoticias.com, careyshenkman@riseup.net,  courage.contact@couragefound.org, transportandoamichoacan@live.com,  periodicooficial@michoacan.gob.mx, buzon@poderjudicialmichoacan.gob.mx,  Comercializacion@telesurtv.net, Albinocm6502@gmail.com, JuanJosedelCastillo@gmail.com,  Borderlinebeat@gmail.com, Charropoliticoenvivo@gmail.com, Conexiononline1@hotmail.com,  Wells@wsws.org, autoworkers@wsws.org, sep@socialistequality.com, NORISSA@socialism2020.org,  JOE@socialism2020.org, Christine.s.Richard@gmail.com, Aaron.Greenspan@plainsite.org,  Realitycheck@plainsite.org, VeritasTIPS@protonmail.com, Richard.clayton@ctwinvestmentgroup.com,  Noe.cruz@eluniversal.com.mx, Denuncia@eluniversal.com.mx, Contacto@eluniversal.com.mx,  Atiempomx@gmail.com, Indicepolitico@gmail.com, Investigacion@elpais.es, jlsc.ua@gmail.com,  WorldsApart@rttv.ru, Charles@russia‐insider.com, moderator@russia‐insider.com,  radio@sputniknews.com, mediapartners@sputniknews.com, advertising@sputniknews.com,  media@sputniknews.com, marketing@sputniknews.com, info@tehrantimes.com,  ads@tehrantimes.com, newsdesk@afr.com, news@thelocal.it, talk@npr.org, TIPS@zerohedge.com,  Digital@thenation.com, Jmyers@thenation.com, Ryan.Gallagher@theintercept.com,  USinfo@theguardian.com, News@sky.com, TIPS@propublica.org, Joaquin.sapien@propublica.org,  Alec.MacGillis@propublica.org, David.mcswane@propublica.org, Robert.Faturechi@propublica.org,  Sebastian.Rotella@propublica.org, Pamela.colloff@propublica.org, suggestions@propublica.org,  Richard.winton@latimes.com, Liam.dillon@latimes.com, Melody.gutierrez@latimes.com,  Luke.money@latimes.com, Alejandra.reyesvelarde@latimes.com, Gustavo.arellano@latimes.com,  Jack.leonard@latimes.com, Ruben.vives@latimes.com, Jcain@scng.com, Joseph.Cox@vice.com,  Jfcox@jabber.ccc.de, kfsndesk@abc.com, kwalsh@kmaxtv.com, newsdesk@cbs47.tv,  Nina.Trentmann@wsj.com, Paul.Ziobro@wsj.com, Jean.Eaglesham@wsj.com,  Robbie.Whelan@wsj.com, Katherine.Blunt@wsj.com, Alejandro.Lazo@wsj.com,  Jean.Eaglesham@wsj.com, Michael.Rapoport@wsj.com, Mengqi.Sun@wsj.com,  Marcelo.Prince@wsj.com, John.Simons@wsj.com, jeannette.neumann@wsj.com, ryan.tracy@wsj.com,  30 Opinion@elfinanciero.com.mx, EMilligan11@bloomberg.net, lprinsloo3@bloomberg.net,  Epfanner1@bloomberg.net, Asguazzin@bloomberg.net, Jkew4@bloomberg.net,  Carleton.English@dowjones.com, Tabby.kinder@ft.com, Dan.mccrum@ft.com, tips@nypost.com,  Lisette.v@columbia.edu, Kagubare@globalinvestigationsreview.com, editor@goingconcern.com,  aaron.nicodemus@complianceweek.com, orly.taitz@gmail.com, tips@theverge.com,  walmartwalkout@gmail.com, Justin.Velasco@sgvn.com, news@whistleblowergov.org,  whistleblowing@article19.org, publications@globalresearch.ca, Eiu_enquiries@eiu.com, poldep‐ budg@europarl.europa.eu, jack.avent@euromoneyplc.com, anjana.haines@euromoneyplc.com,  margaret.varela‐christie@euromoneyplc.com, tips@forbes.com, ideas@forbes.com,  readers@forbes.com, mfazio@chicagotribune.com, emalagon@chicagotribune.com,  gpratt@chicagotribune.com, kkelly@bayareanewsgroup.com, Kashmir.hill@gizmodomedia.com,  jaeger@complianceweek.com, helpdesk@itrinsight.com    urgent‐action@ohchr.org, ethicsoffice@who.int, ethicsoffice@un.org, cdhdf@cdhcm.org.mx,  QUEJAS@cdhcm.org.mx, cdhm@tlachinollan.org, aclupreferences@aclu.org,  communications@aclusocal.org, press@ccrjustice.org, info@insyde.org.mx, info@amnistia.org.mx,  carlos.mendoza@amnesty.org, duncan.tucker@amnesty.org, daniella.gac@ulagos.cl,  tribunalpazecuador@yahoo.com, Victor.cabezas@estud.usfq.edu.ec, asuntoscorporativos@clarochile.cl,  marcel.theza@ulagos.cl, thelmstetter@americansfortaxfairness.org,  dbailey@americansfortaxfairness.org, aorozco@utla.net, albert.lowe@utla.net, acaputopearl@utla.net,  alau@utla.net, Management@usfca.edu    pscaritas@iglesiacr.org, Questions@caritas.org.au, caritas@caritas.org.au, secretary@caritas.ru,  caritas.Iran@gmail.com, caritas.info@caritas‐sy.com, caritas.iraq2015@gmail.com,  Comunicacion.on@caritasnicaragua.com.ni, info@caritasvenezuela.org, caritasvenezuela@gmail.com,  pscb@caritasbolivia.org, info@caritaselsalvador.org.sv, info@caritas.sv, info@caritasecuador.org,  caritas@pastoralcaritaspanama.org, administration@caritascyprus.org, caritaslac@caritas.org.ar,  comisionacional@caritas.org.ar, info@caritas.org.lb, executive@caritas.org.lb,  caritas_de_honduras@caritas.hn, secretaria@communication‐caritashaiti.org,  headoffice@caritasjordan.org.jo, direccion1@ceps.org.mx, snpscol@cec.org.coc,  secretariaejecutiva@caritas.gt, caritasnorthamerica@gmail.com, info@caritas‐europa.org,  caritasoceania@gmail.com, asiacaritas@caritas.asia, coord@caritas‐africa.org, info@devp.org,  info@crs.org, info@catholiccharitiesusa.org, caritas.internationalis@caritas.va,  postmaster@caritas.org.pe, secretaria@caritasuruguaya.org.uy, cep.pastoralsocialnacional@gmail.com,  pscarcr@racsa.co.cr, caritas@caritas.org.br, caritasantilles@aocslu.org, bishoptripoli@gmail.com,  cariteg@link.net, secretaire@caritas.mr, directeur@caritas.mr, caritas.djibouti@gmail.com,  caritassomalia@gmail.com, caritasmig@gmail.com    Inspector.General@eeoc.gov, FOIA@eeoc.gov, OIGWhistleblower@oig.dol.gov, OIGHOTLINE@nlrb.gov,  CRCExternalComplaints@dol.gov, EOC@dol.gov, CivilRightsCenter@dol.gov, LaborOIGinfo@oig.dol.gov,  ofo.eeoc@eeoc.gov, Nicole.stgermain@eeoc.gov, linda.li@eeoc.gov, bryan.hoss@eeoc.gov,  rosa.salazer@eeoc.gov, monica.colunga@eeoc.gov, michael.rojas@eeoc.gov, TalkTODO@dol.gov,  Executivesecretariat@dol.gov, HQOPSHL@ed.gov, HPqopshl@ed.gov    Hotline@oig.dot.gov, Judy.Kaleta@dot.gov, Dana.Nifosi@dot.gov, Brett.Jortland@dot.gov,  Thomas.Holian@dot.gov, Ellen.Herr@dot.gov, Terence.Carlson@dot.gov    OIG@ftc.gov, Secretary@ftc.gov, Antitrust@ftc.gov, lsolis@ftc.gov, Dhanks@ftc.gov, Ctodaro@ftc.gov,  Bchun@ftc.gov, Rjones@ftc.gov, Kwalsh@ftc.gov, nwhitehead@ftc.gov, asix@ftc.gov,  ssheinberg@ftc.gov, vmusick@ftc.gov, tcarson@ftc.gov, kberg@ftc.gov, tkingsberry@ftc.gov,  lsatine@ftc.gov, premerger@ftc.gov, hsrhelp@ftc.gov    31 OIG@gao.gov, Congrel@gao.gov, RussellC@gao.gov, RussellW@gao.gov, OCE@mail.house.gov,  HouseIG@mail.house.gov, Hatchact@osc.gov, khendricks@osc.gov, FOIARequest@osc.gov,  Whistleblower@ronjohnson.senate.gov, Peters_Whistleblower@hsgac.senate.gov,  Whistleblower@commerce.senate.gov, help@elizabethwarren.com, info@elizabethwarren.com,  casework@feinstein.senate.gov, OIG@fec.gov, Pubrec@fec.gov, Lobby@sec.senate.gov,  LobbyInfo@mail.house.gov, Secretary@hhs.gov, OCRPrivacy@hhs.gov, OCRmail@hhs.gov,  OIGhotline@opm.gov, USCIS.FOIA@uscis.dhs.gov, FOIA.OIG@oig.dhs.gov,  Whistleblower.Coordinator@oig.hhs.gov, Whistleblowerprotectioncoordinator@oig.dhs.gov,  OPMOIGWhistleblower@opm.gov, Tmillsaps@osc.gov, Atticus.reaser@cigie.gov,  Michael.e.horowitz@usdoj.gov, Kevin.winters@amtrakoig.gov, Hkerner@osc.gov,  Shimon.Richmond@oig.hhs.gov, RMFSIMSST@nbib.gov, FOIPARequests@nbib.gov,  ICIGHotline@dni.gov, IG_hotline@dodiis.mil, ighotline@exim.gov, DDTCResponseTeam@state.gov,  Socr_Direct@state.gov, WPEAOmbuds@stateoig.gov,     Ombudsman@frb.gov, OIGHotline@frb.gov, CFPBOmbudsman@cfpb.gov,  CFPB_WHISTLEBLOWER@cfpb.gov, whistleblower@consumerfinance.gov,  OMWI@consumerfinance.gov, CFPB_WHISTLEBLOWER@cfpb.gov, military@consumerfinance.gov,  CFPB_OlderAmericans@cfpb.gov, CFPB_CABandCouncilsEvents@consumerfinance.gov,  CFPB_AmicusBriefs@cfpb.gov, CFPB_EEO@consumerfinance.gov,  OfficeOfInnovation@consumerfinance.gov, HMDAHelp@cfpb.gov,  CFPB_ILSAProgramOffice@consumerfinance.gov,  CFPB_RegulatoryImplementation@consumerfinance.gov    OIGCounsel@oig.treas.gov, hotline@oig.treas.gov, SIGTARP‐GC@treasury.gov,  sigtarp.hotline@do.treas.gov, Complaints@tigta.treas.gov, WhistleblowerProtection@tigta.treas.gov,  FRC@fincen.gov, EDI.crd.ra@irs.gov, EDI.civil.rights.division@irs.gov, OFAC_feedback@treasury.gov    OIG@sec.gov, FRAudGroup@sec.gov, 10ALetters@sec.gov, OCA@sec.gov, NYROBankruptcy@sec.gov,  DERA@sec.gov, SanFrancisco@sec.gov, Publicinfo@sec.gov, LosAngeles@sec.gov, Chicago@sec.gov,  NewYork@sec.gov, INFO@secwhistle.com, KaneP@sec.gov, KarrT@sec.gov, ReicherE@sec.gov,  ShimpK@sec.gov, TIPS@pcaobus.org, Ethics@pcaobus.org, DwyerE@pcaobus.org, director@fasb.org,  baumannm@pcaobus.org, randj@pcaobus.org, wattsj@pcaobus.org, wiedemannk@pcaobus.org,  bozhkovae@pcaobus.org, diznae@pcaobus.org, vinellia@pcaobus.org, Info@pcaobus.org,  Speeches@pcaobus.org, PublicAffairs@pcaobus.org, Asksipc@sipc.org, whistleblower@finra.org,  ChairmanOffice@sec.gov, CommissionerJackson@sec.gov, CommissionerLee@sec.gov,  CommissionerRoisman@sec.gov    Firearms.Bureau@doj.ca.gov, pctips‐losangeles@fbi.gov, nics@fbi.gov, info@gungalleryinc.com,  Criminal.Division@usdoj.gov, FCPA.fraud@usdoj.gov, OPR.complaints@usdoj.gov, USACAC.CV‐ CivilRights@usdoj.gov, National.FOIAPortal@usdoj.gov,  oig.whistleblower.ombudsperson.program@usdoj.gov, Debora.Yang@doj.ca.gov,  Xavier.Becerra@doj.ca.gov, NSD.Public@usdoj.gov, USAVAE.NICS@usdoj.gov,  Thomas.Traxler@usdoj.gov, Alexander.P.Berrang@usdoj.gov, Heather.Schmidt@usdoj.gov,  Gordon.Kromberg@usdoj.gov, Peter.Duffey@usdoj.gov, Dennis.Barghaan@usdoj.gov,  Daniel.S.Schwei@usdoj.gov, Trent.McCotter@usdoj.gov, Nathan.M.Swinton@usdoj.gov,  Zia.Faruqui@usdoj.gov, Niall.ODonnell@usdoj.gov, Joseph.Beemsterboer@usdoj.gov,  Amy.Markopoulos@usdoj.gov, Faruqui_Chambers@dcd.uscourts.gov, Michael.Grady3@usdoj.gov,  Brian.Rickers@usdoj.gov, OIG.whistleblower.ombudsperson.program@usdoj.gov,  Victimassistance.fraud@usdoj.gov, John.Marston@usdoj.gov, USPardon.Attorney@usdoj.gov,  FairHousing@usdoj.gov, Voting.Section@usdoj.gov, commandcenter@doj.ca.gov,  keeperofrecords@doj.ca.gov, recordreview@doj.ca.gov    32 OIGcompl@lapd.online, dale.bonner@lapd.online, n4967@lapd.lacity.org, N5449@lapd.online,  n6220@lapd.online, n4964@lapd.online, bopc@lapd.online, lapdcms@lapd.online,  bopcuseofforcepolicy@lapd.online, calganginput@lapd.online, communityrelationsoig@lacity.org,  contact.lapdonline@gmail.com, ethics.commission@lacity.org, info@santamonica.gov,  info@asp.arkansas.gov, sfpd.commission@sfgov.org, sfdpa@sfgov.org,     LASERS.services@lacers.org, erb@lacity.org, info@insyde.org.mx, pra@calbar.ca.gov,  clientsecurityfund@calbar.ca.gov, manager@cityofberkeley.info, kworthington@cityofberkeley.info,  BARcomm@calbar.ca.gov,     Mayor.Garcetti@lacity.org, Mayor@fresno.gov, Daniel.Zack@fresno.gov, Mark.Standriff@fresno.gov,  Esmeralda.Soria@fresno.gov, Paul.Caprioglio@fresno.gov, Robert.Andersen@fresno.gov,  Leager@fresnoedc.com, City.Council@cityofpaloalto.org, OfficeoftheCIO@cityofpaloalto.org,  TomforCouncil@gmail.com, Judy.Ng@cityofpaloalto.org, LydiaKou@cityofpaloalto.org,  Kane@cityofpaloalto.org, David.Carnahan@cityofpaloalto.org, Stephanie.Douglas@cityofpaloalto.org,  Albert.Yang@cityofpaloalto.org, Raj.Patel@cityofpaloalto.org, Tom.Auzenne@cityofpaloalto.org    Assesor@sfgov.org, Arun.Bhatia@sfdwp.org, Board.of.Supervisors@sfgov.org,  Commissions.Secretary@sfgov.org, Sotf@sfgov.org, Ethics.Commission@sfgov.org,  glambing@fppc.ca.gov, CommAssist@fppc.ca.gov, Advice@fppc.ca.gov, Cpra@fppc.ca.gov,  CHackert@fppc.ca.gov, Bridget.Hicks@sfgov.org, JFleming@metricus.net, Jreichental@gmail.com,  jreichental@hotmail.com, Treichental@hotmail.com, Complaint@fppc.ca.gov, Hatchact@osc.gov,  Lobby@sec.senate.gov, LobbyInfo@mail.house.gov, OIG@fec.gov, Pubrec@fec.gov,  StateInfo@state.ca.gov, Secretary.Padilla@sos.ca.gov, WPEAOmbuds@stateoig.gov, DCA@dca.ca.gov,  Kimberly.Kirchmeyer@dca.ca.gov, Alexis.Podesta@dca.ca.gov, SIUMailbox@scif.com,  Enforcement@cslb.ca.gov, Classifications@cslb.ca.gov, Licensing@cslb.ca.gov, Info@cslb.ca.gov,  Sheila.Daniels@cba.ca.gov, Enforcementinfo@cba.ca.gov, ComplianceUnit@cba.ca.gov,  CitationsUnit@cba.ca.gov, patti.bowers@cba.ca.gov, deanne.pearce@cba.ca.gov,  nooshin.movassaghi@cba.ca.gov, oponline@nysed.gov, OldInetInfo@dos.ny.gov, OPDPLS@nysed.gov,  CommitteeMeetings@scif.com, BoardofDirectors@scif.com, hbpadua@scif.com    Silvanoaureoles@michoacan.gob.mx, Marco.lagunas@cocotra.michoacan.gob.mx,  Manuel.valencia@cocotra.michoacan.gob.mx, Transparecia@cocotra.michoacan.gob.mx,  FOM.2@hotmail.com, Tribuno_alfa@hotmail.com, Gobiernodemorelia@morelia.gob.mx,  GobiernoMichoacan2.0@gmail.com, Transparenciamorelia@morelia.gob.mx,  FISCAL@morelia.fiscaliamichoacan.gob.mx, FiscalGeneral@fiscaliamichoacan.gob.mx,  PGJecomsoc@michoacan.gob.mx, Sectec.despacho@michoacan.gob.mx,  Sectec_segob@michoacan.gob.mx, Denuncialosaqui@ssedomex.gob.mx,  Denuncia.regulacionsanitaria@edomex.gob.mx, Glozano@queretaro.gob.mx,  Sedesu@queretaro.gob.mx    Contacto@senadomorena.com, SINDICATO@senado.gob.mx,  SINDICATO969.transparencia@senado.gob.mx, Gobernacion@senado.gob.mx,  Transparecia@senado.gob.mx, puntosconstitucionales@senado.gob.mx,  derechoshumanos@senado.gob.mx, Anticorrupcion@senado.gob.mx, hacienda@senado.gob.mx,  Justicia@senado.gob.mx, Marina@senado.gob.mx, webmaster@semar.gob.mx, cni@cni.gob.mx,  asuntosindigenas@senado.gob.mx, ninezyadolescencia@senado.gob.mx, Economia@senado.gob.mx,  Salud@senado.gob.mx, Educacion@senado.gob.mx, Trabajoyprevision@senado.gob.mx,  reformaagraria@senado.gob.mx, agriculturayganaderia@senado.gob.mx, energia@senado.gob.mx,  comunicacionesytransportes@senado.gob.mx, asuntosfronterizos@senado.gob.mx,  comsegsocial@senado.gob.mx, crpp@senado.gob.mx, seguridadpublica@senado.gob.mx,  seguridad.nacional@diputados.gob.mx, Defensanacional@senado.gob.mx,  33 derechos.arco@funcionpublica.gob.mx, carmina.jasso@sociales.unam.mx,  alternativedevelopment@unodc.org, cristobal.arias@senado.gob.mx,  alejandro.gonzalezy@senado.gob.mx, nestora.salgado@senado.gob.mx, ruben.rocha@senado.gob.mx,  felix.salgado@senado.gob.mx, lcalderonh@senado.gob.mx, webmaster@congreso.gob.mx,  secretaria_direccion@centroprodh.org.mx, defensa@centroprodh.org.mx,  educacion@centroprodh.org.mx, comunicacion@centroprodh.org.mx,  administracion@centroprodh.org.mx, desarrollo2@centroprodh.org.mx,  internacional@centroprodh.org.mx, crmichoa@pfp.gob.mx, csmoreli@pfp.gob.mx,  cslazaro@pfp.gob.mx, cspiedad@pfp.gob.mx, crguadal@pfp.gob.mx, cdguzman@pfp.gob.mx,  cstepati@pfp.gob.mx, csatlaco@pfp.gob.mx, sumit2006@gmail.com, ed‐del‐rev@nic.in,  molegangwar@yahoo.com, secy‐labour@nic.in, farida.samsul@gov.in, igkonwar.acs@assam.gov.in,  bopb1.clb@nic.in, registrar‐mum@nclt.gov.in, secretary@nclt.gov.in, registrar.jpr@nclt.gov.in,  response‐nis@pib.gov.in    FRAUD@insurance.ca.gov, Ombudsman@insurance.ca.gov, CAB‐SF‐Intake@insurance.ca.gov,  ElectronicSubmissionFD‐1@insurance.ca.gov, pushpa.uttamchandani@insurance.ca.gov,  RECRUITMENT@insurance.ca.gov, RSBCovid19PR@insurance.ca.gov,  CustodianofRecords@insurance.ca.gov, StateFarmfireClaims@statefarm.com, Privacy@statefarm.com    Ethics.Officers@jll.com, Laura.Locks@lasalle.com, John.Carlson@lasalle.com, klynch@icsla.us,  S.Mercer@festivalcos.com, T.Killeen@festivalcos.com, D.Whitt@festivalcos.com,  S.Brown@festivalcos.com, F.Insurance@festivalcos.com, Celia.shibata.iyhc@statefarm.com,  Nicole.HillSmidt@roberthalf.com, Samantha.figueroa@roberthalf.com, sherri.agganis@rhmr.com,  anjali.chandel@rhmr.com, chelsea.jongewaard@rhmr.com, julia.person@roberthalf.com,  carmen.romero‐eberle@roberthalf.com, tony.uyehara@roberthalf.com,  zoya.naumchik@roberthalf.com, tala.moussouras@roberthalf.com, cawagenotice@roberthalf.com,  pay.timereporting@roberthalf.com, OnlineTimeReporting@roberthalf.com, quality.manager@rhi.com    SMangum@smwb.com, JRobb@smwb.com, jsweeney@smwb.com, rmason@smwb.com,  sschmidt@smwb.com, colson@smwb.com, kwilson@smwb.com, REB@smwb.com,  wkaufman@smwb.com, dlee@smwb.com, rthomson@smwb.com, LLGinn@smwb.com,  TJacobson@smwb.com, lbalke@smwb.com, WStanger@smwb.com, Parul@giulianiconstruction.com,  Vince@giulianiconstruction.com, Tiffany@giulianiconstruction.com,  Antoinette@giulianiconstruction.com, Ashley@giulianiconstruction.com, AR@giulianiconstruction.com,  Claudia@giulianiconstruction.com, Erik@giulianiconstruction.com, SLG@sghoalaw.com,  TMiller@constructionsdefects.com, Sara@constructiondefects.com, Sbrown@constructiondefects.com,  Linda@constructiondefects.com, Rachel@constructiondefects.com, Joseph@constructiondefects.com,  State@constructiondefects.com, Asha@constructiondefects.com, EHillier@washblaw.com,  THones@washblaw.com, Jknight@berdingweil.com, Cthomas@berdingweil.com,  Lolona@berdingweil.com, Bhirsch@berdingweil.com, Tnocco@berdingweil.com, Kpolk@cahill‐sf.com,  JPalmer@cahill‐sf.com, Rmartini@cahill‐sf.com, Aelizabethcostello@gmail.com,  Donklingbeil@gmail.com, Arun.Bhatia@sfdwp.org, Ngueylay@gmail.com,     CynthiaC@partnerscm.com, CarmenH@partnerscm.com, Karolo@partnerscm.com,  RebCohen999@sbcglobal.net, Kathlineking@yahoo.com, Cbretzin@gmail.com,  Cristin.morneau@gmail.com, Rebelcapitaladvisors@gmail.com, Maddydominick@hotmail.com,  HHW7878@yahoo.com, KristyandAlvin@gmail.com, kyle.algeo@gmail.com, Balog@climbsf.com,  Kevans@gmail.com, renee@hrhrealestate.com, Steven.Sheh@gmail.com,  Steven.sheh.300ivy@gmail.com, Cathy.edwards@gmail.com, Cathy300ivy@gmail.com,  Ariel_zach@yahoo.com, Sabrina.300ivy@gmail.com, Michele.300ivy@gmail.com,  300ivy305@gmail.com, William.e.russell.jr@gmail.com, Larrykern300@gmail.com,  KRISTYWEN@gmail.com, Audreycervantez15@gmail.com, Amanda.cifarelli@gmail.com,  34 Aditi.joshi34@gmail.com, Atishay.jain89@gmail.com, alankarchang@gmail.com,  alexandraliss@gmail.com, alinashah@gmail.com, achiu7@gmail.com, ann.lutzker@gmail.com,  anna.kolontyrsky@gmail.com, alehr1723@gmail.com, avnish.sabharwal@gmail.com,  Natalie.choy@gmail.com, Benchoy@gmail.com, Blake.m.osborn@gmail.com, bty200@gmail.com,  Brenns10@gmail.com, Cairokim@gmail.com, Clairekjackson@gmail.com, cxie08@gmail.com,  ctstraub@gmail.com, Crbarry17@gmail.com, ctunno@gmail.com, cyinglee44@gmail.com,  Danoosh.kapadia@gmail.com, Davelu@gmail.com, Davidsha@gmail.com, dygandcompany@gmail.com,  Eleanorlee@gmail.com, Erin.pettigrew@gmail.com, Gracezwho1@gmail.com, Hanshc@gmail.com,  jjstern14@gmail.com, Jacquelinefurrier@gmail.com, Jamison.fox@gmail.com, jasonpkriese@gmail.com,  jasonmok@gmail.com, jpcolaco1@gmail.com, jefferyhungsf@gmail.com, jslee7765@gmail.com,  jwheywood@gmail.com, jambajoyce@gmail.com, kalynyang@gmail.com, KHSU0720@gmail.com,  k8battles@gmail.com, kkoning5514@gmail.com, kihopkins@gmail.com, kunalakumar@gmail.com,  Laura.nelson.ca@gmail.com, Laiboon@gmail.com, leoylee@gmail.com, Markgrossman@gmail.com,  Matthew.fong@gmail.com, mehrdad.mobasher@gmail.com, Miko2005tw@gmail.com,  missyunilee@gmail.com, mina.dresden@gmail.com, Nckiwang@gmail.com, Nihalani.rahul@gmail.com,  Oliviavort@gmail.com, Pearlman.andrew@gmail.com, Rhkreger@gmail.com, radhika513@gmail.com,  radhikac1210@gmail.com, Rosalin49@gmail.com, shehkay@gmail.com, scotter1030@gmail.com,  SHERMEEN.PAVRI@gmail.com, sfchef12@gmail.com, Sirong.liang@gmail.com,  shyla.batliwalla@gmail.com, Spencer.uttley@gmail.com, stcady054@gmail.com, SGLutzker@gmail.com,  Taylormarcus@gmail.com, Tony.h.liu@gmail.com, Tracyc863@gmail.com, Uma105@gmail.com,  Vmalhi@gmail.com, Vyomesh.joshi@gmail.com, Wccheng@gmail.com, Yadathi@gmail.com,  Justchar@outlook.com, Whstuart@googlemail.com, Llazar@google.com, Joykao2000@icloud.com,  Rilely@icloud.com, Alags10@hotmail.com, Carlos_cm86@hotmail.com, Erickjvn@hotmail.com,  lianayingsu@hotmail.com, Maria_chiossi@hotmail.com, numazer@hotmail.com,  smekhalfa@hotmail.com, Aplutino@yahoo.com, al_laxman@yahoo.com, ethankan@yahoo.com,  gauravbhasin@yahoo.com, souhil.zaim@yahoo.com, terichappell@yahoo.com,  UshaTumkur@yahoo.com, tzippi_zach@yahoo.com, Fred.Hsu@3rdstone.ws,  JMoran@parksconservancy.org, David@ellnerconsulting.com, Atidman@mac.com, Vellner@mac.com,  Dennischang@alumni.stanford.edu, Vinodhini.lakshman@ucsf.edu, Brennan.spellacy@sonder.com,  chikodi@moonshotpr.com, ckwan@chokwancpa.com, JSmith@test.com, lauren@edgertons.com,  manonpaquet@live.fr, hillpropmanager@sbcglobal.net, mponce@alse.com.mx, serfriaz@live.com.mx,  William.Livermore@fsresidential.com, Todd.Caniglia@fsresidential.com, Natalie.valdez‐ smith@fsresidential.com, Jeanette.Zamora@fsresidential.com, Marco.Pulido@yahoo.com,  irmavillalobos@hotmail.com, curlysue713@yahoo.com, ramartinez@gmail.com, rapransky@gmail.com,  ms.ra.martinez@gmail.com, Cordon.Lucky@gmail.com, Paoneill@asu.edu, shaoyun925@hotmail.com,  Atsuko_Nakamura@hotmail.com, Paul.Ryan.201@hotmail.com, Hvchowdhary@gmail.com,  Neng1983@gmail.com, Amacrine67@icloud.com, WexlerSecretary@2730wilshire.com,  info@ericwexlermd.com, pialigeti@gmail.com, Geotff@outlook.com, Marcos.f.carrillo@gmail.com,  Victoriav561@gmail.com, Joe.Cicalo@wholefoods.com, Andyperez23@yahoo.com,  Bebelovesbo76@hotmail.com, Tribuno_alfa@hotmail.com, Jessicaflores05@gmail.com,  ymo73@hotmail.com    RecordsAccessOfficer@trs.nyc.ny.us, Investments@ocers.org, CalSTRSCIO@calstrs.com,  Compliance@calstrs.com, Sustainability@calstrs.com, ADACoordinator@calstrs.com,  NewsRoom@calstrs.com, Sbutler@calstrs.com, Crapolla@calstrs.com, WShuckell@calstrs.com,  Stong@calstrs.com, CAilman@calstrs.com, JDiedesch@calstrs.com, Atran@calstrs.com,  mtoepel@calstrs.com, vchitchakkol@ci.irvine.ca.us, vbeatley@sealbeachca.gov,  smontano@newportbeachca.gov, smontano@newportbeach.ca.gov, mmatsumoto@pico‐rivera.org,  Jeremy.Wolfson@ladwp.com, Fiona.Ma@treasurer.ca.gov, Ben.Meng@calpers.ca.gov,  Jason.Perez@calpers.ca.gov, Lisa.Middleton@calpers.ca.gov, Erania.Ortega@calpers.ca.gov,  Mona.PasquilRogers@gov.ca.gov, Mona.PasquilRogers@spb.ca.gov, ajohnson@treasurer.ca.gov,  bfowler@treasurer.ca.gov, bgrajski@treasurer.ca.gov, dallen@treasurer.ca.gov,  35 dcarrillo@treasurer.ca.gov, dbrown@treasurer.ca.gov, egorman@treasurer.ca.gov,  gpalmertree@treasurer.ca.gov, jwurm@treasurer.ca.gov, jmartinez@treasurer.ca.gov,  jgiordano@treasurer.ca.gov, kjohantgen@treasurer.ca.gov, mpaxson@treasurer.ca.gov,  rwebster@treasurer.ca.gov, tconnelly@treasurer.ca.gov, tpaine@treasurer.ca.gov, vau‐ yeung@treasurer.ca.gov, Kselenski@sto.ca.gov, InvestorRelations@treasurer.ca.gov,  Audrey.Noda@treasurer.ca.gov, Christina.SARRON@treasurer.ca.gov, Frank.Ruffino@treasurer.ca.gov,  Frank.Moore@treasurer.ca.gov, Gloria.Li@treasurer.ca.gov, Gloria.Pulido@treasurer.ca.gov,  Genevieve.Jopanda@treasurer.ca.gov, Judith.Blackwell@treasurer.ca.gov,  Jovan.Agee@treasurer.ca.gov, Kristin.Szakaly@treasurer.ca.gov, Kathryn.Asprey@treasurer.ca.gov,  Kasey.O'Connor@treasurer.ca.gov, Mark.Desio@treasurer.ca.gov, Noah.Starr@treasurer.ca.gov,  Robert.Berry@treasurer.ca.gov, Seth.Doulton@treasurer.ca.gov, Tracey.Paine@treasurer.ca.gov,  Tim.Schaefer@treasurer.ca.gov    AuditorGen@paauditor.gov, Budget@pa.gov, RA‐ethicsRTKL@pa.gov, achristman@nelp.org,  bchen@nelp.org, dberkowitz@nelp.org, gwentworth@nelp.org, krole@nelp.org,  Inspectorgeneral@cpsoig.org, Cmoreno@aft.org, BlackwellJ@ctpf.org, ReillyM@ctpf.org,  RedfeairnG@ctpf.org, CavalleroJ@ctpf.org, WardJ@ctpf.org, Jwaddell@aft1521.org,  lmarzillier@aft1521.org, sharonaft1521@gmail.com, lahc1521@gmail.com, parkcj@lacitycollege.edu,  robbdm@piercecollege.edu, mindy@post.harvard.edu, shewfeo@wlac.edu, russeltm@wlac.edu,  coloche@lahc.edu, fenyesm@laccd.edu, lees@lasc.edu, guerrij@lattc.edu, theodore@uic.edu,  gcities@uic.edu, AGREDAFE@elac.edu, JesseSharkey@ctulocal1.org, ChristelWilliams@ctulocal1.org,  MariaMoreno@ctulocal1.org, StacyDavisGates@ctulocal1.org, nmonteiro@mac.com,  drmarcelm@gmail.com, cofercw@gmail.com, jamesmckeever101@gmail.com,  joseph.guerrieri@gmail.com, phoenixmountain2@gmail.com, Zknorr@gmail.com,  Olgashewfelt@gmail.com, mcdowelljr@gmail.com, Pkallen3717@yahoo.com, Kyasuda62@hotmail.com,  rubybrou@hotmail.com, mmoon13956@aol.com, Sandraleephd@aol.com, sufiserf@aol.com,  sanpsych@aol.com, wder@social.rr.com, wdelarton@socal.rr.com    dorkin@oaktreecapital.com, Westcoastorkin@gmail.com, Shaoyun925@hotmail.com,  dkirchheiner@oaktreecap.com, jarnold@oaktreecapital.com, arnoldmd@aol.com,  Lsilva@canyonpartners.com, MCulp@oaktreecapital.com, Losorio@oaktreecapital.com,  NRedington@colonyinc.com, Jplaga@canyonpartners.com, Smansfeld@canyonpartners.com,  Pprak@canyonpartners.com, Lsilva@canyonpartners.com, Mpage@canyonpartners.com,  Dmillman@canyonpartners.com, Purrutia@clearlakecapital.com, Peter.Viles@tcw.com,  Lynn.kalbach@tcw.com, Fiona.huang@twc.com, Lindsey.Lennon@carlyle.com,  Elizabeth.gill@carlyle.com, Irina.Rudnitsky@tcw.com, PRivera@shamrockcap.com,  CPark@shamrockcap.com, AHoward@shamrockcap.com, SRoyer@shamrockcap.com,  LHeld@shamrockcap.com, MDiLorenzo@shamrockcap.com, Rohit.Subramaniam@duffandphelps.com,  Rohit.venkatasubban@gmail.com, investorrelations@marriott.com, IR@invesco.com,  Company.Secretary@invesco.com, Contactus@invescomortgagecapital.com, Patty.Dow@cbre.com,  Bonnie.m.wong@jpmorgan.com, edwin.k‐w.chin@jpmorgan.com, REA_Finance_‐ _Central@jpmorgan.com, Investor@gruposantander.com, Fidelity.Investments@mail.fidelity.com,  reportphish@wellsfargo.com, ofsrep.rumbbgw@wellsfargo.com, contacto@gmxt.mx, ri@telmex.com,  info@grupobmv.com.mx, vfueyo@homex.com.mx, ir@gruma.com,  daniela.lecuona@americamovil.com, investor.relations@americamovil.com,  anticorrupcion@americamovil.com, asuntoscorporativos@clarochile.cl,  codigoetica@americamovil.com, derechoshumanos@americamovil.com,  conflictointeres@americamovil.com, valores@americamovil.com,  seguridadinformatica@americamovil.com, infoconfidencial@americamovil.com,  privacidad@americamovil.com, clientes@americamovil.com, investor@uber.com,  Angela.Padilla@uber.com, raymond.galaviz@uber.com, tracey.merwise@uber.com,  nbartow@uber.com, press@uber.com, social@uber.com, tradingcompliance@uber.com,  36 ipteam@uber.com, competition@uber.com, Abengoa@abengoa.com.mx,  cam.espanola@camescom.com.mx, Jgange@dkpartners.com, Rebelcapitaladvisors@gmail.com,  Johnson@barkerpacific.com, Wsueiro@statestreet.com, Nathan@standishmanagement.com,  G.hill@standardinvestment.com, Jwurtz@pathfinderfunds.com, George.rupp@carioncapital.com,  anna.marie.lopez@hwcm.com, t.duanne@pefco.com, Ethics.Helpline@wal‐mart.com,  Luis.kolster@walmart.com, Alberto.mora@walmartlegal.com, Rainlay@walmart.com,  inversionistas@walmart.com, mjafern@outlook.com, Jessicaamassey@gmail.com,  claudia.delavega@walmart.com, Gabriela.buenrostro@walmart.com, Mario.Gonzalez@walmart.com,  Jimena.Rodriguez@walmart.com, Adriana.Garza@walmart.com, Mario.González@walmart.com,  miopinion@wal‐mart.com, donativosenespecie@walmart.com, Juanf.torreslanda@hoganlovells.com,  Michael.Mctiernan@hoganlovells.com, bill.flanagan@hoganlovells.com,  richard.climan@hoganlovells.com, Jaime.espinosa@hoganlovells.com, james.banks@hoganlovells.com,  Erin.brady@hoganlovells.com, maria.durant@hoganlovells.com, tjmckenna@gme‐law.com,  gegleston@gme‐law.com, dkreml@willkie.com, mweinstein@willkie.com, mmottesi@milbank.com,  calbarracin@milbank.com, rgordon@milbank.com, ron@ammonslaw.com,  patrick.luff@ammonslaw.com, miriah@ammonslaw.com, joy@ammonslaw.com, james@epinjury.com,  davidglenn@glennlawfirm.com, jesse@zambranolawfirm.com, edgar@zambranolawfirm.com    InvestorRelations@herbalife.com, Ericm@herbalife.com, CorporateSecretary@herbalife.com,  jlinder@mayerbrown.com, JuliaBa@herbalife.com, HenryW@herbalife.com, julieti@herbalife.com,  octaviomor@herbalife.com, juanfu@herbalife.com, josemic@herbalife.com, RonR@herbalife.com,  ReneT@herbalife.com, liag@herbalife.com, jarrellj@herbalife.com, patti@herbalife.com,  Aimeea@herbalife.com, lisashee@herbalife.com, reinas@herbalife.com, solomonb@herbalife.com,  roxanan@herbalife.com, juliap@herbalife.com, evali@herbalife.com, alinef@herbalife.com,  albertvil@herbalife.com, almao@herbalife.com, natalian@herbalife.com, valeriec@herbalife.com,  shareej@herbalife.com, fredh@herbalife.com, ryanb@herbalife.com, georger@herbalife.com,  bharris@kc.rr.com,  michaelj@herbalife.com, Benjamro@herbalife.com,  rbarbosa@barbosahuerga.com.mx,  ghuerga@barbosahuerga.com.mx, lortiz@ohoabogados.com.mx, ghernandez@ohoabogados.com.mx,  nieto@basham.com.mx, barrera@basham.com.mx, mbarajas@basham.com.mx,  zenteno@basham.com.mx, rswilloughby@pomlaw.com, pdahlstrom@pomlaw.com,  mvl@kerrwagstaffe.com, clune@kerrwagstaffe.com, nabity@kerrwagstaffe.com,  clune@kerrwagstaffe.com, law.west@gmail.com, kprendergast@raiglobal.com,  disputes@raiglobal.com, asmith@raiglobal.com, lisa.strickel@hireright.com, csmail@hireright.com,  Rohit.Subramaniam@duffandphelps.com, Rohit.venkatasubban@gmail.com, Emorton@ycst.com,  jbarry@ycst.com, rbartley@ycst.com, nlabovitz@debevoise.com, jball@debevoise.com,  cabruens@debevoise.com, info@equifaxbreachsettlement.com    jmatty@kpgm.com, inovak@kpmg.com, cneyra@kpmg.com, sjeffery@kpmg.com, kaitlynmoore@kpmg,  joannewilliamson@kpmg.com, Robert.moritz@us.pwc.com, DChrencik@hotmail.com,  Scott.w.tornberg@pwc.com, Tomoko.nagashima@us.pwc.com, Laurie.Endsley@us.pwc.com,  colm.r.kelly@pwc.com, mary.c.monfries@pwc.com, david.j.ryan@us.pwc.com,  anna.tantoco@pwc.com, frank.graziano@pwc.com, scottrhuff@gmail.com, irina.artem@us.pwc.com,  mitra.m.best@us.pwc.com, Kimberley Oloffson/US/ABAS/PwC, Barry P.  Benjamin/US/ABAS/PwC@Americas‐US, Michele L. Godvin/US/ABAS/PwC@Americas‐US, Karen  Stuckey/US/ABAS/PwC@Americas‐US, Derrick T Stiebler/US/ABAS/PwC@Americas‐US, Karen  Sierra/US/HR/PwC@Americas‐US, Kari B Henry/US/HR/PwC@Americas‐US, Richard  Ancona/US/GTS/PwC@Americas‐US    Susan.cote@ey.com, susan.rothfels@uk.ey.com, tracy.koh@my.ey.com, kelly.musmanno@ey.com,  alexis.lucas@ey.com, kathryn.tominovich@ey.com, carmine.disibio@ey.com, Patrick.niemann@ey.com,  thomas.flannery@ey.com, tfflannery@gmail.com, mark.weinberger@uk.ey.com,  37 michael.serota@ey.com, mark.gutierrez@ey.com, michael.odonnell@ey.com, joost.hendriks@ey.com,  david.cormack@ey.com, jim.mccaulley@ey.com, marc.roberts@ey.com, gabriel.marquez@ey.com,  roger.yang@ey.com, sandra.burns@ey.com, gregory.feng@ey.com, greg.glater@ey.com,  david.statman@ey.com, troy.jones@ey.com, allen.freeman@ey.com, keith.lupton@ey.com,  michael.johnson4@ey.com, garrett.behling@ey.com, jason.lin@ey.com, alex.borden@ey.com,  marie.buteauferland@ey.com, mariano.borges@ey.com, cynthia.ding@ey.com, ross.cockrell@ey.com,  jamey.p.johal@ey.com, elliot.kim@ey.com, helen.kim@ey.com, lynn.kim@ey.com,  james.kim1@ey.com, cathy.lai@ey.com, sara.lo@ey.com, franky.low@ey.com, kurt.rieck@ey.com,  michael.mendoza@ey.com, rob.masi@ey.com, marcus.marbrey@ey.com, mongwei.wee@ey.com,  brittney.watson@ey.com, janet.wang@ey.com, chloe.shen@ey.com, shawn.simmons@ey.com,  christopher.kearley@ey.com, kurt.neidhardt@ey.com, edwin.pisani@ey.com, joanne.dunbar@ey.com,  arthur.tully@ey.com, william.schlich@ey.com, alfredo.alvarez@mx.ey.com, oscar.santos@mx.ey.com,  rodrigo.ochoa@mx.ey.com, mario.karim@mx.ey.com, arturo.hernandez@mx.ey.com,  german.vega@mx.ey.com, francis.grab@ey.com, danielle.ryea@ey.com, joon.kim@ca.ey.com,  alan.thom@ca.ey.com, ana.johnson@mx.ey.com, pamela.mable@ey.com, ashley.giles@ey.com,  ben.carter@ey.com, dan.karen@ey.com, zoi.koutsogiannakopoulou@gr.ey.com,  Rohan.Small@ky.ey.com, Jeffrey.Short@ky.ey.com, Dan.Scott@ky.ey.com, Baron.Jacob@ky.ey.com,  Bill.Bailey@bm.ey.com, ashley.horne@ey.com, ey.fsotax@ey.com,  ey.fso.wealthassetmanagement@ey.com, fergus.mcnally@ie.ey.com, sinead.colreavy@ie.ey.com,  donal.osullivan@ie.ey.com, Muntasir.Khaleik@ie.ey.com, Cormac.Kelly@ie.ey.com,  Kieran.Daly@ie.ey.com, souza@ie.ey.com, Fergus.McNally@ie.ey.com, Ailbhe.MacManus@ie.ey.com,  Lisa.Kealy@ie.ey.com, michele.walker@ey.com, brian.mcilhinney@ey.com, brenda.betts@ey.com,  joseph.bianco@ey.com, samer.ojjeh@ey.com, dave.racich@ey.com, robert.mulhall@ey.com,  michael.estock@ey.com, jacqueline.bloom@ey.com, paul.kangail@ey.com,  michael.lee@ey.com, michel.kapulica@ey.com, scott.odahl@ey.com, joseph.n.micallef@ca.ey.com,  fraser.t.whale@ca.ey.com, dan.scott@ky.ey.com, jeffrey.short@ky.ey.com, fatima.de‐windt‐ ferreira@an.ey.com, bryan.irausquin@an.ey.com, christine.jha@ey.com, adrienne.main@ey.com,  matthew.koenig@ey.com, alex.johnson1@ey.com, shaun.real@ey.com, robert.glassman@ey.com,  tiffany.norris@bs.ey.com, jessel.mendes@bm.ey.com, flavio.s.peppe@br.ey.com,  pedro.custodio@br.ey.com, rohan.small@ky.ey.com, mike.mannisto@ky.ey.com,  marchello.gelashvili@ru.ey.com, petr.avramenko@ru.ey.com, ton.daniels@nl.ey.com,  remco.bleijs@nl.ey.com, mauro.iacobucci@it.ey.com, stefano.cattaneo@it.ey.com,  paolo.zucca@it.ey.com, karl.mercieca@mt.ey.com, ronald.attard@mt.ey.com, adam.miller@lu.ey.com,  michael.ferguson@lu.ey.com, helena.noren@se.ey.com, fredrik.stigerud@se.ey.com,  peter.franks@se.ey.com, monserrat.turradoalonso@es.ey.com, roberto.diezcerrato@es.ey.com,  anthony.cadman@za.ey.com, christian.soguel@ch.ey.com, fcarpenter@uk.ey.com,  mprice1@uk.ey.com, jyoung2@uk.ey.com, raitchison@uk.ey.com, ryaad.owodally@mu.ey.com,  daryl.csizmadia@mu.ey.com, matthieu.dautriat@ey‐avocats.com, hermin.hologan@fr.ey.com,  michelle.kotze@ae.ey.com, anthony.osullivan@ae.ey.com, dmoore@uk.ey.com,  ashwani.siotia@bh.ey.com, oliver.heist@de.ey.com, rosheen.dries@de.ey.com, mbane@uk.ey.com,  pduffy@im.ey.com, aegilmore@im.ey.com, jong‐yeol.park@kr.ey.com, jeong‐hun.you@kr.ey.com,  amy.ang@sg.ey.com, matthew.hanley@nz.ey.com, graeme.bennett@nz.ey.com,  kazuhiro.ebina@jp.ey.com, Sameer.gupta@in.ey.com, viren.mehta@in.ey.com, gavin.tang@cn.ey.com,  yeeckle.zhou@cn.ey.com, aj.lim@cn.ey.com, paul.ho@hk.ey.com, george.saffayeh@hk.ey.com,  antoinette.elias@au.ey.com, rohit.khanna@au.ey.com, jon.pye@au.ey.com    groa@deloittemx.com, knishimura@deloittemx.com, rgajdzik@deloittemx.com,  nalfaro@deloittemx.com, Sukahouaty@deloittemx.com, Surenkk@gmail.com,  migmillan@deloittemx.com, marellano@deloittemx.com, rtraconis@deloittemx.com,  jorgflores@deloittemx.com, brmaloney@deloitte.com, apdavis.com@deloitte.com,  stelarson@deloitte.com, snegangard@deloitte.com, kbernard@deloitte.com, lagarg@deloitte.com,  seprince@deloitte.com, Izagal@deloittemx.com, saradams@deloitte.com, saraadams@deloittemx.com,  38 fmaciasjasso@deloittemx.com, jcortina@deloittemx.com, jmatorres@deloittemx.com,  jegonzalezarellano@deloittemx.com, jgonzalezsaravia@deloittemx.com, sangutierrez@deloittemx.com,  corta@deloittemx.com, miggarcia@deloittemx.com, rimorales@deloittemx.com,  abaez@deloittemx.com, pberthely@deloittemx.com, mestrada@deloittemx.com,  oaguirre@deloittemx.com, argarciachavez@deloittemx.com, aanaya@deloittemx.com,  gmorenovega@deloittemx.com, joramirez@deloittemx.com, jotapia@deloittemx.com,  gondelatorre@deloittemx.com, robmorales@deloittemx.com, jrcarcano@deloittemx.com,  fcabanas@deloittemx.com, fcuahuencos@deloittemx.com, lpereda@deloittemx.com,  rosfuentes@deloittemx.com, jpalomino@deloittemx.com, lvalle@deloittemx.com,  victormedinagallo@deloittemx.com, jgarcia@deloittemx.com, gonzalezrodriguez@deloittemx.com,  jgarciavillalobos@deloittemx.com, nmerino@deloittemx.com, adcampos@deloittemx.com,  mariatorres@deloittemx.com, jocrivera@deloittemx.com, cachavez@deloittemx.com,  isdelgado@deloittemx.com, vdiaz@deloittemx.com, ensoriano@deloittemx.com,  cesagalvez@deloittemx.com, realonso@deloittemx.com, epozos@deloittemx.com,  adelcallejo@deloittemx.com, dhernandezfrontan@deloittemx.com,  egutierrezlegorreta@deloittemx.com, yteran@deloittemx.com, acolchado@deloittemx.com,  eshernandez@deloittemx.com, anagarcia@deloittemx.com, gosreview@deloittemx.com,  algonzalez@deloittemx.com, dgarcialozano@deloittemx.com, globalchair@deloitte.co.uk,  punit@deloitte.com, bseoane@deloittemx.com, jeguethoff@deloitte.com, mahmed@deloitte.com,  drheder@deloitte.com, centrodecontacto@deloittemx.com, eticayconducta@deloittemx.com,  anticorrupcion@deloittemx.com, JohnRussell@deloitte.ie, JoKehoe@deloitte.ie,  luismiguel@independencia.com.mx, bpacheco@independencia.com.mx,  jgarciamadr@independencia.com.mx, sergio.dominguez@ica.com.mx, guadalupe.torres@ica.com.mx,  bernardo.sepulveda@ica.com.mx, alejandro.gracida@ica.com.mx, nora.barbosa@ica.com.mx,  jose.guerrero@ica.com.mx, luis.romandia@ica.com.mx, paloma.grediaga@ica.com.mx,  juan.carlos.palomar@pemex.com, maricarmen.montano@pemex.com, Areli.perez@playaresorts.com,  paola.schilman@playaresorts.com, jm.ribas@playaresorts.com, ssastre@playaresorts.com,  rdiogo@playaresorts.com, PSaif@playaresorts.com, ir@playaresorts.com, press@playaresorts.com    Michael.Mctiernan@hoganlovells.com, Cbode@tpg.com, Doug.warner@weil.com,  Chris.machera@weil.com, Kyle.Krpata@weil.com, Nelsonj@gtlaw.com, Saylea@gtlaw.com,  brunoespindola@paulhastings.com, gonzalogutierrez@paulhastings.com,  emilywinston@paulhastings.com, elenapoleganova@paulhastings.com, joygallup@paulhastings.com,  leopoldogomezgrassi@paulhastings.com, pvelasco@s‐s.mx, theather@ritch.com.mx,  ldanton@ritch.com.mx, cobregon@ritch.com.mx, gdelvalle@ritch.com.mx, jpfarah@ritch.com.mx,  jberrueta@ritch.com.mx, lnicolau@ritch.com.mx, pperezalonso@ritch.com.mx, efreedman@cgsh.com,  ggaleotti@cgsh.com, fgaray@cgsh.com, ngrabar@cgsh.com, jcardona@cgsh.com,  apaul@whitecase.com, andrew.choe@balm.com, filo.fiorani@balm.com,     Joseph.Mazza@mcgladrey.com, Ron.kent@mcgladrey.com, Craig.Wickwire@mcgladrey.com,  Christine.Jung@mcgladrey.com, Tom.leyden@mcgladrey.com, Tracy.whetstone@mcgladrey.com,  Steven.Johnson@mcgladrey.com, Paige.Kuroyama@mcgladrey.com, Scott.Mackey@rsmus.com,  karen.jong@mcgladrey.com, Ericka.Foster@mcgladrey.com, Ellen.Burns@mcgladrey.com,  Michelle.McKenzie@mcgladrey.com, Leroy.Dennis@mcgladrey.com, allison.hovey@mcgladrey.com,  Byron.Whittlinger@mcgladrey.com, jack.rominger@mcgladrey.com, Tselby@wc.com,  BRobb@shilepsky.com, CNeff@foxrothschild.com, BRodos@foxrothschild.com,  PConnolly@foleyhoag.com, JLQ@foleyhoag.com, Marc.maselli@morganpartners.com,  JRudd@solutionsiq.com, Gmorein@gmail.com, George.Schlitz@gmail.com, Jamesiracundiff@gmail.com,  Garson@soelaw.com, Darrin_Ladd@hotmail.com, Stalley333@gmail.com, Stalley@kcrlegal.com,  Kelvin.Tetz@mossadams.com, Dkouame@bdo.com    39 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Sunday, May 16, 2021 5:42 PM To:paloaltofreepress@gmail.com Cc:Council, City; Jonsen, Robert Subject:PR vs. Public Access: Many Bay Area police agencies are issuing slick videos to justify police shooting, but critics say they twist the facts and undermine laws requiring transparency...( headline story front page of today’s Sunday Mercury News) must r... CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Sent from my iPhone    Begin forwarded message:  From: Aram James <abjpd1@gmail.com>  Date: May 16, 2021 at 5:22:53 PM PDT  To: Joe Simitian <supervisor.simitian@bos.sccgov.org>, Jeff Moore <moorej@esuhsd.org>, Raj  <raj@siliconvalleydebug.org>, hrc@cityofpaloalto.org, Richard Konda <rkonda@asianlawalliance.org>,  Planning.Commission@cityofpaloalto.org, CityCouncil <city.council@cityofpaloalto.org>,  city.council@menlopark.org, wilpf.peninsula.paloalto@gmail.com, city.council@menlopark.org, Tony  Dixon <Wadixon@menlopark.org>, tom.dubois@cityofpaloalto.org, Robert Jonsen  <Robert.Jonsen@cityofpaloalto.org>, Andrew Binder <andrew.binder@cityofpaloalto.org>,  cindy.chavez@bos.sccgov.org, Jeff Rosen <jrosen@dao.sccgov.org>, Jay Boyarsky  <jboyarsky@dao.sccgov.org>, supervisor.ellenberg@bos.sccgov.org, Rebecca Eisenberg  <rebecca@winwithrebecca.com>  Subject: PR vs. Public Access: Many Bay Area police agencies are issuing slick videos to justify police  shooting, but critics say they twist the facts and undermine laws requiring transparency...( headline  story front page of today’s Sunday Mercury News) must read —how our taxpayer money being spent  Follow the link below to view the article.  https://mercurynews‐ca‐app.newsmemory.com/?publink=21d0c4a89_1345d78      Sent from my iPhone  40 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Sunday, May 16, 2021 5:23 PM To:Joe Simitian; Jeff Moore; Raj; Human Relations Commission; Richard Konda; Planning Commission; Council, City; city.council@menlopark.org; wilpf.peninsula.paloalto@gmail.com; city.council@menlopark.org; Tony Dixon; DuBois, Tom; Jonsen, Robert; Binder, Andrew; cindy.chavez@bos.sccgov.org; Jeff Rosen; Jay Boyarsky; supervisor.ellenberg@bos.sccgov.org; Rebecca Eisenberg Subject:PR vs. Public Access: Many Bay Area police agencies are issuing slick videos to justify police shooting, but critics say they twist the facts and undermine laws requiring transparency...( headline story front page of today’s Sunday Mercury News) must r... CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Follow the link below to view the article.  https://mercurynews‐ca‐app.newsmemory.com/?publink=21d0c4a89_1345d78      Sent from my iPhone  41 Baumb, Nelly From:Pc User <pc77user@aol.com> Sent:Sunday, May 16, 2021 4:03 PM To:Council, City; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY Subject:genetically engineered Magneto proteins at DuckDuckGo CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    https://duckduckgo.com/?q=genetically+engineered+Magneto+proteins&t=iphone&ia=web      Best Regards, & Stay Healthy, Wealthy & Wise.  RJS  42 Baumb, Nelly From:Pc User <pc77user@aol.com> Sent:Sunday, May 16, 2021 3:52 PM To:BBC ONLY; Council, City; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; Courthouse News; Breaking News; BBC Westen | ONLY; Patriots Daily Post; Shaun King; Forbidden Knowledge TV; My Fellow Patriots; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY; BBC Westen | ONLY Subject:genetically engineered MAGNETO PROTEINS ! Is this what is causing magnets to stick to Injection Sites ?? CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Recent video on the net show small magnets sticking to the arms of people who have recently gotten the COVID‐19  shots.  Are these demonic Pharma manufacturers putting this hi‐tech stuff into the sheeple so they can control them  remotely ?   Possibly cause their blood sugar to rise, or increase their pulse rate until they stroke out and croak ???   If  you ask me, I would say that I suspect that there may be something very sinister going on.  Bone up on these genetically  engineered MAGNETO PROTEINS that the mad scientists seem to be in love with lately.  As we have heard and read  many times before, “It’s all about control”.        https://duckduckgo.com/?q=genetically+engineered+Magneto+proteins&t=iphone&ia=web      Best Regards, & Stay Healthy, Wealthy & Wise.  RJS  43 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Sunday, May 16, 2021 1:59 PM To:Council, City; Binder, Andrew; Jonsen, Robert; Human Relations Commission; rebecca@winwithrebecca.com; Planning Commission; wilpf.peninsula.paloalto@gmail.com; chuck jagoda; paloaltofreepress@gmail.com; ParkRec Commission; citycouncil@mountainview.gov; GRP- City Council; city.council@menlopark.org; Tony Dixon; Jeff Moore; Raj Subject:Black Americans disproportionately die in police Taser confrontations | Reuters (June 2020) CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    https://www.reuters.com/article/us‐minneapolis‐police‐protests‐tasers‐in‐idUSKBN23M16E      Sent from my iPhone  44 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Sunday, May 16, 2021 9:22 AM To:Channing House Bulletin Board; chopinion@gogglegroups.com Subject:Fwd: Survey Finds Many Unaware Of Surge In Hate Crimes Against Asian Americans – CBS San Francisco CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From: Allan Seid, Lynette Eng Lee  Date: Sun, May 16, 2021   Subject: Survey Finds Many Unaware Of Surge In Hate Crimes Against Asian Americans –   Source:  CBS San Francisco      https://sanfrancisco.cbslocal.com/2021/05/16/asian‐american‐attacks‐survey‐surge‐hate‐crimes/  Survey Finds Many Unaware Of Surge In Hate Crimes Against Asian Americans Betty YuMay 16, 2021 at 6:26 am SAN FRANCISCO (CBS SF) — A first of its kind survey from the newly formed group Leading Asian Americans to Unite for Change or LAAUNCH has found that Asian Americans are still largely invisible in society, despite their contributions and history in this country. “I’m shocked, I’m sad, I’m disappointed, but this is the data that suggests that we have a lot more work to do to,” said LAAUNCH board member Eric Toda. He was reacting to the finding that 37% of white Americans say they’re not aware of an increase in hate crimes and racism against Asian Americans over the past year. 24% said anti-Asian racism isn’t a problem that should be addressed. The results of the report from LAAUNCH are based on a survey of 2,766 US residents, ages 18 and over, conducted online between March 29 to April 14, 2021. Another big takeaway from the survey – 42% of people struggled to name a prominent Asian American today. 45 “The answer that they do have are Jackie Chan, who is obviously not American, and Bruce Lee, who has been deceased for quite some time,” said Toda. “And they don’t recognize Kamala Harris as an Asian American, and they haven’t said Andrew Yang, and so in prominence that just shows you that there is some level of hypocritical feelings.” That’s because half of non-Asian American respondents incorrectly believed the group is fairly or over-represented in leadership positions. 80% of Asian Americans, the fastest growing minority group in the US, said they face discrimination in America. On Saturday, actor and Oakland resident Daniel Wu energized the crowd at the Unite Against Hate march and rally to mark AAPI heritage month. Hundreds blew whistles in solidarity with similar events across the country at noon. The organizers and featured speakers, which included Mayor Libby Schaaf and President of Oakland’s Chinatown Chamber of Commerce Carl Chan, encouraged the crowd to support Asian-owned businesses and register to vote. “We know that we can’t solve these problems in the short-term, there are long term solutions,” said Wu. “It’s great to see the community united together like this, and this is a great moment, but we need to keep pushing.” LAAUNCH is doing so by sharing the new data with congressional leaders, including Representative Ted Lieu, to inform policy and push for Asian American history courses in classrooms. “We do believe that having this study out in the world will help gain more perspective, not just in the Asian American community, but all communities overall to understand the Asian American experience in America,” said Toda. “The more that we understand the Asian American experience in America the more we can have allies to support us.” Now that LAAUNCH has baseline data, they plan to conduct this survey annually to track changes in public perception over time. 46 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Saturday, May 15, 2021 10:13 PM To:Council, City; Joe Simitian; cindy.chavez@bos.sccgov.org; mike.wasserman@bos.sccgov.org; Planning Commission; Human Relations Commission; chuck jagoda; rebecca@winwithrebecca.com; wilpf.peninsula.paloalto@gmail.com; ParkRec Commission; Roberta Ahlquist; Shikada, Ed Subject:THE WALL STREET JOURNAL: Israel’s New Challenge: Violence Among Its Own Citizens CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Israel’s New Challenge: Violence Among Its Own Citizens  Arab and Jewish Israelis are increasingly clashing with one another; ‘an existential threat’   Read in The Wall Street Journal: https://apple.news/AQoQ‐6R5yRseevzYVakWk_Q    Shared from Apple News    Sent from my iPhone  47 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Saturday, May 15, 2021 9:09 PM To:Council, City; Human Relations Commission; Planning Commission; Roberta Ahlquist; wilpf.peninsula.paloalto@gmail.com; chuck jagoda; Shikada, Ed; ParkRec Commission; citycouncil@mountainview.gov; city.council@menlopark.org Subject:NYTimes: Tensions Among Democrats Grow Over Israel as the Left Defends Palestinians ( its about time the democrats defend the Palestinians)!!! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Tensions Among Democrats Grow Over Israel as the Left Defends Palestinians  https://www.nytimes.com/2021/05/15/us/politics/democrats‐israel‐palestinians.html?referringSource=articleShare      Sent from my iPhone  48 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Saturday, May 15, 2021 9:05 PM To:Council, City; Planning Commission; chuck jagoda; rebecca@winwithrebecca.com; Human Relations Commission; wilpf.peninsula.paloalto@gmail.com; Roberta Ahlquist; ParkRec Commission Subject:NYTimes: After Years of Quiet, Israeli-Palestinian Conflict Exploded. Why Now? CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    After Years of Quiet, Israeli‐Palestinian Conflict Exploded. Why Now?  https://www.nytimes.com/2021/05/15/world/middleeast/israel‐palestinian‐gaza‐ war.html?referringSource=articleShare      Sent from my iPhone  49 Baumb, Nelly From:aestheticstrength@gmail.com Sent:Saturday, May 15, 2021 6:55 PM To:Council, City Subject:I'm Voting to keep Ramona St Closed CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Palo Alto City Council: I enjoy the safe outdoor experience created with the closure of Ramona St. Please count my vote  to CLOSE Ramona St, through the summer.    Thank you      Sent from my iPhone  50 Baumb, Nelly From:Claire <ckillian113@gmail.com> Sent:Friday, May 14, 2021 10:30 PM To:Council, City Subject:I'm Voting to keep Ramona St Closed CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Palo Alto City Council: I enjoy the safe outdoor experience created with the closure of Ramona St. Please count my vote  to CLOSE Ramona St, through the summer.    Thank you      —  Claire Killian  Structural Engineering M.S. Candidate | Stanford  c: (707) 364‐7126  51 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Friday, May 14, 2021 7:47 PM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: Suspect arrested in hammer attack on Asian woman near Times Square CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.      From: Allan Seid <allanseid734@gmail.com>  Date: Fri, May 14, 2021   Subject: Suspect arrested in hammer attack on Asian woman near Times Square  Source: Yahoo News        https://news.yahoo.com/suspect‐arrested‐hammer‐attack‐asian‐141100687.html  Suspect arrested in hammer attack on Asian woman near Times Square Thu, May 13, 2021, 7:11 AM The person suspected of attacking an Asian woman with a hammer last week near Times Square has been arrested, police said Wednesday. Ebony Jackson, 37, has been charged with two counts each of felony assault, felony criminal possession of a weapon with a previous conviction and menacing, according to the New York City Police Department. She has no known address, and it was not clear Thursday if she had an attorney. The attack occurred about 8:40 p.m. ET May 2 on West 42nd Street between 9th and 10th avenues, in Hell's Kitchen in Manhattan, police said. Police released surveillance video that showed a woman appear to accost two Asian women walking on the sidewalk from behind. The woman demanded they remove their masks before striking one of them in the head with a hammer, police said. The suspect then ran away. 52 The New York Police Department's Hate Crimes Task Force is investigating the assault. The victim was identified as a 31-year-old woman who was taken to the hospital for a laceration to the head, according to authorities. The other Asian woman, 29, did not appear to suffer any physical injuries. The attack occurred just about a block from where a 65-year-old Filipino woman was knocked to the ground and repeatedly kicked outside a luxury New York City apartment building on West 43rd Street between 8th and 9th avenues. The suspect in that attack is a man who was convicted of murdering his mother in 2002, according to police. He was living at a nearby hotel that has served as a homeless shelter during the pandemic, officials said. Hours before the hammer attack, hundreds of New Yorkers, including city officials, gathered at a rally in Flushing, Queens, denouncing the wave of hate crimes against Asian American communities. The Stop Asian Hate march was held a day after two other Asian Americans were targeted in separate attacks in Queens and Brooklyn, police said. A recent analysis of hate crime data revealed that the increase in anti-Asian attacks has remained consistent. The analysis, released by the Center for the Study of Hate and Extremism at California State University, San Bernardino, found that hate crimes surged 169 percent when comparing the first quarter of 2021 to the same time period in 2020 across 15 major cities. New York City accounted for the largest surge, from 13 hate crimes in the first quarter of 2020 to 42 in the same period this year — a 223 percent jump, according to the research. 53 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Friday, May 14, 2021 6:05 PM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: 15-Year-Old Called 'Ch*nk', Repeatedly Punched in the Head at Playground in Queens CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From: Allan Seid <allanseid734@gmail.com>  Date: Fri, May 14, 2021 at 5:16 PM  Subject: 15‐Year‐Old Called 'Ch*nk', Repeatedly Punched in the Head at Playground in Queens  Source: Yahoo News      https://news.yahoo.com/15‐old‐called‐ch‐nk‐222846073.html  15‐Year ‐Old Called 'Ch*nk', Repeatedly Punched in the Head at Playground in Queens Fri, May 14, 2021, 3:28 PM 54 A 15‐year‐old was jumped and punched in the head while he was at a playground in the Rego Park of Queens, New York. What happened: Leting Cai, 15, was at a playground with his friends when two other teenagers started harassing and insulting them with racial slurs on May 1, according to ABC7.  Cai told CeFaan Kim of ABC7 that one of the teens called him "ch*** ch****" but he wasn't going to take it and dared them to say the slur again.  He stood his ground and just as he thought it was over, he noticed the pair on the phone calling for backup.  Three other teenagers came and jumped him when his back was turned to them.  "What followed was a relentless barrage of punches to the head," reports Kim. The charges: Police arrested three out of the five suspects including two 14-year- old boys and one 18-year-old girl.  The suspects have been charged with misdemeanor assault and harassment.  NYPD Hate Crimes Task Force is reportedly currently investigating. The aftermath: Cai suffered a bruised head, a swollen eye and had a headache for weeks following the attack. 55 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Friday, May 14, 2021 4:56 PM To:Channing House Bulletin Board; chopinion@gogglegroups.com; Allan Seid; ADAM SEID; ALBERT CHING; ALEX LEE; ALEX LEE; ALICE WOO; ALLAN CHIN; AMADO PADILLA; AMY YANG; ANDREA WOLF; Anita Wong Kwock; ANN XU; ANNE CLARK; ANNE IM; ANNE SEID CHAN; ANNIE CHO; ANTHONY LIN; ARLENE SEID; BALDWIN CHIU; BEN and FRANCES BURR; Bill Johnson; CAROL BACHETTI; CAROLE CHINN; CHARLENE LIAO; CHARLOTTE FU; CHRIS and MAX WEI; Christian Jochim, PhD; CHRISTIE LI; CHRISTINE PHAM; CHRISTY CHUNG; CONNIE YOUNG-YU; DAIMEN SEID; DALE LIEBES; DALE TROCKEL; Dan & Shirley Mock; DAVID KWOH; DAVID THORNTON; DAVID TORIN; DEBRA HUI CEN; DESI. HAMMOND SEID; DIRK BENNETT; DON AUSTIN; Summa, Doria; EILEEN. CHOW; EIMI OKANO; ELAINE SEID; ELIZABETH HUNT; ELIZABETH SCHMIDT; ELLEN KAMEI; ELLENBERG; EMORY LEE; Filseth, Eric (external); ERNIE ORDUNA; EUGENE MOY; EUNICE CHENG; EVA TROCKEL; EVAN LOW; FLO OY WONG; Flowers Nancy; FRANCES MORSE; FRANCES SHIH; GARRET VAN DYKE; GAY YUEN; GAYLE CHAN; GILBERT WONG; GINA DALMA; GINA DALMAS; GINGER LAI; GREER STONE; GREG TANAKA; HANNAH LU; HELEN LEI; HELEN TSOU; HELEN YOUNG; HENRY DER; IAN AITCHISON; ISAO KOBASHI; JACK SUN; JADE CHAO; JAQUI GUZMAN; JEAN AITCHISON; JEANETTE ARAKAWA; JEFF ROSEN; JEFFREY LEE; JENNIFER DIBRIENZA; JERRY UNDERDAL; JESSIE FURUKAWA; JINGjing XU; JOE SIMITIAN; JOHN A. MOORE; JOHN SINK; JOHN STCLAIR; JORGE WONG; JOY SLEIZER; JULIE CHANG; K.C. CHAE; KAREN MORRISON; Kathleen GOLDFEIN; KELLY CHAU; KELLY TSAI; KENNETH DAUBER; KERI WAGNER; KIANA SEID; KIMBERLY ENG-LEE; KIMBERLY KIM-SHIMAZAKI; LADONNA YUMORIKAKU; LADORIS CORDELL; LARRY GERSTON; LAURIE SEID; LENNIE STOVEL; LILY LOH; LIN SUN-HOFFMAN; LINUO LIANG; LUCIA CHA; LYDIA KOU; LYNDA WOO; LYNETTE LEE-ENG; LYNN MITCHELL; LYNNE FAUST; M KITAYAMA; MAGGIE; MANUEL HERRERA; MARC BERMMAN; MARC. ALLAN SEID; MARCIA PUGSLEY; MARCINE SEID; MARGARET ABEKOGA; MARIA MAO; MARLYS KEOSHIAN; MARSHA FONG; MARY ALICE THORNTON; MARY ANNE SIMPSON; MARY BETH TRAIN; MARY MUNTER; MARY VINCENT; MARY. ANN MICHEL; MEI KUANG; MICHAEL CHU; MICHAEL FONG; MICHAEL HONDA; MICHAEL SETO; MICHELE LEW; MICKEY TROCKEL; MIKE ENG; MIKE WOO; MIKI PAN; MILDRED JONES; MIN and LI JEN (TRUONG) LAM; MINI SAMANTARAY; MOLLY VAN DYKE; MONICA DAVIS; MONICA LYNCH; MONICA YEUNG ARIMAS; MUNSON KWOK; Myrna & Will Tsukamoto; NANCY FLOWERS; NELSON BUCHANAN; OTTO LEE; Council, City; PAMELA C. SEID; PAT BURT; PATRICK KWOCK; PAUL FONG; PAUL WONG; PINKI and DANIEL LEE; PINKIIO FUNG; RHONDA BEKKEDAHL; RICHARD KONDA; RONA HU; ROSE SEID; ROSEMARY KAMEI; ROSS PUSEY; ROY & PJ HIRABYASHI; ROY TAKEUCHI; RUBY HE; SABRIYA SEID; SALLY WU; SAMRETH NUON; SANDY SONGY; SARA ARMSTRONG; SARA Woodham; SARITA KOHLI; SHARON VEECH; SHOUNAK DHARAP; SIU KUEN HA; SKYLER DITTMAR; SLOAN SEID; SOPHIA LIU; Stephen Lee; STEVE PREMINGER; SUELLEN KWOK CHANG; SUSAN GILBRT; SUSAN HAYASE; T.H. SHIH; TERRY McCAFFREY; Timothy Van Dyke; TITI LIU; TOM DUBOIS; TOM TSAI; TOM VICIAN; TOMARA SEID; TRINH PHAM; VICTOR OJAKIAN; VICTOR wong; WEI DONG; WES MUKOYAMA; WILLY WONG; YUKARI LAKE; YVETTE LEE; att.low@gmail.com Subject:Fwd: TOMORROW - Unity Against Hate Rally Location/Virtual Information CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From: Therese Twomey <therese@highviewstrat.com, Allan Seid  Date: Fri, May 14, 2021 at 4:36 PM  Subject: TOMORROW ‐ Unity Against Hate Rally Location/Virtual Information  56   Thank you for your support of the Unity Against Hate rally.     You are receiving this email because you previously contacted info@communityagainsthate.org. Please feel free to  share.     To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.Unity Against Hate FB event cover template Join us TOMORROW! In Washington D.C., New York, California, Texas, Ohio and cities all across America to denounce hate crimes against the AAPI community. Hear from elected officials. Stand with more than 80 organizations. Be seen and heard! Check out rally locations/times in a city near you. Rally Locations/Times To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.washi ngton mon umen t 2 Attend Virtually If you are unable to attend in person, join the live-stream beginning at 11:00 am PDT or 2:00 pm EDT via Zoom. Virtual Rally Have questions? info@communityagainsthate.org 58 Baumb, Nelly From:Mariela Silva Pizarro <mpizarro@stanford.edu> Sent:Friday, May 14, 2021 1:50 PM To:Council, City Subject:I'm Voting to keep University Ave Closed CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear Palo Alto City Council:    I enjoy safely dining outdoors on University Ave with the street closed from traffic. Please count my vote for city street  CLOSED through the summer for a safe, socially distanced experience.    Thank you,  Mariela Pizarro‐Silva      Sent from my iPhone  59 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Friday, May 14, 2021 11:05 AM To:Allan Seid; Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: This prosecutor is on a mission to help the Asian Pacific Islander community fight race-based crime CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From: Allan Seid  Date: Fri, May 14, 2021 at 10:54 AM  Subject: This prosecutor is on a mission to help the Asian Pacific Islander community fight race‐based crime  Source: Palo Alto Weekly , (paloaltoonline)      https://www.paloaltoonline.com/news/2021/05/14/this‐prosecutor‐is‐on‐a‐mission‐to‐help‐the‐asian‐pacific‐islander‐ community‐fight‐race‐based‐crime?utm_source=express‐2021‐05‐ 14&utm_medium=email&utm_campaign=express#.YJ65Kp0Ud80.mailto  60 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Friday, May 14, 2021 8:19 AM To:Allan Seid Subject:Apology CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Friends,     I deeply regret that my news information yesterday had the repugnant title "BLM Attacking and  Robbing Asians." The best I can determine is a regular AAPI supporter of progressive causes and of the Black  Lives  Movement passed on the article to me and I was not careful in spotting his unintended, offensive and inaccurate  title before emailing it out to you.    Indeed our causes as AAPI people are intimately tied to and united with the fight by the BLM; the racial and social  injustice perpetrated on our African‐ American sisters and brothers are mirrored in similar inequalities suffered by us  along with other colored minorities. I am sorry to have been asleep at the wheel and caused you any distress.     In solidarity,    Allan Seid                                                         61 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Thursday, May 13, 2021 11:09 PM To:Jonsen, Robert; Binder, Andrew; Jeff Moore; Planning Commission; Human Relations Commission; rebecca@winwithrebecca.com; chuck jagoda; wilpf.peninsula.paloalto@gmail.com; Roberta Ahlquist; Council, City; GRP-City Council; citycouncil@mountainview.gov; city.council@menlopark.org; ParkRec Commission; Perron, Zachary; Shikada, Ed; Greer Stone Subject:Police Transparency equals police accountability? CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  https://apnews.com/article/us‐news‐police‐reform‐police‐government‐and‐politics‐ fa6cbd7e017b85aa715e23465a90abbe    Shared via the Google app    Sent from my iPhone  62 Baumb, Nelly From:Monica Yeung Arima <myarima@gmail.com> Sent:Thursday, May 13, 2021 10:02 PM To:Monica Yeung Arima Subject:2021 International COVID-19 Conference: Lessons Learned | CARE | Stanford Medicine CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Hi All,    A reminder for tomorrow’s Stanford conference on covid19. Need registration to participate, please share:    We cordially invite you to explore this question at our 2nd International COVID‐19 Conference: Lessons Learned. The  virtual conference will take place on Friday, May 14th, 7:30 AM to 3:30 PM (Pacific Standard Time).    This multi‐disciplinary Conference will bring together public health officials, researchers, and physicians to share lessons  learned from COVID‐19. Together, we endeavor to increase knowledge, empower education, and positively impact our  response to this pandemic. In funding innovative research, educating promising scholars, and community outreach, we  seek to improve healthcare both locally and globally.    Please join us in this bold initiative, and together we can make a difference in the continued fight against COVID‐19.  Need registration to participate, see below.  Sincerely,    https://med.stanford.edu/care/events/2021‐international‐covid‐19‐conference‐‐lessons‐ learned.html?fbclid=IwAR35IsIbbnQqiIetAWr16‐ ps__OBC7OhcAiI6KcxGUZvciTeKJTKsLuQELw&from=message&isappinstalled=0      Sent from Monica Yeung Arima's iPhone  www.myarima.com  650 888‐4116  63 Baumb, Nelly From:John Drago <johndrago212@gmail.com> Sent:Thursday, May 13, 2021 8:33 PM To:Council, City Subject:I'm Voting to keep Ramona St Closed CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Palo Alto City Council: I enjoy the safe outdoor experience created with the closure of Ramona St. Please count my vote  to CLOSE Ramona St, through the summer.    Thank you  64 Baumb, Nelly From:Nancy Alfaro <alfaro.nancy@gmail.com> Sent:Thursday, May 13, 2021 6:42 PM To:RecordsAccessOfficer@trs.nyc.ny.us; Investments@ocers.org; CalSTRSCIO@calstrs.com; Compliance@calstrs.com; Sustainability@calstrs.com; ADACoordinator@calstrs.com; NewsRoom@calstrs.com; Sbutler@calstrs.com; CRapolla@calstrs.com; WShuckell@calstrs.com; stong@calstrs.com; CAilman@calstrs.com; JDiedesch@calstrs.com; Atran@calstrs.com; mtoepel@calstrs.com; vchitchakkol@ci.irvine.ca.us; vbeatley@sealbeachca.gov; smontano@newportbeachca.gov; smontano@newportbeach.ca.gov; mmatsumoto@pico-rivera.org; Jeremy.Wolfson@ladwp.com; Fiona.Ma@treasurer.ca.gov; Ben.Meng@calpers.ca.gov; Jason.Perez@calpers.ca.gov; Lisa.Middleton@calpers.ca.gov; Erania.Ortega@calpers.ca.gov; Mona.PasquilRogers@gov.ca.gov; Mona.PasquilRogers@spb.ca.gov; ajohnson@treasurer.ca.gov; bfowler@treasurer.ca.gov; bgrajski@treasurer.ca.gov; dallen@treasurer.ca.gov; dcarrillo@treasurer.ca.gov; dbrown@treasurer.ca.gov; egorman@treasurer.ca.gov; gpalmertree@treasurer.ca.gov; jwurm@treasurer.ca.gov; jmartinez@treasurer.ca.gov; jgiordano@treasurer.ca.gov; kjohantgen@treasurer.ca.gov; mpaxson@treasurer.ca.gov; rwebster@treasurer.ca.gov; tconnelly@treasurer.ca.gov; tpaine@treasurer.ca.gov; vau- yeung@treasurer.ca.gov; Kselenski@sto.ca.gov; InvestorRelations@treasurer.ca.gov; Audrey.Noda@treasurer.ca.gov; Christina.SARRON@treasurer.ca.gov; Frank.Ruffino@treasurer.ca.gov; Frank.Moore@treasurer.ca.gov; Gloria.Li@treasurer.ca.gov; Gloria.Pulido@treasurer.ca.gov; Genevieve.Jopanda@treasurer.ca.gov; Judith.Blackwell@treasurer.ca.gov; Jovan.Agee@treasurer.ca.gov; Kristin.Szakaly@treasurer.ca.gov; Kathryn.Asprey@treasurer.ca.gov; Kasey.O'Connor@treasurer.ca.gov; Mark.Desio@treasurer.ca.gov; Noah.Starr@treasurer.ca.gov; Robert.Berry@treasurer.ca.gov; Seth.Doulton@treasurer.ca.gov; Tracey.Paine@treasurer.ca.gov; Tim.Schaefer@treasurer.ca.gov Cc:Mayor.Garcetti@lacity.org; mayor@fresno.gov; Daniel.Zack@fresno.gov; Mark.Standriff@fresno.gov; Esmeralda.Soria@fresno.gov; Paul.Caprioglio@fresno.gov; Robert.Andersen@fresno.gov; Leager@fresnoedc.com; Council, City; Office of the CIO; TomforCouncil@gmail.com; Ng, Judy; LydiaKou@cityofpaloalto.org; Kane@cityofpaloalto.org; Carnahan, David; Stephanie.Douglas@cityofpaloalto.org; Yang, Albert; Patel, Raj; Auzenne, Tom Subject:Fwd: Cyberattack Forces Shutdown Of Largest Gasoline Pipeline In United States | ZeroHedge V2 CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Begin forwarded message:  From: "." <alfaro.nancy@gmail.com>  Date: May 13, 2021 at 6:02:58 PM PDT  To: contacto@senadomorena.com, SINDICATO@senado.gob.mx,  SINDICATO969.transparencia@senado.gob.mx, gobernacion@senado.gob.mx,  Transparecia@senado.gob.mx, puntosconstitucionales@senado.gob.mx,  derechoshumanos@senado.gob.mx, anticorrupcion@senado.gob.mx, hacienda@senado.gob.mx,  justicia@senado.gob.mx, marina@senado.gob.mx, webmaster@semar.gob.mx, cni@cni.gob.mx,  asuntosindigenas@senado.gob.mx, ninezyadolescencia@senado.gob.mx, economia@senado.gob.mx,  salud@senado.gob.mx, educacion@senado.gob.mx, trabajoyprevision@senado.gob.mx,  reformaagraria@senado.gob.mx, agriculturayganaderia@senado.gob.mx, energia@senado.gob.mx,  comunicacionesytransportes@senado.gob.mx, asuntosfronterizos@senado.gob.mx,  comsegsocial@senado.gob.mx, crpp@senado.gob.mx, seguridadpublica@senado.gob.mx,  65 seguridad.nacional@diputados.gob.mx, defensanacional@senado.gob.mx,  derechos.arco@funcionpublica.gob.mx, carmina.jasso@sociales.unam.mx,  alternativedevelopment@unodc.org, cristobal.arias@senado.gob.mx,  alejandro.gonzalezy@senado.gob.mx, nestora.salgado@senado.gob.mx, ruben.rocha@senado.gob.mx,  felix.salgado@senado.gob.mx, lcalderonh@senado.gob.mx, webmaster@congreso.gob.mx  Cc: sbarragan@aristeguinoticias.com, redaccion@aristeguinoticias.com, careyshenkman@riseup.net,  courage.contact@couragefound.org, transportandoamichoacan@live.com,  periodicooficial@michoacan.gob.mx, buzon@poderjudicialmichoacan.gob.mx,  Comercializacion@telesurtv.net, Albinocm6502@gmail.com, JuanJosedelCastillo@gmail.com,  Borderlinebeat@gmail.com, Charropoliticoenvivo@gmail.com, Conexiononline1@hotmail.com,  wells@wsws.org, autoworkers@wsws.org, sep@socialistequality.com, Norissa@socialism2020.org,  joe@socialism2020.org, Christine.s.Richard@gmail.com, Aaron.Greenspan@plainsite.org,  realitycheck@plainsite.org, VeritasTIPS@protonmail.com, richard.clayton@ctwinvestmentgroup.com,  noe.cruz@eluniversal.com.mx, denuncia@eluniversal.com.mx, contacto@eluniversal.com.mx,  atiempomx@gmail.com, indicepolitico@gmail.com, Investigacion@elpais.es, jlsc.ua@gmail.com,  WorldsApart@rttv.ru, charles@russia‐insider.com, moderator@russia‐insider.com,  radio@sputniknews.com, mediapartners@sputniknews.com, advertising@sputniknews.com,  media@sputniknews.com, marketing@sputniknews.com  Subject: Fwd: Cyberattack Forces Shutdown Of Largest Gasoline Pipeline In United States | ZeroHedge  V2        Thomas Flannery (EY, Sr. Audit Partner)   Co‐leader, Americas Wealth and Asset Management, EY Boston    From the start, these emails refer to Energy Security and critical infrastructure, supply chains  vulnerabilities and national defense.     Sophisticated criminals with ongoing access to IT systems and critical infrastructure its the opposite of  random hackers (i.e. cyber‐chupacabras).     The point of highlighting continuous cyberattacks aimed at disrupting and obstructing   my emails (electronic communications) since July 2019 has been to distort the information and  sabotage other people.     It's clear opportunistic criminals weren't interested in containing or eliminating me as "credible  threat"  but on maintaining control over the flow of information included in these emails.     Cyber‐security is a lucrative enterprise that has embolden criminals. Without a "credible threat" to  "contain" or "eliminate" opportunistic criminals can't profiteer.     The methods and tactics use against me should be a "red alert" to everyone given the implications and  years of increasing violence. Who or what was the threat?       Supply Chain Disruptions   Herbalife/Wal‐Mart,  consumer products companies, references to Logistics and Transportation involve  inventories, supply chains and suppliers. Just‐in‐time manufacturing/just‐in‐time inventories (lean  inventories). are risk averse strategies and incompatible with American corporations excessive risk  taking culture. Significant Supply chain risk     66 As noted several prior email communications and most recently on May 8, 2021 and May email  communication (email sent right before this email) subject: "Illicit Financial Flows, Trade Misinvoicing,  and Multinational Tax Avoidance: The Same or Different? ‐ EY‐Wal‐Mart as an model "    In April 2012, Felipe Calderon was  communicating with and publicly defending Walmart as Walmart's  bribery and corruption scandal was being made public by the New York Times. Specifically, Calderon was  touting Wal‐Mart's  logistics/supply chain as a model to be follow in Latin America. Again, Read the  fucking news paper.     Customs agents aren't bribed by anyone transporting legal products in or out of the country.  If both  Walmart and Herbalife were paying bribes to custom agents and the DEA was involved, the issues are  very different than what corporate criminals claimed was and is happening in Mexico.  The DEA focuses  on drug trafficking and money laundering and operates in foreign soil. The DEA or the FBI  aren't even  qualify or permitted to speak to me in private or in public.      The SEC/DOJ can't be in possession of incriminating evidence against foreign corporate executives prior  to opening an FCPA investigation because Its illegal for US law enforcement to stick its nose in foreign  jurisdictions.  This means there are DEA/FBI and US Corporate Rats and criminals involved in mayor  criminal activity i.e. fabricating evidence against innocent people in foreign nations.     Disrupting my emails (flow of information) is unlike a supply chain disruption. Example: Ford can't get  semiconductor chips, thousands of its best selling trucks will remain parked at the Kentucky Speedway  awaiting chips.     Unfinished vehicles (Ford's inventory) can't be sold until the chip shortage problem is resolved. This is a  Big unknown. Unfinished inventory (cost‐of‐goods‐sold, significant cash outflow) and storage costs  (unexpected negative cash outflows) is costing Ford millions of dollars and trigger a liquidity crisis.  Whatever stories Ford and Wall Street Analysts want to sell publicly is irrelevant to me. I am the elite Big  Four Public Accountant, I visualized Ford's entire cost structure in my head as reflex.     A company with no incoming cash flows and significant cash outflows (Ford vehicles sitting in a Parking  lot) under the current  economic climate (Covid‐19, Globalists, Climate Change Agenda, Telsa, EVs) and  extreme market conditions (Global Corporate War) could be facing a potential meltdown overnight.    Logic: Ignoring everything else, Tesla will have to bankrupt Ford and get Toyota on its knees, as a start.     Americans don't even buy their own American cars. Mexicans don't drive and have a very low opinion of  American made cars. This isn't a new thing, It goes back 50 years. Making shitty American cars that  break down is intentional. Its a corporate strategy to profiteer from constantly selling (volume)  expensive car repairs services and components to repair its shitty vehicles. The more American vehicles  breaks down, the better for Corporate America's bottom line. Quantity over Quality.    It isn't just Ford's unsold inventory sitting at in a Parking lot awaiting a chip component the real the cash  flow issue crippling Ford or the American Auto industry is it? The supply chain disruptions affect a lot  more car components than just low level semiconductors chips. How is Corporate America going to fix  its shitty Cars that are already being driven on the streets if it can't get  car components? What Labor  services (its employees manual labor) are being sold?     The American Auto Industry is bluffing. I drive a German car ‐ 2008 Mercedes E350. I have been getting  shit from the DMV on vehicle emissions since 2013‐2014. I caught the DMV and smog check emissions  shops in a fraudulent scheme over emissions testing and the emissions on my car. The emissions test  telenovela with my E350 Mercedes for over 12 months consists of leveling claims that the car has a  67 some sort of "unknown" fatal engine flaw and it can't pass the smog test in CA. Of course, the US  Mercedes dealership demanded hundreds of dollars just to "check" the unknown fatal engine.  My car  has less than 50 thousand miles. Everyone outside the CA approved smog check testing shops and  American dealerships burst out laughing at the scam.   The US Mercedes dealership bullies quickly back‐off once I informed them I was contacting the  American and German regulators to so they can agree which country is getting its ass nailed to a wall for  fraud.  CA is pushing Climate Change and twisting Germany's arm over the Russian pipelines and  extorting them to buy LGN instead of Russian natural gas. Not very hard to what is going on with my  German made car.     FYI ‐ I am under close surveillance. The issues with my car are being observed and heard via phone calls  in CA and Michoacán. My car was tamper with in 2014 as well.Like I said, the schemes involving property  destruction by flooding (plumbers), Property Management Companies,  State Farm Insurance, and  insurance claims were a repeat of 2014. Unsurprisingly, the Property Management plumbing company  has been replaced. I warn the property management company not get into any legal coverups and  schemes related to my property.  Refer back to the electricity and water issues at my LA property emails  from November 2020 ‐ December/January 2021.      What stupid property managers lawyer advice them fool the Bentley Rose HOA Board to request a third  plumbing inspection and require a monitor observe the inspection just so the property manager could  cover its ass. Since we all agreed with three plumbing inspections there weren't any water issues inside  my unit, the Property Manager can't turn around and start desperately nagging me for the last two‐ three months to give them access to my apartment  to repair some "leak" in the parking lot right below  my unit.     I do not have any water or leaky faucets issues. I don't allow entrance to my unit. Just as the property  manager believes is generating documents in preparation for legal issues, so are others.  The Property  Manager isn't going to turn its own separate legal issues into my problem.  Whoever got in bed with  opportunistic criminals i.e. lawyers schemes, they get to deal with their shit themselves.  There aren't  any small time or incompetent criminals snooping and surveilling my every move 24/7.     Learn  Complex systems thinking capabilities + knowledge  Public Accountant + Public Auditors + Sarbanes‐Oxley 404 work ‐ Controls over IT systems and  infrastructure in global corporate enterprises.     IT controls and security over systems protecting critical IT systems and infrastructure.    isn't the same thing as cybersecurity.      System Shocks and Supply Chain disruptions with severe impact to the US and global economies and  human life.  Who got to hired by Colonial to secure the pipelines?   Me or a cybersecurity firm?     The Colonial Pipeline cyberattack (Royal Dutch Shell and Koch Industries)is just the latest incident in a  series of increasingly debilitating attacks against critical infrastructure.  Colonial Pipeline headquartered  in Alpharetta Georgia.    FYI ‐these email was drafted and pretty much complete and casually being discussed over the phone,  when Colonial "suddenly" reopened its Pipeline. I don't even talk to communicate with the cybersecurity  creeps.      68 Did you think the issues with my spectrum cable on May 8, 2021 and the May 12, 2021 lost email  detailed in my previous email communications or the releasing the investigation  and article below was a  coincidence?      Read again.      Cryptos Slide After Report Binance (World's biggest crypto currency) Under Investigation By IRS, DOJ |  May 13, 2021  https://www.zerohedge.com/markets/cryptos‐slide‐after‐report‐binance‐under‐investigation‐irs‐doj    It's not a good day for cryptos which after being hammered earlier on the Elon Musk reversal, just legged lower after a Bloomberg report that the world's biggest cryptoexchange Binance is under investigation by the Justice Department and Internal Revenue Service. The report notes that "officials who probe money laundering and tax offenses have sought information from individuals with insight into Binance’s business." Binance ‐ which is led by Changpeng Zhao, "a charismatic tech executive who relishes promoting tokens on Twitter and in media interviews" ‐ is incorporated in the Cayman Islands and has an office in Singapore but says it lacks a single corporate headquarters. Chainalysis Inc., a blockchain forensics firm whose clients include U.S. federal agencies, concluded last year that among transactions that it examined, more funds tied to criminal activity flowed through Binance than any other crypto exchange. To be sure, in the aftermath of the Colonial Pipeline ransomware hack - where we learned that the hackers were immediately paid $5 million in crypto - it was virtually inevitable that there would be some blowback. “We take our legal obligations very seriously and engage with regulators and law enforcement in a collaborative fashion,” Binance spokeswoman Jessica Jung said in an emailed statement, while adding that the company doesn’t comment on specific matters or inquiries. “We have worked hard to build a robust compliance program that incorporates anti-money laundering principles and tools used by financial institutions to detect and address suspicious activity.” Meanwhile, Zhao has said Binance closely follows U.S. rules, blocks Americans from its website, and uses advanced technology to analyze transactions for signs of money laundering and other illicit activity. Last year, the firm warned that U.S. residents would have their accounts frozen if they were found to be trading, crypto trade publications have reported. 69 Bloomberg notes that along with the CFTC, the Justice Department is likely to examine steps that Binance has taken to keep U.S. residents off its exchange. One person familiar with Binance’s operations said that prior to the establishment of Binance. Americans were advised to use a virtual proxy network, or VPN, to disguise their locations when seeking to access the exchange. Jung, the Binance spokeswoman, said the exchange has never encouraged US residents to use VPNs to get around its rules, as doing so would be something “that has always been contrary to our company’s principles.” In January, Zhao tweeted that Binance’s security systems block Americans even if they try to connect through one of the networks. "We have implemented strong access controls that have been tested via external audit and are under continuous review and evaluation by Binance to ensure that the appropriate restrictions are in place and are effective," Jung said. While the subject of the DoJ and IRS investigation wasn't revealed, Bloomberg's sources said the investigation is being led by the DoJ's bank integrity unit, which probes complex cases targeting financial firms. The scrutiny from the IRS is a separate issue, and has reportedly been going back months. Whatever has been happening, the revelation that a ransom payment was made in crypto means authorities are bound to try and follow the digital trail (the blockchain is open to public scrutiny, after all). With investigators knocking, Binance clearly stepped up its presence in Washington and retained a former Treasury Department official and top white-collar defense lawyers to represent it in legal cases and matters being reviewed by regulators. In March, the firm hired former Sen. Max Baucus, a well-connected Montana Democrat, to advise it on policy and government relations. This isn't the first time US regulators have launched an investigation into Binance. Back in March, Bloomberg reported that the CFTC was investigating whether Biannce, which isn't registered in the US and thus doesn't allow Americans to trade, allowed US residents to buy and sell derivatives that the CFTC regulates. It was perhaps the first ripple of what many fear might be a bigger crackdown in the US, as prosecutors come after one of the world's biggest exchanges that they effectively helped criminals cripple the American energy infrastructure, an economic strike against American civilians.       70       Begin forwarded message:  From: "." <alfaro.nancy@gmail.com>  Date: May 8, 2021 at 4:52:56 PM PDT  To: thomas.flannery@ey.com, tfflannery@gmail.com, susan.cote@ey.com,  susan.rothfels@uk.ey.com, tracy.koh@my.ey.com, kelly.musmanno@ey.com,  Alexis.Lucas@ey.com, kathryn.tominovich@ey.com, carmine.disibio@ey.com,  Patrick.niemann@ey.com, thomas.flannery@ey.com, mark.weinberger@uk.ey.com,  michael.serota@ey.com, mark.gutierrez@ey.com, michael.odonnell@ey.com,  joost.hendriks@ey.com, david.cormack@ey.com, jim.mccaulley@ey.com,  marc.roberts@ey.com, gabriel.marquez@ey.com, roger.yang@ey.com,  sandra.burns@ey.com, gregory.feng@ey.com, greg.glater@ey.com,  david.statman@ey.com, troy.jones@ey.com, allen.freeman@ey.com,  keith.lupton@ey.com, michael.johnson4@ey.com, robert.moritz@us.pwc.com,  groa@deloittemx.com, sbarragan@aristeguinoticias.com, dchrencik@hotmail.com,  Benjamro@herbalife.com, Glozano@queretaro.gob.mx, Sedesu@queretaro.gob.mx  Cc: silvanoaureoles@michoacan.gob.mx, Marco.Lagunas@cocotra.michoacan.gob.mx,  manuel.valencia@cocotra.michoacan.gob.mx,  Transparecia@cocotra.michoacan.gob.mx, FOM.2@hotmail.com,  tribuno_alfa@hotmail.com, gobiernodemorelia@morelia.gob.mx,  GobiernoMichoacan2.0@gmail.com, transparenciamorelia@morelia.gob.mx,  Fiscal@morelia.fiscaliamichoacan.gob.mx, fiscalgeneral@fiscaliamichoacan.gob.mx,  pgjecomsoc@michoacan.gob.mx, sectec.despacho@michoacan.gob.mx,  sectec_segob@michoacan.gob.mx, denuncialosaqui@ssedomex.gob.mx,  denuncia.regulacionsanitaria@edomex.gob.mx, contacto@senadomorena.com,  SINDICATO@senado.gob.mx, SINDICATO969.transparencia@senado.gob.mx,  gobernacion@senado.gob.mx, Transparecia@senado.gob.mx,  puntosconstitucionales@senado.gob.mx, derechoshumanos@senado.gob.mx,  anticorrupcion@senado.gob.mx, hacienda@senado.gob.mx, justicia@senado.gob.mx,  marina@senado.gob.mx, webmaster@semar.gob.mx, cni@cni.gob.mx,  asuntosindigenas@senado.gob.mx, ninezyadolescencia@senado.gob.mx,  economia@senado.gob.mx, salud@senado.gob.mx, educacion@senado.gob.mx,  trabajoyprevision@senado.gob.mx, reformaagraria@senado.gob.mx,  agriculturayganaderia@senado.gob.mx, energia@senado.gob.mx,  comunicacionesytransportes@senado.gob.mx, asuntosfronterizos@senado.gob.mx,  comsegsocial@senado.gob.mx, crpp@senado.gob.mx,  seguridadpublica@senado.gob.mx, seguridad.nacional@diputados.gob.mx,  defensanacional@senado.gob.mx  Subject: Cyberattack Forces Shutdown Of Largest Gasoline Pipeline In United States |  ZeroHedge     Thomas Flannery (EY, Sr. Audit Partner)  Co‐leader, Americas Wealth and Asset Management, EY Boston    I am not sure who the hell you think is playing games. Spectrum systems can't be  showing my cable internet has been shut down and but I've connected and on‐line as  usual. Even as I was speaking to them bout 30 min ago. I was clear that I speak on the  phone and keep writting on my draft email and iPad notes even if I myself don't send  emails or my outgoing Google email is blocked by stupid  and opportunistic orangutans  71 in the US. I am in Los Angeles, CA on the same location, only use this iPad in my home  with my personal internet (paid by me with American Express or Chase and my CA bank  account.     Just because your ignorant ass stuck in CA and stupid CA snowflakes businesses didn't  learn after getting their ass kicked in 2012 doesn't mean you got permission to follow  me around and stick your nose where it doesn't belong much less appropriate critical  national resources  that never belong to the US exclusively. BigTech isn't OPEC.   Telsa isn't Toyota. Electricity isn't Carbon Trade Markets.     Only imbeciles are brain washed with crap decarbonizing the economy. Even humans  are made out of Carbon. You and I inhale oxygen and excel carbon dioxide (green house  emissions). Plant's inhale carbon dioxide and excel oxygen.     Because you and I are the ones who were the ones arguing over the dumbness of  crypto‐currency and blockchain technology over the phone around November 2017, you  know well it what happened in that call. I neither agree with an Audit Partner promoting  a Wall Street product not that it provided anonymity in electronic transactions in global  trade.     Since its clear that BigTech (Silicon Valley) and US unintelligence got their asses handed  down to them by US imbeciles engaged in corporate and political surveillance and their  cronies misrepresenting what I do or respond to incompetent criminals as intelligence.     Only Stupid shit heads will miss that NAFTA was between (Canada, US, Mexico) but  doesn't mean it is it was (Substance over form ‐ fact vs appearance) and was signed by  Bill Clinton (Democrat Arkansas,  attorney general and Arkansas governor). Wal‐Mart is  headquarter in Arkansas. I was in Washington DC after 1995 and out of DC before 2000.  I joined PwC in Los Angeles in 2000.  Wal‐Mart is your client.    You better read in between the lines,  there weren't any stupid criminals who ratted out  Walt‐Mart systems on a background check investigation order by KPMG San Francisco in  February 2016 for a low level position. I was going into a Sr. Executive position in IT  technology systems (Sarbanes‐Oxley 404 ‐ IT Controls ‐ a.k.a. corporate and government  IT infrastructure  and IT systems and interfaces). KMPG was summoned to Washington  DC, and I was blackballed in San Francisco, Silicon Valley and CA. Unsurprisingly, only  Toyota wanted to take me out of CA with them to Texas to lead their IFRS (a.k.a.  Japanese IFRS involved) newly formed accounting and reporting division. That's a Global  role position in Texas. Toyota backed off quickly.  ObjectiveChange, specifically George  Schlitz (German Puerto Rican) was kicked out Toyota innovations in Northern CA and  Agile work that ObjectiveChange was engaged and performing in Los Angeles, CA.  Toyota paid me the entire contract when it didn't have to nor did I ask for payment.  George was meeting with you and Jonathan Reichental in Northern, CA and was very  fishy about explaining to me why Toyota was firing ObjectiveChange. I wasn't being fired  it was George. ObjectiveChange owned and control 40% of the shares in BigVisible  Solutions (the top and largest Agile consulting company in the US based out of Boston,  MA). I controlled ObjectiveChange not George.  I had cornered, owned and controlled  the US the US Agile Market.     George sold BigVisible to SolutionsIQ based in Seattle from under me. He agreed to it on  July 31, 2014 in Delaware, CA. I found out in January 2015, when it was clear I was not  getting murdered in Michoacán and was returning in one piece to the US. How  72 unsurprising that OC got about a million dollars in contracts between September‐ December 2014, including Autodesk and George, based in CA was back on top of the  Agile Market but shut out SolutionsIQ but Giora Morein, the Boston based Israeli  partner in BigVisible received contracts from SolutionsIQ to work as an independent  vendor.    WellsFargo had a BigRole and interest in attempting to frame me organized crime and  get rid of me over its role in the transaction in 2014. It didn't just wiped out my entire  personal accounts at the bank. I had nailed WellsFargo's ass to the Wall from Michoacán  before I entered the US in February 2015.   The IRS was deployed against George, and BigVisible (George/Giora) and SolutionsIQ.     What a surprise that New York, Boston, Seatlle, Delaware  legal shit heads had  orchestrated the fraudulent. FoxRothschild drop George overnight and ObjectiveChange  came back under my control along with George's ass. Who the fuck sales a company  with $10 million in annual revenues for $3.5 million and agrees that half of that cash is  going to pay a credit line Bank of America and pay key employee bonuses first before it  goes through a waterfall distribution, before the only two shareholders get any cash  after certain mile stones are met over a two years time frame (BigVisible potential Tax  IRS Audits in all US States).     I had taken the Boston based Israeli Partner, its investment banker's valuation of the  Company, its Boston and New York overpriced lawyers (being paid by insurance  companies deep legal pockets) to Delaware courts with a third year lawyer from  FoxRothchild based in Delaware over refusing to provide financial records to a 40%  minority shareholder. When was a stupid investment banker and lawyer was going to  fool a BigFour Auditor with a spreadsheet and an elaborate story over receivables to  justify a valuation model using a discounted cash analysis and future profitability. I am  the BigFour Auditor who Audits Private equity and Venture Capital Funds in Silicon  Valley investment valuations. Read:  complex valuations of underlying operating  companies acquired and then value on its Private Equity/Venture Capital Funds and  reported to the Funds investors.    What I say rules in Private Equity, Venture Capital and everyone in Silicon Valley,   and others markets to  "alternative investors".   No one gives a shit about the SEC. The  PCAOB doesn't get to stick its nose in my turf. The law of the land are "alternative  investors"   hiding and entering the US through a complex web of tax heavens and  offshore structures.     US elite lawyers anywhere in the US pick up the phone and answer to me directly when I  call over their shitty legal language. I call, they get to tell me in person what they are  doing. No one gets to stick its dirty fingers in the wrong alternative investor piggy banks.  The Fund lawyers lied to me, there is a record on my Audit work papers of what they  said to me, when,  authorizations I received from the Fund MD's and invoices paid to  them for speaking to the Auditor, me.     Legal shit  heads love to tell different versions of reality and show  different  people  different versions of documents.      I am the one that tells investment bankers and fund owners (alternative investors)  whether  I agree or not with the Funds shitty valuation models. I sign or not sign Yes/No  to investors.   73   Why don't you ask Michael O'Donnell (Cayman Islands Partner),  Joost Hendricks (Dutch  Parner) and Clearlake  in Los Angeles what went down with the 2011 Audits and  investment valuations between in January‐March 2012, I was replaced as the Sr.  Manager by Jim McCauley, Los Angeles Real Estate Partner and pulled out of Clearlake  at the end of March in 2012. Jim McCauley was on Ares Management, Oaktree and  Capital Colony.  Neither Clearlake nor I agreed with Michael O'Donnell or  Joost Hendriks  on valuations nor Duff and Phelps. Specifically, on altering the valuation of Italian  company, where Ares Capital was involved. It went on for months. I didn't sign‐ off  Clearlake's valuations methodology, management and incentive fees  in 2012.     Jim McCauley did. EY knew it was violating even internal EY Audit  methodology  and  was intentionally destroying my Audit work papers and setting up Clearlake's Audit files  to show a story beneficial to EY and Ares Management at the expense of Clearlake.      I was the second Senior Manager on other funds in Los Angeles, specifically focus on the  Bank Own Real Estate Asset portfolios being unloaded by the banks and the FDIC  to  private equities. Specifically one where EY Tax from Mexico work  being flown to Los  Angeles to work as Auditors under me.     The accretion valuation models for the REO's was the issue not the EY Tax Mexicans sent  from Mexico to work as Auditors under me were Jim and I butt heads.     When I said we defrauded and rob Americans from their homes ‐real estate houses and  I was one of  them in Los Angeles I know we knew what we were doing was called grand  fraud and we were colluding (organized crime) with private equity, banks and FDIC. We  robbed teachers, police, firefighters, military officers, veterans and bureaucrats  themselves with impunity and the little ignorant shit heads did the work for us while we  were robbing them.     I get sign off on valuations as the Big Four Auditor, I get to stick my nose everywhere  into Duh!       PwC Australia wanted to take me out of the US to PwC Australia after Toyota couldn't  take me out of CA.  Let's not be stupid.  EY Real Estate in Los Angeles sold me to Sue  Cote they got their asses wiped by EY FSO.     They can't expect me to give a shit about stupid opportunists that didn't know how  ignorant they were to have agreed to such stupidity behind my back. I  still said NO as  the orchestration was taking place between FSO, Real Estate and Los Angeles Office.     I was transferred to a USA flying saucer called Americas Wealth and Asset Management  and no longer owned by EY‐CA nor a CA employee shit‐heads.   Americas = American Continent.    I wasn't transferred to FSO in San Francisco, New York or Boston. Get your damn US  legal structures right in their first place.  Then we can talk on about who wears the  crown in LatinAmerica and where your sit in the US and global food chain of command.    74 Hint. You were never my equal to begin with. That's why you kept complaining I had  more lives than a cat and Stuart Furman EY FSO West Coast Leader based in CA is dead  not me. I was being promoted to Americas boss  against my own will.     Just because stupid people are mentally tied to a title and too ignorant about what and  where wealth  change reality.  Oil, Land the Financial System and USD is still superior to  Tesla, BigTech and cryptocurrencies.  Just because something has currency in the name  doesn't mean is one or that it will replace even the Mexican Peso.     So why don't you keep buying Telsa's with your crypto currency and see where I go with  the Auto Industry in Latin America.  Whenever the LAPD US can run its cars military  trinkets (airplanes, helicopters, ships and tanks) on electricity from wind farms, or  Telsa's solar panels we can talk about what the global Climate Change agenda is about.     Climate Change has nothing to do with the environment.  I     told you to back the hell down and get your oligarchs in line.  You are asking to get your  brains blown out along with your children.     I wasn't the one who lied or tricked US shit‐heads in the military nor the US oligarchs to  hit the Reset button at the wrong time.     In the US, I would defend Texas before CA stupidity in American Continent. Mexico sits  at the top of LatinAmerica and LatinAmerica has a tendency to move together against  invaders. Too bad for CA jews and shrinks not getting their history right in Mexico nor  Michoacan. Felipe Calderon is the wrong catholic and were the  psychologists  "mental  health" professionals  in Michoacán specifically in Avocado land where El Chupacabras  was doing its rounds in the 90s.      What do you think are the chances that I was sitting in the middle of NAFTA  negotiations in the late 80s and 90s?        https://www.zerohedge.com/energy/cyberattack‐forces‐shutdown‐largest‐fuel‐ pipeline‐united‐states  Cyberattack Forces Shutdown Of Largest Gasoline Pipeline In United States The largest gasoline pipeline on the East Coast, and the US in general, was shut down on Friday after its operator struggled to contain a cyberattack which threatened its systems. The 5,500-mile Colonial Pipeline, which is the single largest refined-products pipeline in the United States, halted transit as the company was forced to take "certain systems offline to contain the threat, which has temporarily halted all 75 pipeline operations," according to The Wall Street Journal on Saturday. It's reportedly still offline into early Saturday. Colonial Pipeline System To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet. Colonial's network is responsible for supplying fuel that originates with refiners on the Gulf Coast to most of the eastern and southern US, accounting for over 2.5 million barrels per day in gasoline, diesel, and jet fuel, or other refined products transferred, making up 45% of all the East Coast's fuel supply. It spans from Texas through southern states and up to New Jersey. "At this time, our primary focus is the safe and efficient restoration of our service and our efforts to return to normal operation," the Alpharetta, Georgia-based company stated. "This process is already underway, and we are working diligently to address this matter and to minimize disruption to our customers." 76 To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet. The disruption earlier in the day Friday saw Gulf Coast cash prices for gasoline and diesel push lower, though longer-term price effects will depend on just how long the lines remain shut. If the closure persists further into the weekend or even early next week, it's very likely to send gasoline prices soaring. The last time there was a significant shutdown of Colonial's lines was during Hurricane Harvey in 2017, which shot spot Gulf Coast gasoline prices to a five-year high and diesel to near a four-year high. This fresh cyberattack against vital American infrastructure has reportedly already seen federal agencies and law enforcement get involved, alongside a third-party cybersecurity firm brought in by Colonial to launch an investigation. Some of the early details of the investigation suggest a ransomware attack, which is being reported as follows: The Washington Post reported that ransomware was used in the attack, citing two U.S. officials it didn’t identify. It wasn’t clear if the attack was carried out by foreign government hackers or a criminal group, the officials told the Post. In ransomware attacks, hackers typically encrypt an organization’s computer files and then demand a ransom payment to unlock the data. GI 77 Though there appears little in the way of culprits or suspected individuals or entities that may have carried out the attack at this early period of the investigation, we can expect the Biden administration to hold this up as a prime example of why his ambitious cybersecurity and power grid protection initiative is urgent and essential. It also comes after the White House's April 15 sanctions rollout targeting Russian officials and entities for alleged involvement in the SolarWinds hack. The need for an overhaul of cybersecurity and protections of US government and civil infrastructure networks has been a major theme of this administration, also stemming from leading Democrats quickly blaming Moscow for pretty much every hack which targets American companies or agencies for much of the past five years, despite cases often lacking any evidence as to responsible parties. The Iranians and Chinese have also increasingly brought in alongside the Russians as prime nefarious actors in terms of cyberthreats. However, as was recently admitted in a Wired piece on the Oldsmar, Florida water supply systems hack wherein chemicals were added to the town's water at dangerous levels, there's also many instances of "unsophisticated" lone wolf hackers able to sometimes penetrate overly exposed systems. As suspected, the Colonial Pipeline precautionary shutdown was due to ransomware. This is what I was hearing from sources as well. https://t.co/nNXocQPXYT — Kim Zetter (@KimZetter) May 8, 2021 But there's little doubt that in this major instance of the Colonial pipeline going offline, we expect any moment to hear screams of "Russians!" - even before any evidence is publicly made available, if it gets presented at all.   Email distribution list [added  May 13, 2021]  SBarragan@aristeguinoticias.com, redaccion@aristeguinoticias.com, careyshenkman@riseup.net,  courage.contact@couragefound.org, transportandoamichoacan@live.com,  periodicooficial@michoacan.gob.mx, buzon@poderjudicialmichoacan.gob.mx,  Comercializacion@telesurtv.net, Albinocm6502@gmail.com, JuanJosedelCastillo@gmail.com,  Borderlinebeat@gmail.com, Charropoliticoenvivo@gmail.com, Conexiononline1@hotmail.com,  78 Wells@wsws.org, autoworkers@wsws.org, sep@socialistequality.com, NORISSA@socialism2020.org,  JOE@socialism2020.org, Christine.s.Richard@gmail.com, Aaron.Greenspan@plainsite.org,  Realitycheck@plainsite.org, VeritasTIPS@protonmail.com, Richard.clayton@ctwinvestmentgroup.com,  Noe.cruz@eluniversal.com.mx, Denuncia@eluniversal.com.mx, Contacto@eluniversal.com.mx,  Atiempomx@gmail.com, Indicepolitico@gmail.com, Investigacion@elpais.es, jlsc.ua@gmail.com,  WorldsApart@rttv.ru, Charles@russia‐insider.com, moderator@russia‐insider.com,  radio@sputniknews.com, mediapartners@sputniknews.com, advertising@sputniknews.com,  media@sputniknews.com, marketing@sputniknews.com, info@tehrantimes.com,  ads@tehrantimes.com, newsdesk@afr.com, news@thelocal.it, talk@npr.org, TIPS@zerohedge.com,  Digital@thenation.com, Jmyers@thenation.com, Ryan.Gallagher@theintercept.com,  USinfo@theguardian.com, News@sky.com, TIPS@propublica.org, Joaquin.sapien@propublica.org,  Alec.MacGillis@propublica.org, David.mcswane@propublica.org, Robert.Faturechi@propublica.org,  Sebastian.Rotella@propublica.org, Pamela.colloff@propublica.org, suggestions@propublica.org,  Richard.winton@latimes.com, Liam.dillon@latimes.com, Melody.gutierrez@latimes.com,  Luke.money@latimes.com, Alejandra.reyesvelarde@latimes.com, Gustavo.arellano@latimes.com,  Jack.leonard@latimes.com, Ruben.vives@latimes.com, Jcain@scng.com, Joseph.Cox@vice.com,  Jfcox@jabber.ccc.de, kfsndesk@abc.com, kwalsh@kmaxtv.com, newsdesk@cbs47.tv,  Nina.Trentmann@wsj.com, Paul.Ziobro@wsj.com, Jean.Eaglesham@wsj.com,  Robbie.Whelan@wsj.com, Katherine.Blunt@wsj.com, Alejandro.Lazo@wsj.com,  Jean.Eaglesham@wsj.com, Michael.Rapoport@wsj.com, Mengqi.Sun@wsj.com,  Marcelo.Prince@wsj.com, John.Simons@wsj.com, jeannette.neumann@wsj.com, ryan.tracy@wsj.com,  Opinion@elfinanciero.com.mx, EMilligan11@bloomberg.net, lprinsloo3@bloomberg.net,  Epfanner1@bloomberg.net, Asguazzin@bloomberg.net, Jkew4@bloomberg.net,  Carleton.English@dowjones.com, Tabby.kinder@ft.com, Dan.mccrum@ft.com, tips@nypost.com,  Lisette.v@columbia.edu, Kagubare@globalinvestigationsreview.com, editor@goingconcern.com,  aaron.nicodemus@complianceweek.com, orly.taitz@gmail.com, tips@theverge.com,  walmartwalkout@gmail.com, Justin.Velasco@sgvn.com, news@whistleblowergov.org,  whistleblowing@article19.org, publications@globalresearch.ca, Eiu_enquiries@eiu.com, poldep‐ budg@europarl.europa.eu, jack.avent@euromoneyplc.com, anjana.haines@euromoneyplc.com,  margaret.varela‐christie@euromoneyplc.com, tips@forbes.com, ideas@forbes.com,  readers@forbes.com, mfazio@chicagotribune.com, emalagon@chicagotribune.com,  gpratt@chicagotribune.com, kkelly@bayareanewsgroup.com, Kashmir.hill@gizmodomedia.com,  jaeger@complianceweek.com, helpdesk@itrinsight.com    urgent‐action@ohchr.org, ethicsoffice@who.int, ethicsoffice@un.org, cdhdf@cdhcm.org.mx,  QUEJAS@cdhcm.org.mx, cdhm@tlachinollan.org, aclupreferences@aclu.org,  communications@aclusocal.org, press@ccrjustice.org, info@insyde.org.mx, info@amnistia.org.mx,  carlos.mendoza@amnesty.org, duncan.tucker@amnesty.org, daniella.gac@ulagos.cl,  tribunalpazecuador@yahoo.com, Victor.cabezas@estud.usfq.edu.ec, asuntoscorporativos@clarochile.cl,  marcel.theza@ulagos.cl, thelmstetter@americansfortaxfairness.org,  dbailey@americansfortaxfairness.org, aorozco@utla.net, albert.lowe@utla.net, acaputopearl@utla.net,  alau@utla.net, Management@usfca.edu    pscaritas@iglesiacr.org, Questions@caritas.org.au, caritas@caritas.org.au, secretary@caritas.ru,  caritas.Iran@gmail.com, caritas.info@caritas‐sy.com, caritas.iraq2015@gmail.com,  Comunicacion.on@caritasnicaragua.com.ni, info@caritasvenezuela.org, caritasvenezuela@gmail.com,  pscb@caritasbolivia.org, info@caritaselsalvador.org.sv, info@caritas.sv, info@caritasecuador.org,  caritas@pastoralcaritaspanama.org, administration@caritascyprus.org, caritaslac@caritas.org.ar,  comisionacional@caritas.org.ar, info@caritas.org.lb, executive@caritas.org.lb,  caritas_de_honduras@caritas.hn, secretaria@communication‐caritashaiti.org,  headoffice@caritasjordan.org.jo, direccion1@ceps.org.mx, snpscol@cec.org.coc,  secretariaejecutiva@caritas.gt, caritasnorthamerica@gmail.com, info@caritas‐europa.org,  79 caritasoceania@gmail.com, asiacaritas@caritas.asia, coord@caritas‐africa.org, info@devp.org,  info@crs.org, info@catholiccharitiesusa.org, caritas.internationalis@caritas.va,  postmaster@caritas.org.pe, secretaria@caritasuruguaya.org.uy, cep.pastoralsocialnacional@gmail.com,  pscarcr@racsa.co.cr, caritas@caritas.org.br, caritasantilles@aocslu.org, bishoptripoli@gmail.com,  cariteg@link.net, secretaire@caritas.mr, directeur@caritas.mr, caritas.djibouti@gmail.com,  caritassomalia@gmail.com, caritasmig@gmail.com    Inspector.General@eeoc.gov, FOIA@eeoc.gov, OIGWhistleblower@oig.dol.gov, OIGHOTLINE@nlrb.gov,  CRCExternalComplaints@dol.gov, EOC@dol.gov, CivilRightsCenter@dol.gov, LaborOIGinfo@oig.dol.gov,  ofo.eeoc@eeoc.gov, Nicole.stgermain@eeoc.gov, linda.li@eeoc.gov, bryan.hoss@eeoc.gov,  rosa.salazer@eeoc.gov, monica.colunga@eeoc.gov, michael.rojas@eeoc.gov, TalkTODO@dol.gov,  Executivesecretariat@dol.gov, HQOPSHL@ed.gov, HPqopshl@ed.gov    Hotline@oig.dot.gov, Judy.Kaleta@dot.gov, Dana.Nifosi@dot.gov, Brett.Jortland@dot.gov,  Thomas.Holian@dot.gov, Ellen.Herr@dot.gov, Terence.Carlson@dot.gov    OIG@ftc.gov, Secretary@ftc.gov, Antitrust@ftc.gov, lsolis@ftc.gov, Dhanks@ftc.gov, Ctodaro@ftc.gov,  Bchun@ftc.gov, Rjones@ftc.gov, Kwalsh@ftc.gov, nwhitehead@ftc.gov, asix@ftc.gov,  ssheinberg@ftc.gov, vmusick@ftc.gov, tcarson@ftc.gov, kberg@ftc.gov, tkingsberry@ftc.gov,  lsatine@ftc.gov, premerger@ftc.gov, hsrhelp@ftc.gov    OIG@gao.gov, Congrel@gao.gov, RussellC@gao.gov, RussellW@gao.gov, OCE@mail.house.gov,  HouseIG@mail.house.gov, Hatchact@osc.gov, khendricks@osc.gov, FOIARequest@osc.gov,  Whistleblower@ronjohnson.senate.gov, Peters_Whistleblower@hsgac.senate.gov,  Whistleblower@commerce.senate.gov, help@elizabethwarren.com, info@elizabethwarren.com,  casework@feinstein.senate.gov, OIG@fec.gov, Pubrec@fec.gov, Lobby@sec.senate.gov,  LobbyInfo@mail.house.gov, Secretary@hhs.gov, OCRPrivacy@hhs.gov, OCRmail@hhs.gov,  OIGhotline@opm.gov, USCIS.FOIA@uscis.dhs.gov, FOIA.OIG@oig.dhs.gov,  Whistleblower.Coordinator@oig.hhs.gov, Whistleblowerprotectioncoordinator@oig.dhs.gov,  OPMOIGWhistleblower@opm.gov, Tmillsaps@osc.gov, Atticus.reaser@cigie.gov,  Michael.e.horowitz@usdoj.gov, Kevin.winters@amtrakoig.gov, Hkerner@osc.gov,  Shimon.Richmond@oig.hhs.gov, RMFSIMSST@nbib.gov, FOIPARequests@nbib.gov,  ICIGHotline@dni.gov, IG_hotline@dodiis.mil, ighotline@exim.gov, DDTCResponseTeam@state.gov,  Socr_Direct@state.gov, WPEAOmbuds@stateoig.gov,     Ombudsman@frb.gov, OIGHotline@frb.gov, CFPBOmbudsman@cfpb.gov,  CFPB_WHISTLEBLOWER@cfpb.gov, whistleblower@consumerfinance.gov,  OMWI@consumerfinance.gov, CFPB_WHISTLEBLOWER@cfpb.gov, military@consumerfinance.gov,  CFPB_OlderAmericans@cfpb.gov, CFPB_CABandCouncilsEvents@consumerfinance.gov,  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bozhkovae@pcaobus.org, diznae@pcaobus.org, vinellia@pcaobus.org, Info@pcaobus.org,  Speeches@pcaobus.org, PublicAffairs@pcaobus.org, Asksipc@sipc.org, whistleblower@finra.org,  ChairmanOffice@sec.gov, CommissionerJackson@sec.gov, CommissionerLee@sec.gov,  CommissionerRoisman@sec.gov    Firearms.Bureau@doj.ca.gov, pctips‐losangeles@fbi.gov, nics@fbi.gov, info@gungalleryinc.com,  Criminal.Division@usdoj.gov, FCPA.fraud@usdoj.gov, OPR.complaints@usdoj.gov, USACAC.CV‐ CivilRights@usdoj.gov, National.FOIAPortal@usdoj.gov,  oig.whistleblower.ombudsperson.program@usdoj.gov, Debora.Yang@doj.ca.gov,  Xavier.Becerra@doj.ca.gov, NSD.Public@usdoj.gov, USAVAE.NICS@usdoj.gov,  Thomas.Traxler@usdoj.gov, Alexander.P.Berrang@usdoj.gov, Heather.Schmidt@usdoj.gov,  Gordon.Kromberg@usdoj.gov, Peter.Duffey@usdoj.gov, Dennis.Barghaan@usdoj.gov,  Daniel.S.Schwei@usdoj.gov, Trent.McCotter@usdoj.gov, Nathan.M.Swinton@usdoj.gov,  Zia.Faruqui@usdoj.gov, Niall.ODonnell@usdoj.gov, Joseph.Beemsterboer@usdoj.gov,  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jreichental@hotmail.com, Treichental@hotmail.com, Complaint@fppc.ca.gov, Hatchact@osc.gov,  Lobby@sec.senate.gov, LobbyInfo@mail.house.gov, OIG@fec.gov, Pubrec@fec.gov,  StateInfo@state.ca.gov, Secretary.Padilla@sos.ca.gov, WPEAOmbuds@stateoig.gov, DCA@dca.ca.gov,  Kimberly.Kirchmeyer@dca.ca.gov, Alexis.Podesta@dca.ca.gov, SIUMailbox@scif.com,  Enforcement@cslb.ca.gov, Classifications@cslb.ca.gov, Licensing@cslb.ca.gov, Info@cslb.ca.gov,  Sheila.Daniels@cba.ca.gov, Enforcementinfo@cba.ca.gov, ComplianceUnit@cba.ca.gov,  CitationsUnit@cba.ca.gov, patti.bowers@cba.ca.gov, deanne.pearce@cba.ca.gov,  nooshin.movassaghi@cba.ca.gov, oponline@nysed.gov, OldInetInfo@dos.ny.gov, OPDPLS@nysed.gov,  CommitteeMeetings@scif.com, BoardofDirectors@scif.com     81 Silvanoaureoles@michoacan.gob.mx, Marco.lagunas@cocotra.michoacan.gob.mx,  Manuel.valencia@cocotra.michoacan.gob.mx, Transparecia@cocotra.michoacan.gob.mx,  FOM.2@hotmail.com, Tribuno_alfa@hotmail.com, Gobiernodemorelia@morelia.gob.mx,  GobiernoMichoacan2.0@gmail.com, Transparenciamorelia@morelia.gob.mx,  FISCAL@morelia.fiscaliamichoacan.gob.mx, FiscalGeneral@fiscaliamichoacan.gob.mx,  PGJecomsoc@michoacan.gob.mx, Sectec.despacho@michoacan.gob.mx,  Sectec_segob@michoacan.gob.mx, Denuncialosaqui@ssedomex.gob.mx,  Denuncia.regulacionsanitaria@edomex.gob.mx, Glozano@queretaro.gob.mx,  Sedesu@queretaro.gob.mx    Contacto@senadomorena.com, SINDICATO@senado.gob.mx,  SINDICATO969.transparencia@senado.gob.mx, Gobernacion@senado.gob.mx,  Transparecia@senado.gob.mx, puntosconstitucionales@senado.gob.mx,  derechoshumanos@senado.gob.mx, Anticorrupcion@senado.gob.mx, hacienda@senado.gob.mx,  Justicia@senado.gob.mx, Marina@senado.gob.mx, webmaster@semar.gob.mx, cni@cni.gob.mx,  asuntosindigenas@senado.gob.mx, ninezyadolescencia@senado.gob.mx, Economia@senado.gob.mx,  Salud@senado.gob.mx, Educacion@senado.gob.mx, Trabajoyprevision@senado.gob.mx,  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cstepati@pfp.gob.mx, csatlaco@pfp.gob.mx, sumit2006@gmail.com, ed‐del‐rev@nic.in,  molegangwar@yahoo.com, secy‐labour@nic.in, farida.samsul@gov.in, igkonwar.acs@assam.gov.in,  bopb1.clb@nic.in, registrar‐mum@nclt.gov.in, secretary@nclt.gov.in, registrar.jpr@nclt.gov.in,  response‐nis@pib.gov.in    FRAUD@insurance.ca.gov, Ombudsman@insurance.ca.gov, CAB‐SF‐Intake@insurance.ca.gov,  ElectronicSubmissionFD‐1@insurance.ca.gov, pushpa.uttamchandani@insurance.ca.gov,  RECRUITMENT@insurance.ca.gov, RSBCovid19PR@insurance.ca.gov,  CustodianofRecords@insurance.ca.gov, StateFarmfireClaims@statefarm.com, Privacy@statefarm.com    Ethics.Officers@jll.com, Laura.Locks@lasalle.com, John.Carlson@lasalle.com, klynch@icsla.us,  S.Mercer@festivalcos.com, T.Killeen@festivalcos.com, D.Whitt@festivalcos.com,  S.Brown@festivalcos.com, F.Insurance@festivalcos.com, Celia.shibata.iyhc@statefarm.com,  Nicole.HillSmidt@roberthalf.com, Samantha.figueroa@roberthalf.com, sherri.agganis@rhmr.com,  anjali.chandel@rhmr.com, chelsea.jongewaard@rhmr.com, julia.person@roberthalf.com,  carmen.romero‐eberle@roberthalf.com, tony.uyehara@roberthalf.com,  zoya.naumchik@roberthalf.com, tala.moussouras@roberthalf.com, cawagenotice@roberthalf.com,  pay.timereporting@roberthalf.com, OnlineTimeReporting@roberthalf.com, quality.manager@rhi.com    SMangum@smwb.com, JRobb@smwb.com, jsweeney@smwb.com, rmason@smwb.com,  sschmidt@smwb.com, colson@smwb.com, kwilson@smwb.com, REB@smwb.com,  wkaufman@smwb.com, dlee@smwb.com, rthomson@smwb.com, LLGinn@smwb.com,  82 TJacobson@smwb.com, lbalke@smwb.com, WStanger@smwb.com, Parul@giulianiconstruction.com,  Vince@giulianiconstruction.com, Tiffany@giulianiconstruction.com,  Antoinette@giulianiconstruction.com, Ashley@giulianiconstruction.com, AR@giulianiconstruction.com,  Claudia@giulianiconstruction.com, Erik@giulianiconstruction.com, SLG@sghoalaw.com,  TMiller@constructionsdefects.com, Sara@constructiondefects.com, Sbrown@constructiondefects.com,  Linda@constructiondefects.com, Rachel@constructiondefects.com, Joseph@constructiondefects.com,  State@constructiondefects.com, Asha@constructiondefects.com, EHillier@washblaw.com,  THones@washblaw.com Jknight@berdingweil.com, Cthomas@berdingweil.com,  Lolona@berdingweil.com, Bhirsch@berdingweil.com, Tnocco@berdingweil.com, Kpolk@cahill‐sf.com,  JPalmer@cahill‐sf.com, Rmartini@cahill‐sf.com, Aelizabethcostello@gmail.com,  Donklingbeil@gmail.com, Arun.Bhatia@sfdwp.org, Ngueylay@gmail.com,     CynthiaC@partnerscm.com, CarmenH@partnerscm.com, Karolo@partnerscm.com,  RebCohen999@sbcglobal.net, Kathlineking@yahoo.com, Cbretzin@gmail.com,  Cristin.morneau@gmail.com, Rebelcapitaladvisors@gmail.com, Maddydominick@hotmail.com,  HHW7878@yahoo.com, KristyandAlvin@gmail.com, kyle.algeo@gmail.com, Balog@climbsf.com,  Kevans@gmail.com, renee@hrhrealestate.com, Steven.Sheh@gmail.com,  Steven.sheh.300ivy@gmail.com, Cathy.edwards@gmail.com, Cathy300ivy@gmail.com,  Ariel_zach@yahoo.com, Sabrina.300ivy@gmail.com, Michele.300ivy@gmail.com,  300ivy305@gmail.com, William.e.russell.jr@gmail.com, Larrykern300@gmail.com,  KRISTYWEN@gmail.com, Audreycervantez15@gmail.com, Amanda.cifarelli@gmail.com,  Aditi.joshi34@gmail.com, Atishay.jain89@gmail.com, alankarchang@gmail.com,  alexandraliss@gmail.com, alinashah@gmail.com, achiu7@gmail.com, ann.lutzker@gmail.com,  anna.kolontyrsky@gmail.com, alehr1723@gmail.com, avnish.sabharwal@gmail.com,  Natalie.choy@gmail.com, Benchoy@gmail.com, Blake.m.osborn@gmail.com, bty200@gmail.com,  Brenns10@gmail.com, Cairokim@gmail.com, Clairekjackson@gmail.com, cxie08@gmail.com,  ctstraub@gmail.com, Crbarry17@gmail.com, ctunno@gmail.com, cyinglee44@gmail.com,  Danoosh.kapadia@gmail.com, Davelu@gmail.com, Davidsha@gmail.com, dygandcompany@gmail.com,  Eleanorlee@gmail.com, Erin.pettigrew@gmail.com, Gracezwho1@gmail.com, Hanshc@gmail.com,  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manonpaquet@live.fr, hillpropmanager@sbcglobal.net, mponce@alse.com.mx, serfriaz@live.com.mx,  83 William.Livermore@fsresidential.com, Todd.Caniglia@fsresidential.com, Natalie.valdez‐ smith@fsresidential.com, Jeanette.Zamora@fsresidential.com, Marco.Pulido@yahoo.com,  irmavillalobos@hotmail.com, curlysue713@yahoo.com, ramartinez@gmail.com, rapransky@gmail.com,  ms.ra.martinez@gmail.com, Cordon.Lucky@gmail.com, Paoneill@asu.edu, shaoyun925@hotmail.com,  Atsuko_Nakamura@hotmail.com, Paul.Ryan.201@hotmail.com, Hvchowdhary@gmail.com,  Neng1983@gmail.com, Amacrine67@icloud.com, WexlerSecretary@2730wilshire.com,  info@ericwexlermd.com, pialigeti@gmail.com, Geotff@outlook.com, Marcos.f.carrillo@gmail.com,  Victoriav561@gmail.com, Joe.Cicalo@wholefoods.com, Andyperez23@yahoo.com,  Bebelovesbo76@hotmail.com, Tribuno_alfa@hotmail.com, Jessicaflores05@gmail.com,  ymo73@hotmail.com    RecordsAccessOfficer@trs.nyc.ny.us, Investments@ocers.org, CalSTRSCIO@calstrs.com,  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christopher.kearley@ey.com, kurt.neidhardt@ey.com, edwin.pisani@ey.com, joanne.dunbar@ey.com,  arthur.tully@ey.com, william.schlich@ey.com, alfredo.alvarez@mx.ey.com, oscar.santos@mx.ey.com,  rodrigo.ochoa@mx.ey.com, mario.karim@mx.ey.com, arturo.hernandez@mx.ey.com,  german.vega@mx.ey.com, francis.grab@ey.com, danielle.ryea@ey.com, joon.kim@ca.ey.com,  alan.thom@ca.ey.com, ana.johnson@mx.ey.com, pamela.mable@ey.com, ashley.giles@ey.com,  ben.carter@ey.com, dan.karen@ey.com, zoi.koutsogiannakopoulou@gr.ey.com,  Rohan.Small@ky.ey.com, Jeffrey.Short@ky.ey.com, Dan.Scott@ky.ey.com, Baron.Jacob@ky.ey.com,  Bill.Bailey@bm.ey.com, ashley.horne@ey.com, ey.fsotax@ey.com,  ey.fso.wealthassetmanagement@ey.com, fergus.mcnally@ie.ey.com, sinead.colreavy@ie.ey.com,  donal.osullivan@ie.ey.com, Muntasir.Khaleik@ie.ey.com, Cormac.Kelly@ie.ey.com,  Kieran.Daly@ie.ey.com, souza@ie.ey.com, Fergus.McNally@ie.ey.com, Ailbhe.MacManus@ie.ey.com,  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rdiogo@playaresorts.com, PSaif@playaresorts.com, ir@playaresorts.com, press@playaresorts.com    87 Michael.Mctiernan@hoganlovells.com, Cbode@tpg.com, Doug.warner@weil.com,  Chris.machera@weil.com, Kyle.Krpata@weil.com, Nelsonj@gtlaw.com, Saylea@gtlaw.com,  brunoespindola@paulhastings.com, gonzalogutierrez@paulhastings.com,  emilywinston@paulhastings.com, elenapoleganova@paulhastings.com, joygallup@paulhastings.com,  leopoldogomezgrassi@paulhastings.com, pvelasco@s‐s.mx, theather@ritch.com.mx,  ldanton@ritch.com.mx, cobregon@ritch.com.mx, gdelvalle@ritch.com.mx, jpfarah@ritch.com.mx,  jberrueta@ritch.com.mx, lnicolau@ritch.com.mx, pperezalonso@ritch.com.mx, efreedman@cgsh.com,  ggaleotti@cgsh.com, fgaray@cgsh.com, ngrabar@cgsh.com, jcardona@cgsh.com,  apaul@whitecase.com, andrew.choe@balm.com, filo.fiorani@balm.com,     Joseph.Mazza@mcgladrey.com, Ron.kent@mcgladrey.com, Craig.Wickwire@mcgladrey.com,  Christine.Jung@mcgladrey.com, Tom.leyden@mcgladrey.com, Tracy.whetstone@mcgladrey.com,  Steven.Johnson@mcgladrey.com, Paige.Kuroyama@mcgladrey.com, Scott.Mackey@rsmus.com,  karen.jong@mcgladrey.com, Ericka.Foster@mcgladrey.com, Ellen.Burns@mcgladrey.com,  Michelle.McKenzie@mcgladrey.com, Leroy.Dennis@mcgladrey.com, allison.hovey@mcgladrey.com,  Byron.Whittlinger@mcgladrey.com, jack.rominger@mcgladrey.com, Tselby@wc.com,  BRobb@shilepsky.com, CNeff@foxrothschild.com, BRodos@foxrothschild.com,  PConnolly@foleyhoag.com, JLQ@foleyhoag.com, Marc.maselli@morganpartners.com,  JRudd@solutionsiq.com, Gmorein@gmail.com, George.Schlitz@gmail.com, Jamesiracundiff@gmail.com,  Garson@soelaw.com, Darrin_Ladd@hotmail.com, Stalley333@gmail.com, Stalley@kcrlegal.com,  Kelvin.Tetz@mossadams.com, Dkouame@bdo.com      88 Baumb, Nelly From:Alex Mowry <ajmowry@gmail.com> Sent:Thursday, May 13, 2021 6:04 PM To:Council, City Subject:I'm Voting to keep Ramona St Closed CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Palo Alto City Council: I enjoy the safe outdoor experience created with the closure of Ramona St. Please count my vote  to CLOSE Ramona St, through the summer.     Thank you     Best,    Alex Mowry      WW Corporate Recruiting     amowry@apple.com     iPhone 916‐622‐7298  89 Baumb, Nelly From:Jeff Hoel <jeff_hoel@yahoo.com> Sent:Thursday, May 13, 2021 5:20 PM To:Council, City; UAC Cc:Hoel, Jeff (external) Subject:TRANSCRIPT & COMMENTS (part 3) -- 04-21-21 UAC mtg -- FTTP CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Council members and Commissioners, Part 3 of the TRANSCRIPT. Jeff ################################################################################################# ################## Video: https://midpenmedia.org/utilities-advisory-commission-31-4212021/ Staff report, including the presentation slides (pages 47-102) https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2021/04-21-2021-special/id-12118-item-no-1.pdf 2:47:53: Chair Forssell: Are we ready for general discussion? 2:47:57: John Honker: Um, do we want to look at the "next steps slide"? 2:48:01: ### Slide 40 Did we want to go though that? 2:48:02: Chair Forssell: That's a -- Yes. Let's to that. 2:48:04: John Honker: OK. Perfect. This is our last slide. So, the next steps, that have already been approved from the prior meeting ### Which meeting? UAC met on 08-05-20, but UAC doesn't have the power to "approve" things. Council met on 10-05- 20, but the fiber item was on the Consent Calendar, so it was approved with no discussion. were the community engagement, the broadband services ### survey (not "services") 90 for residents and businesses, and then exploration of the partnerships, which -- you know, depending on what you guys decide to do, that may come off the table or may stay. But the two that would be really important next steps for us, then, would be community engagement and -- as well as the broadband surveys for your residents and businesses. And the recommended next steps, that haven't been approved yet, are detailed engineering and exploring those federal grant options. So, the detailed engineering -- The goal here would be to combine, really, phases 2 and 4. So, the fiber backbone and the fiber-to-the-home, to be able to create synergies for the overall design. Meaning that, you know, by doing the engineering on both phases simultaneously, chances are, those construction costs will be able to come down. Because we can value-engineer a lot of the fiber-to-the-home plant and the backbone simultaneously. It also leads to a lot of sort of synergies on the design side, to be able to reduce some of those engineering costs. And we've already identified about $200,000 in design costs that would come out of OUR budget, that -- if these two phases were to be put together with -- you know, save the City considerable money. But not at the magnitude of ** construction, where we really see the synergy is -- you know, the combined engineering and identifying how construction costs could come down between the fiber backbone and fiber-to-the-home. 2:50:03: Vice Chair Segal: Could I ask one question on the "explore partnerships"? Is that exclusively having a third-party ISP, versus some of the other ideas that Commissioner Scharff mentioned earlier in the meeting? 2:50:18: John Honker: I -- You know, I -- I kind of think where you -- where you guys are is -- you want to see the detail, and how we could optimize the city-ISP, using a combination of sort of insourcing and outsourcing. Sort of a blended model, where there's, you know, key vendors doing some of the heavy lift for the City, where the City doesn't have the expertise, and maybe the City is insourcing some others. So, maybe that "partnership" is more of a blend of, you know, insource/outsource and looking at those partners. The original intent of it was more of a traditional partner-ISP. Meaning, looking at an ISP that would come in and basically partner with the City for a full build-out. And provide service. Right? 2:51:13: Commissioner Jackson: Those are VERY DIFFERENT THINGS. ### Absolutely. 2:51:15: John Honker: They are. 2:51:15: Commissioner Jackson: And I think this top-level thing is: city-as-ISP, partner-as-ISP. That is a big fork in the road. Now, if you say city-as-ISP, then there's all kinds of things you could do. How best to make city-as-ISP. It's not partnerships. It's pay-for-service, and outsourcing **. But it's a DIFFERENT FORK. And so, the question is, what are you -- what are we being asked -- which fork are we being asked to weigh in on? 'Cause it's a very different question, I think. 2:51:49: John Honker: And I think that's the question for is, is whether the City wants to consider the partnership. The partner-ISP option. Or whether it should just be city[-ISP]. Because this -- That was the original intent of this task, was to look at those traditional partnerships. ### Elsewhere, Honker says, in effect, that partner-as-ISP partnerships haven't been around long enough to qualify as "traditional." But that's not -- If the City's not feeling that that's the best route, then -- You know, it would be more business optimization. How does the City build and manage the business in the best way that it can, to provide service to the community. 91 2:52:22: Chair Forssell: Commissioner Scharff. 2:52:25: Commissioner Scharff: Yeah. No. I mean, I think we clearly should do the detailed engineering. Combined phases 2 and 4. We should let staff move forward on exploring federal grant options. Especially in this climate, with Biden's infrastructure plan, and all of that. I mean, I think those are no-brainers. And I'm with Commissioner Jackson on this. That I think that we should recommend to the City Council that we don't explore partnerships. That we explore how to best optimize the City owning the ISP. And moving forward on that. And there's lots of information that, you know, Magellan could come up with, I'm sure. The best way to optimize that. What are our options. What are our thoughts. 2:53:08: John Honker: I mean, for us, it would be sort of a traditional -- let's call it sort of a "business plan lite." This is how you really would do it. And then that becomes a playbook. And say, you know, once you have all those detailed costs, and an analysis how YOU would operate, and what functions you would insource versus outsource, then you can make a decision on it. Right? But that would be a very, very valuable task, we think, for the UAC, to be able to see that at a very granular level, and understand the dynamics around, you know, the business itself. 2:53:43: Commissioner Jackson: So, I have a discussion item for my fellow commissioners. Which is, where do -- What do we think bond-and-build versus let's increment over 10 years and then figure out the last 7,000 later? Those are very different models. And do we have an opinion about one versus the other? ### Good question. Although I object to its being called a "discussion item." Item VII.1 of this UAC meeting is an action item, not a discussion item. One way to talk about something within an action item is to MOVE something. And I'll go first. I like build-and-bond. OK. But that's, I mean, a big surprise to everyone here. 2:54:17: Chair Forssell: Vice Chair Segal. 2:54:19: Vice Chair Segal: Thanks. Yeah. I was going to comment on -- I prefer build-and-bond as well. And I, also, the -- at least the way it was presented, which is a little different from when we were -- or, at least, I thought it was different from where we had left it from where we were meeting in the subcommittee. ### What are the rules for how a subcommittee is suppose to interact with staff? Are the meetings supposed to have agendas? And minutes? And are meetings publicly noticed? And is the public welcome to attend? The Brown Act doesn't require these. When the Citizens Advisory Committee on FTTP and Wireless (CAC) was created, it didn't have any of these things, because the Brown Act didn't require them. But as things evolved, CAC started doing them anyway. (Because of the City's disastrous update of its website functionality, the public doesn't currently have access to CAC agendas and minutes. But according to this, https://www.cityofpaloalto.org/Departments/City-Clerk/Regulatory-and-Advisory-Boards-Commissions-and-Committees that problem may be fixed in the future.) ### Also, are subcommittee members expected not to tell anybody what occurred at subcommittee meetings, at least until the full UAC considers the issue? ### A meeting between staff and the subcommittee might be an opportunity for staff to persuade the subcommittee, in a way that the public can't watch. I find that problematic. ### I think subcommittee members should resist being persuaded in subcommittee meetings, and should wait for full- UAC meetings to be persuaded -- or not. 92 But I think going to the community and saying that, 40 percent of the households, we'll figure it out at some point is not a great way to get community engagement. You know, that's after 10 years, well, we'll figure it out somewhere. That's a problematic way to start. If there's some other way to -- maybe with federal funds or something -- to contract the timing, and, you know, start with the low-hanging fruit, and get customers signed up, and use that revenue to pay for the more expensive one. You know, certainly we should explore that. But it's -- I don't know. It's -- it doesn't -- it rubs me the wrong way to say to that 40 percent, well, -- We of the majority -- it's over 50 percent -- but that 40 percent are left sort of hanging -- I find problematic. And I also, just to reiterate, I think it probably doesn't make a lot of sense to go too far down the partner-ISP path, as well. 2:55:43: Chair Forssell: Commissioner Johnston. 2:55:46: Commissioner Johnston: I agree with Vice Chair Segal's comments. I -- And Commissioner Jackson's. I mean, I think that the build-and-bond model is much better. I think there's going to be a lot of community concern if, you know, a large percentage -- or even a significant percentage of residents are going to have to wait 10 years to get the benefits of this. So, I would go for the build-and-bond. And I'm persuaded that the city-as-ISP is the preferable model. The benefits are significant. As I see it, the two risks are, obviously, the cost. And we've talked about that. And ways to manage the cost. I continue to be concerned about the take rate. Because I think that's a risk. Obviously, at a 24 percent take rate, we break even, if that. So, I'm very interested in the results of the community survey. But I agree with the comment that was made by the member of the public at the very beginning that the community survey is not going to be meaningful unless there is a fairly detailed explanation of what this means for -- and kind of what you -- what people in the community would get if they signed up for this. So, those are my comments. I think it's really good that we have come this far. I think that we're making -- important progress, for something that's very important for the community. And I want to see us keep moving forward. But, as I say, I think the community survey is going to be key. 2:57:51: Commissioner Jackson: One sentence clarification. I'm sorry I misspoke. I think it's better to say "bond-and- build." Versus "build-and-bond." It's the cart before the horse. So, let's just call it "bond-and-build." If you don't object. 2:58:06: Chair Forssell: Commissioner Smith. 2:58:08: Commissioner Smith: Thank you, Chair. I just want to highlight the importance of this initiative as well. We've all lived through the last year of COVID-19. And, if anything, it has certainly highlighted the need for very, very extreme levels of broadband services in our homes. ### And businesses? When we ourselves are at work, online, full-time. When our children are online, full-time. Yes, we are getting back to some degree of normalcy. But that is not happening quickly. And you can expect -- and, I think, certainly in my own work life, I will expect that at least one to two days a week, I will be online at home, on Zoom, or a GVC. So, I think this is incredibly important work. I think it definitely is worthwhile pushing forward. I also agree that "bond-and-build" is the right way to go, as a city-owned ISP. More importantly, I echo Co-Chair Segal's comments about equity. I don't think it sends the right message that we're going to build -- we're going to spend 10 years building 70 percent of the population and 40 percent of the population is going to wait. That's not equity. And there will be rancor result, I think, if we don't respond appropriately. I -- Based upon what Magellan has done -- And, by the way, Magellan, kudos to you. I think you've done a wonderful job. This has been a very thorough investigation. And I very much appreciate the time that you have spent with us, as we develop this process, and as we understand. But I don't see a great deal of appeal -- at least personally -- when it comes to finding a partner organization to run an ISP. And that's just simple economics. More importantly, I just want to echo not only Andy Poggio's comments but also A.C. Johnston's -- Commissioner Johnston's -- comments about this community engagement. It's something that I have spoken with Dean Batchelor in the past. I am very worried about introducing something that is, quite frankly, technologically advanced for this community, without educating the community about what we are actually doing. And I think that the need for a very, very concerted and heavy community engagement 93 and community EDUCATION is absolutely critical. And I would advise -- and agree -- that that community engagement, and that community outreach, and education should happen PRIOR to a survey. Thank you. 3:01:06: Dean Batchelor: So, real quick. If I could just address that. So, I can tell you, Commissioner, that Ed [Shikada], our City Manager, feels exactly -- from what you're just demonstrating and what you're talking about. He is very, very much -- wants to get out in front of the public on this. Get out to the community. And talk about this. Because -- the same -- the sentiment feelings are -- the survey will not be really true to it if we just went out. And we've had conversations with John and the Magellan team about this. About how we can go about getting this information out ahead of time, before we even start doing the survey. So, I can tell you that it's definitely on Ed's radar. Very strongly. 3:01:56: Commissioner Smith: FANTASTIC! Thank you, sir. Thank you, sir. 3:01:59: Chair Forssell: Commissioner Danaher. 3:02:00: Commissioner Danaher: So, echo my agreement with a lot of what's been said. Yes, go to the detailed engineering. Let's ignore the partnerships. You might start with a "survey lite." Something like are you satisfied with your level of broadband? And see how -- do you trust your existing providers to increase that? But, yes, to education and the like, we should do that. And I think we should emphasize the future-leaning part of this. So, if we can go to a gigabit and beyond, for all these new demands that we're going to have, going forward. I also want to thank John and his Magellan partners for the presentation and the report. And why -- I learned something that was useful, to go through that incremental approach, now that I understand it. Yes, if we're spinning off that kind of cash, we can do the kind of borrowing we need to build this out fast. And you don't want to go slow to provide fast service. So, let's go fast to provide fast service. Thank you. 3:03:07: Chair Forssell: Commissioner Jackson. [pause] You're on mute. 3:03:16: Commissioner Jackson: So, where I end up in all of this, after this discussion -- I guess I -- I would suggest that -- the UAC -- we make a much stronger set of recommendations than are in the staff report. And I -- Something along the lines of: We think the fiber expansion is a great idea. And that should be done. ### If Commissioner Jackson is talking about the new fiber backbone, I disagree. FTTP doesn't need to have an all- singing-all-dancing fiber backbone. We think the fiber-to-the-home -- So, we should be -- Fiber -- 3:03:42: Let me go back up. * Fiber expansion is a great idea. So let's proceed with Phase 2. ### I think the all-singing-all-dancing fiber backbone is not a good idea, and it's not necessary for FTTP. And I think UAC didn't really hold staff's feet to the fire to explain why they want it. * Fiber-to-the-home is a great idea. So let's proceed with Phase 4. * Furthermore, we think that "bond-and-build" is the right model for fiber-to-the-home. * And, furthermore, we think that city-as-ISP is the right business model. So don't spend any time working on the other things. 94 ### Here, I think "the other things" refers specifically to the partnership-as-ISP business model. It does not refer to city- as-ISP variants such as outsourcing -- or, for that matter, "open access." * And, sure, if you want to go off and -- you know, I'm sure that Council and staff will keep track of largesse coming from the federal and state governments that could fund this if those opportunities arise, I have full confidence that they will be all over that. ### I think it would be helpful to clarify that moving forward does not depend on this largesse. But, to me, that sort of five-pronged stronger recommendations is what I would suggest that we recommend. To Council. 3:04:38: Chair Forssell: Vice Chair Segal. 3:04:39: Vice Chair Segal: Yeah. I -- One thing just crossed my mind. And maybe this for another time. But, you know, I know that there was already -- We talked about it at the last meeting, I believe. That there was other funding coming from the federal government, and that the City -- that it COULD be used for broadband, but the City was going to use it for other needs. And I just wonder whether -- use -- if some those funds, for example, could be used for broadband, and there's a different way to raise funds for the other needs that it was being considered to be used. If that needs to be also considered, when we go further into the analysis. So, it says "explore federal grants." I take that as future ones. As opposed to ones that have already been granted. ### Many grants are only for "shovel-ready" projects. So maybe the City should focus on making its FTTP project "shovel-ready." 3:05:30: John Honker: We would -- So, we -- we have -- You know, the AARP funding is important. But there's also additional federal funding that's coming out for urban municipalities that is slated for May-June-July, that we would really want to start investigating. And really provide a kind of a opportunity on how you would use that. Because some of the program rules are still out, and haven't been finalized. But we have our folks in Washington tracking those. So, you know, keeping our ear to the pavement, to make sure that, any money comes out, you guys are aware of, that could go toward the build for fiber-to-the-home. 3:06:18: Chair Forssell: Commissioner Scharff. 3:06:21: Commissioner Scharff: Well, I think we do need to wrap this up, in terms of a motion. ### Hear, hear. And where we should go on that. And I agree with what everyone said. I mean, I think -- I think if we only build out 40 percent of it -- or 60 percent of it -- and we leave everyone else hanging, I think there will be a lot of upset people in Palo Alto. I sort of feel about the undergrounding, which I think we've heard about for years. When are you going to underground my neighborhood? And the answer is, never. ### I agree that the City's "100-year" project of undergrounding electric citywide is an apt analogy. I think Council hasn't prioritized getting this citywide undergrounding project moving again. But I don't think Council has voted to abandon the project. I think -- especially if we do the low-hanging fruit and do the cheaper ones first, and then it's just the expensive portions that really aren't economical, I think that will be more difficult. So, I do think we should recommend to the City Council that they, you know, move forward on community engagement. I think that's a no-brainer. The broadband survey. I think we should not explore the partnerships. I think we should optimize for the business, and have Magellan figure that out, as was discussed. Do the detailed engineering. Explore the federal grant options. And I think we should recommend that - 95 financing options to build out the whole City be explored -- and a plan to come up with that. And that, to me, seems to be the heart of it. Of what we should do. 3:07:37: And I think I'd like to make a motion for that. And people can things, if they want, to it. But I think -- if I can get a second - - at least start bringing this to a conclusion. ### Normally, the maker of the motion has to make the motion (by reciting it) before it can be seconded. 3:07:46: Vice Chair Segal: Second. 3:07:46: Commissioner Jackson: I second that. ### The approved minutes of the meeting haven't been posted to the website yet, but according to the draft minutes, https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2021/05-12-2021-special/04-21-2021-uac-draft- minutes.pdf Jackson seconded the motion. ### At this point, normally, the maker of the motion gets to speak to the motion, and then the seconder gets to speak to it. 3:07:52: ### A visual is displayed which is not in the staff report. It says: Recommendation: Staff requests that the Utility Advisory Commission (UAC) recommend that the Council: 1. Accelerate communication and education of FTTH; Develop a community engagement platform including a broadband survey for residents and businesses; 2. Combine Phase 2 and Phase 4 of the Magellan contract to provide detailed engineering design of the City's fiber backbone and fiber-to-the-home (FTTH); 3. Explore public-private partnership opportunities and model for FTTH; and 4. Evaluate federal and state grant funding options for broadband infrastructure. Recommend City ISP "bond and build" FTTH model; optimize business opportunities with a mix of insource and outsource services. ### Due to the limitations of my environment, I'm using different conventions for this visual: yellow = staff's original recommendation, orange & bold = changes, purple & italic = cross-out. ### During the next half hour or so, this visual evolved in real-time, but I'm not going to transcribe how. Dave Yuan: I did take the liberty of putting together -- sorry -- a motion, that was previously in the report -- of what I've been hearing. So the red markings are the revisions. And the black markings are the original. So, if you guys want to work off of this, we can. ### In my opinion, when it comes to motions, staff shouldn't be putting words in commissioners' mouths. If Commissioner Scharff had moved the staff recommendation (with exceptions), then it would have been appropriate for the visual to start with the staff recommendation (on page 1 of the staff report). 3:08:07: Commissioner Scharff: Great. ### I would rather have heard Commissioner Scharff make his motion in his own words. 3:08:08: 96 Vice Chair Segal: I would just say, Dave, with 1), I would break that into two, so it's clear that, you know, that we start with the communication and education. And -- yeah -- And I -- you know, I guess you can "develop" the survey. But to not execute it after 1). I don't know if you want to say that here. But -- 3:08:34: Dave Yuan: OK. ### This sounds like a so-called "friendly amendment." Vice Chair Segal should be asking Commissioner Scharff if he'll accept the friendly amendment. Staff should not be in the loop. 3:08:37: Commissioner Smith: I think we can leave timing of the survey, if you will, to be determined. But we really do need to educate and engage first. 3:08:47: Chair Forssell: Can I ask, is it a big deal, and expensive, to do a survey? 3:08:52: Commissioner Scharff: It's like $25,000 to $30,000. ### As I recall, the first FTTH survey from 2002 cost about $40,000 (in 2002 dollars). But then, staff did a follow-up survey, to ask questions they forgot to ask the first time, and I don't know what that cost. In this case, I think the same group of people answered both surveys. The City surveyed 960 people. https://www.paloaltoonline.com/weekly/morgue/2002/2002_10_04.fiber04.html ### In 2012, the City surveyed 401 people about user-financed FTTP. I don't know how much it cost. https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2012/06-06-2012-meeting/item-1_uac-report- broadband-system-project-june-2012.pdf 3:08:55: Chair Forssell: I'm intrigued by Commissioner Danaher's idea of a before and after. To really just get quickly to how many people -- you know, what do people think of their current level of service. 3:09:11: Vice Chair Segal: I mean, I could tell you that when I put in a request on NextDoor -- what do you prefer, when I was trying to decide which one to go with, all I -- [laughs] -- there were about 50 negative comments. I don't think that we need a survey. I don't think anyone loves their provider. 3:09:26: [general laughter] 3:09:28: Vice Chair Segal: I just think they choose the lesser of two evils. Or, what provides the best service in their neighborhood. Is what I took away from that. But I also worry that there's -- you know, survey fatigue. And I wouldn't want to lose the more important second survey. ### Good point. ### I don't see the point of having a "warm-up" survey. I don't think it will help to formulate the "real" survey, or, really, to serve any other useful purpose. And it will cost time and money. 97 3:09:46: Chair Forssell: Fair enough. 3:09:47 Commissioner Scharff: Well, it's usually some different people that are surveyed. Right? You know. 'Cause they choose 600 homes, or -- I mean, it's more expensive, the more homes you choose. And if you do two surveys, you're not usually choosing the same group. At least that's my understanding. But I could be wrong. ### It depends on what you're trying to find out. In the City's 2002 FTTH survey, they wanted the same people to answer both the original survey and the follow-up survey. But I know it's usually, you know, a finite group. They don't survey the whole City. But -- 3:10:13: Commissioner Jackson: So, I think we're trying to make this motion. Right? ### Right. Rather than just chit-chat, at this point? 3:10:19: Commissioner Scharff: Yup. 3:10:19: Commissioner Jackson: So, I would -- I would like the last item to be like the first item. Recommend the City bond and build. Like, we want to go do this. OK? And then, the rest of it is, like, HOW are we going to go do it? Right? How many people like that idea? 3:10:36: Commissioner Smith: I think, Commissioner Jackson, you make a very interesting point. And this is -- might be something that perhaps the City Council will have a discussion about. ### Again, I'm allergic to the term "discussion." When City Council talks it about it, it will be an action item. Bond and build. They -- we don't need to bond anything to actually build the backbone. ### But we don't actually need the fiber backbone. At least, we don't need the all-singing-all-dancing fiber backbone. To the new fiber backbone. We don't need to do anything. We just need to spend the money. ### There hasn't been a detailed analysis yet of where all the money should come from to build everything that should be built. So I think UAC shouldn't just buy into staff's plan to use up Fiber Fund money to build an all-singing-all-dancing backbone when a lean-and-mean fiber backbone might be all FTTP needs. So, we could, actually, break this out further, and we could say, go ahead and build it. 3:11:05: Commissioner Jackson: Go build the fiber expansion piece. Right? 3:11:11: Commissioner Scharff: Well, the risk to doing that, which I think you have to be cognizant of, if we just build that piece, we may not do the rest. Whereas, if you do it -- I thought the models he showed us ... 98 3:11:21: Commissioner Smith: Good point. 3:11:21: Commissioner Scharff: ... actually did have them doing both together, and not **. 3:11:25: [multiple speakers] 3:11:27: Commissioner Scharff: ... we won't do the whole thing. 3:11:28: Commissioner Smith: Very good point. I would not ... 3:11:30: Commissioner Jackson: OK. Let's put it all in one thing. We would do ... 3:11:44: Commissioner Smith: Yeah. I wouldn't want -- I agree 100 percent with what Commissioner Scharff just pointed out. I would not want to give -- I would be very reluctant for them to say, I'm going to build THIS part, but I'm not going to build THIS part. That's not what I think I'm hearing this evening. 3:11:55: Commissioner Jackson: OK. So, you could put both recommendations into number 1). Which is, do the fiber expansion AND do the fiber-to-the-home. 3:12:04: Chair Forssell: Is it -- is it -- Is it premature -- or is it necessary -- I mean, there's -- Remember, the -- we're recommending that Council create detailed engineering plans for both fiber-to-the-home and the backbone. So, it feels premature to say we recommend that City Council approve BUILDING it. Since the next step is the detailed engineering designs. 3:12:34: Commissioner Smith: I -- I -- From my -- From my own perspective, ... 3:12:38: Chair Forssell: Design with intent to implement? 3:12:40: Commissioner Smith: I do absolutely understand the concern, Chair Forssell. But I think -- also, I think -- you know -- and I will -- won't speak for the rest of our colleagues, but I -- I -- I hear a strong representation that this is the right course of action. So, it would be really nice that, as part of this motion -- and message to City Council -- that we've listened to what Magellan has said. We've listened to their analysis. And we DO believe that we are on the right course of action. And if we are going to advance the design, let's start talking about how we are going to fund it, as well. And move to that concurrently. Because the City will work on the funding. Magellan will work on the design. 3:13:33: 99 Commissioner Scharff: So, we should take out "bond and build." We should just say "build." And then something else should say, you know, explore the most cost-effective way to finance this. 3:13:44: Commissioner Smith: Sure. 3:13:46: John Honker: And, if I can add a point, there, I think the engineering becomes a way to ground truth -- the final costs. Right? And create the opportunity for the final amount that would be, you know, financed by the City. So, it's a step towards building. But it's not -- you know, it gives you sort of flexibility. 3:14:10: Commissioner Smith: I'm -- I'm curious, Council Member Filseth. Your thoughts. 3:14:20: Council Member Filseth: Thoughts. 3:14:22: [chuckling] 3:14:25: Council Member Filseth: I don't want to try to influence the group. ### Great answer. Council wants UAC's advice. But then, at 3:14:18, Council Member Filseth yields to temptation. 3:14:29: Commissioner Smith: OK. 3:14:31: Commissioner Jackson: What -- 3:14:34: Council Member Filseth: I'll make an observation, though. 3:13:37: Commissioner Jackson: [chuckles] 3:14:38: Council Member Filseth: Which is -- you know, all the numbers look great. Buried in there, you've got some interesting assumptions. One is, sure, we can get 25, or 30, or 40 percent market share. No problem. OK? ### The presentation said that a take rate of 24 percent would break even, and that municipalities tend to average maybe 40 percent. And, nah -- AT&T and Comcast aren't going to cut their prices, you know, when they see -- when they see this coming along. Second is that, well, we don't have to worry about -- we don't have to worry too much about TV bundles. Right? Which -- 'Cause everybody can go get Sling. But, you know, it remains to be seen. And, finally, that -- the fund balance chart. Right? I mean, I bet that thing's really sensitive to small changes in the take-up rate and how much money we can charge. 'Cause you got sort of small amounts of money compounded over large amounts of 100 time. So, I think we should just -- you know, I think overall, it looks pretty good. I think we should make sure we understand where all the risks are. 3:15:50: And the survey stuff -- There's some interesting stuff on the survey stuff that I personally would like to know. How many cord-cutters out there are there? So, I'm a cord-cutter. OK? But I don't know if I represent 5 percent of Palo Alto, or 50 percent of Palo Alto. And, you know, how many people want TV? And how many don't? You know, Sling TV's got, you know, 70 channels, or something like that. XFinity's got 250. Does that make a difference? I don't know. Right? So, this -- I think -- Stuff that we don't know yet I'd like to know about. And we'll find that out during the community engagement process. So, it's a -- Anyway, that's my two bits. 3:16:29: Commissioner Smith: Thank you. 3:16:37: Commissioner Jackson: So, we can go delete 6), right? ### At this point, 6) was about public-private partnerships. 3:16:47: Commissioner Scharff: Yes. 3:16:49: Commissioner Jackson: OK. 3:16:50: Dave Yuan: Should we start back from the top? Just so I'm clear. So, we're good with number 1)? We see ** ### That is, "1. Recommend fiber backbone expansion and City ISP FTTH model; optimize business operations with a mix of insource and outsource services." ### I'm NOT good with the fiber backbone part. 3:16:58: Commissioner Danaher: Well, so, the staff recommendation was to proceed with Phases 2 and 4 of the engineering. Which gives us the more detailed cost model. I think that's the appropriate thing. We're not -- we don't have to be at the decision yet. But that'll --And, like, Eric makes some good points on -- you know, I hope we're not ready to pull the trigger on the build-out. 3:17:27: Commissioner Jackson: Well, my point of view is that Council's not going to do anything they don't want to do. OK? Just because we put a recommendation ... 3:17:35: Commissioner Smith: [hearty laughter] 3:17:37: Commissioner Jackson: OK? So, look, my worry on that is very, very low. I think it's -- Look, even if Council just goes and says, "We're just going to do Phase 2 and Phase 4," it's -- they can -- you know -- But, I think it eliminates extraneous paths to pick a path. OK? If you say, we're just not going to go down the partner-ISP thing, then we just save all that work, and all that time. If we say, we're going to put our focus on "bond-and-build," then that -- then let's just focus on 101 that. It doesn't mean they've committed to doing it yet. But it's like -- But that's the focus. And then they should go figure out how they want to go do that. Instead of, you know, analyzing this ad infinitum. So, I guess ... 3:18;26: Council Member Filseth: You're -- you're -- you're -- you're mak- -- you're making some broad assumptions about Council not paying much attention to UAC. [laughs] 3:18:34: Chair Forssell: Commissioner Jackson, is it fair to say that maybe what you're getting at is, evaluat- -- on point 5), evaluating different financing models for building the entire system up-front, rather than, you know -- and do not consider ... 3:18:53: Commissioner Scharff: I think that's what he's getting at. 3:18:54: Chair Forssell: ... just roll out. 'Cause you're really not saying build it tomorrow. But you're saying let's stop considering these other ways we could build it, and focus on ... 3:19:02: Commissioner Jackson: Yes, Chair. That's an excellent idea. Let's do say that. That's what I meant. Even though I could have never said it myself. 3:19:13: Chair Forssell: So, it wasn't -- It's not the fact that it's this [City] ISP model. It's the fact that we don't want to do this phased, 40 percent in three years, and another 30 percent in 10 years, and, 40 percent, we're not really sure when they would get it. ### Well, the percents don't add up. But, yes, we don't want to do the so-called incremental approach. 3:19:26: Vice Chair Segal: Maybe the way to get it is to do it by timing -- in the, you know, fastest, most cost-effective way. Or something like that. 3:19:35: Chair Forssell: Well, it's not cost-effective. That's ... 3:19:37: Vice Chair Segal: OK. That's fastest. [laughs] We know it's ... 3:19:40: Commissioner Scharff: It's to evaluate different financing models to build it out to the entire City. Within 5 years. 3:19:46: Vice Chair Segal: There you go. 3:18:47: Council Member Filseth: You know, if I could chime in -- Listening to the commissioner here, I actually think you sort of had two different thoughts going on in this. One was, I think what I heard, a reluctance to go out with a plan that doesn't 102 cover the entire City. OK? To say, this part of the City, we don't know what we're going to do. We'll decide some other time. So, that was one. But I also heard Commissioner Segal, early on, commenting on the staged thing more as, well, you know, we could do SOME of it up-front, and see if we really hit our take [rate] targets, and so forth. And then, if we do, to proceed with the rest of it. ### I don't remember Vice Chair Segal's saying that. But staff's idea for the incremental approach is to do the first stage with money we already have (or can borrow from the Electric Special Projects Reserve), and then use "excess" FTTP revenues to fund the next stage. But if the system doesn't hit its take rate targets, there won't be much "excess" FTTP revenues. And so, there were sort of two thoughts. One was, should we do it -- commit to the whole thing all at once or not? And, two was, should we go out with a plan that doesn't cover all of the City. And I think those are two slightly different things. Right? I mean, one was more along the lines of, you know, are there some test marketing we can do? And the other was, well, what do we do about, you know, parts of the -- all the rest of the town that's going to be the hardest to get to? And I don't think that those are the same. And so, I think -- It looks to me like you guys are trying to sort of encapsulate some of both of that. 3:21:05: Vice Chair Segal: So, let me just make it clear what I meant. 'Cause that's a fair point, that we should clarify. So, 1), yeah, the -- not covering everyone -- for all the reasons we've talked about -- I don't feel good about. And then, 2) my only point was that, as you roll it out, to look at the early take-up as funding for the later, which I only saw when it was the long term proposition. But I don't see why it can't also be incorporated into a faster roll-out and uptake model. Does that clarify that? 3:21:53: Chair Forssell: Vice Chair Segal, do you want to suggest language that captures what you have in mind? 3:22:00: Vice Chair Segal: Well, I mean, I think that's just evaluating different financing. It's just the idea that there was this divide that I thought was a false divide. If you're rolling it out, different portions are going to be lit up at different times. And different customers -- Not every customer is going to be turned on day one. And so, just to look at that as more revenue, and not only factored that in when we're looking at a ten-year -- or ten-year-plus -- plan. But I think -- The only point is that, consider the early revenue as part of the funding for later expenses. 3:22:42: Commissioner Scharf: You know, I think we said 5 years, not "XX." Just ... 3:22:46: Commissioner Smith: Yeah, Dave. I was just going to highlight that. 5 years. 3:22:50: Chair Forssell: So, is it "evaluate different financing models, to build out over the entire City over 5 years" -- you know, including using revenue from early high-expected-uptake neighborhoods to finance later neighborhoods ... 3:23:15: Commissioner Scharff: Well, do we need to be prescriptive about how we would do the financing from here? I mean, that's obviously one approach. And it may be the best approach. But -- Using COPs may be a good approach. I mean, I don't know what it is. I mean, I just think ... 3:23:27: Chair Forsell: Yeah. So maybe it's just, put the period after "5 years." 3:23:31: 103 Commissioner Scharff: I'm just saying, we should give broad advice, and say, look, we want this to look this way. And, I guess I did want to make one other comment on Council Member Filseth's point. And I think -- just so I understand that -- and I was thinking a little bit -- If, for instance, we are going to spend a lot of money to do this, and the take rate turns out to be 15 percent, and it's a disaster, you know, what is the down side to the City? And I think that's really Council Member Filseth's concern. And if that's the concern, and Council felt that way, then you actually probably would do the conservative approach, which is build it out slowly, and leave out 40 percent of the City, and do it that way. That would be better than doing nothing. But, while I share the concern, I don't think that's what's going to happen. And so, I'm less risk- averse. But if you really more risk-averse, you would do the -- what we're NOT recommending. And I just think we need to just recognize that we're taking the more aggressive approach, because we have faith that we will offer a good product that, you know, at least 25 percent of the people of Palo Alto will want. And -- I mean, I think that's almost a new business. And it's almost sort of "faith-based" on some of that. And, yeah, we'll do surveys, and we'll do market studies, and all of that. But, you know, at the end of the day, there's going to be a risk there. 3:25:00: Vice Chair Segal: That's an interesting point. I guess it goes back to my earlier comment, which is -- And I don't know how the COP works -- if you have to do it all on the front end, because -- I mean, maybe we enter into a contract for the whole City, or a big portion. And maybe we save a lot of money doing that. But we will be turning it on over -- over time. So, it it won't be 5 years of build-out and then, you know, we flick a switch and everyone is lit up. It will be over time. And so, we'll have a sense, too. And we'll have a sense, frankly, of what -- or whether AT&T and Comcast are trying to come in and compete with steeper discounts. 3:25:37: Commissioner Scharff: Yup. 3:25:40: Dean Batchelor: Commissioners, if I could just point out one thing on number 5. It's going to take more than 5 years to build the whole plant out. John, don't we -- John, don't we have that out at 7 or 8 years? 3:25:54: John Honker: Well, we had it between 5 and 7 -- total build-out. But the majority of the build-out we would expect over sort of that 5-year period. 3:26:00: Dean Batchelor: The majority of it. Yeah. But, ... 3:26:03: Commissioner Scharff: Well, the good plan -- Dean, I totally agree with you. But the good plan is to say 5 and then it takes 7. 'Cause if we say 7, it will take 10. 3:26:10: Dean Batchelor: [laughs] All right. 3:26:12: Council Member Filseth: There's a guy who worked in government. [laughs] 3:26:16: Vice Chair Segal: Well, there's always the hope that we can change some of the permitting, and move it all along, as well. Right? Wasn't that build into the model -- is a shorter work day? 3:26:26: 104 John Honker: Right. 3:27:26: [others]: Right. 3:26:27: Dean Batchelor: I'll just remember -- when the community is asking me about it, I'll ask Greg to answer those questions for me. Thank you. 3:26:33: Commissioner Scharff: Exactly. 3:26:34: [laughter] 3:26:34: Commissioner Jackson: OK. So, now, I have some more wordsmithing. I would propose to move 5) to underneath number 1). And so, maybe the new 2). And then I would move 4) to be underneath that. OK? And move 4) to that. Yes, that. Move that to there. And then delete number 7) -- whatever it is. Down there. It's -- Well, not that -- whatever that is. OK. Scroll up. There. I'm finished wordsmithing. 3:27:17: Commissioner Danaher: So, I have it -- I have it formulated some what differently. It would be -- ah -- of whether 1) and 2) could be changed. But -- quick -- Magellan do 2 and 4 in tandem, build out fiber backbone in a manner designed to support citywide fiber-to-the-home, proceed toward city-ISP, to offer fiber-to-the-home service. And sub-points to that would be: evaluate financing alternatives, conduct community engagement and customer survey, complete risk analysis. 3:27:50: Commissioner Smith: May I ask a question of John Honker and the team at Magellan? If we combine phases 2 and 4, when do you anticipate completion? 3:28:00: John Honker: So, we would be looking at -- the backbone piece of it, we would be looking at the end of the year. And we would be looking at phase -- we would be looking at the fiber-to-the-home phase first quarter of next year. 3:28:15: Commissioner Smith: Then, can we modify number 4) -- accelerate communication and education of fiber-to-the-home -- to represent -- since we're in the middle of this year -- to complete by Q1 of next year? So that that education process is complete? That engagement process is complete by the time the design is actually done? The assumption being, then, that the survey would happen -- perhaps -- Q1 of 2022. So that it all comes in -- all information is available at the end of Q1 2022, for -- let's go and do it. 3:29:00: Commissioner Jackson: What -- I'm sorry. I -- I -- I heard Commissioner Danaher say something. And I ... 3:29:07: Commissioner Danaher: I was thinking, it seems to me a no-brainer. We do the fiber backbone expansion. And we do it in a way that would support fiber-to-the-home. 105 ### I think UAC hasn't thought enough about why a fiber backbone expansion is necessary at all -- either for fiber-to-the- home or for any other reason. 3:29:16: Commisisoner Jackson: OK. All right. OK. Is that not captured here? Or ... 3:29:21: Commissioner Danaher: Maybe it's captured **. 3:29:24: Commissioner Jackson: OK. That's what I was -- I just wanted to make sure your concern was being addressed. 3:29:29: Commissioner Danaher: Yes. I think the -- Mixing that up maybe with the optimized business operations. But that's OK. 3:29:40: Commissioner Jackson: OK. So, are we ready to think about this? [laughs] 3:29:45: Commissioner Scharff: Maybe we should just ** -- to prove it. 3:29:50: Chair Forssell: Commissioner Scharff, this was your motion. Right? 3:29:51: Commissioner Scharff: Yup. I'll just go ahead and say that's my motion. And I forget who seconded. 3:29:55: Commissioner Jackson: I'll second it. ### The motion was seconded at 3:07:46 by Commissioner Jackson. (According to the official draft minutes.) 3:28:57: Chair Forssell: All right. Do we have any further discussion before voting on this motion? [pause] All right. I think, in that case, ... 3:30:09: Vice Chair Segal: No, wait. Wait. I'm sorry. I'm just reading 4). So, 4) we're going to make sure the education communication by Q1 2022. And the survey will be done by the same time? Is that what our goal is? Or do we want -- I mean, -- 3:30:28: Commissioner Smith: It's a great question, Vice Chair. The way I was thinking -- in my head -- Having ALL of the information -- the design, the engineering, the funding, the education, the survey results -- all available by March 31, 2022. So, in April of 2022, it's all there. We know exactly what we're going to do, exactly how long it's going to take, and how we're going to get it. 3:30:58: 106 Vice Chair Segal: I love that idea. I was just sort of ... 3:31:00: Commissioner Smith: OK. 3:31:00: Vice Chair Segal: ... since we've been talking about education coming before a survey. But, I guess maybe that's being too precise. 3:31:11: Commissioner Smith: Oh. I se- -- 3:31:13: Vice Chair Segal: That was my only point. 3:31:15: Chair Forssell: I think he's trying to say it's done by Q1, and then, in Q1. So, one is intended to be before, and one is intended to be in that quarter. 3:31:24: Vice Chair Segal: Got it. Got it. 3:31:29: Chair Forssell: Is it -- 3:31:29: **: [unamplified] ** 3:31:31: Dave Yuan: Just to confirm, this is calendar year, right? We're not talking about fiscal year. ### Good point. 3:31:36: Commissioner Smith: Yes, Dave. Calendar year. Sorry. 3:31:38: Chair Forssell: Is it better to put March -- by March -- and then put starting in April ... 3:31:45: Commissioner Scharff: Yeah. Let's do that. 3:31:47: Chair Forssell: ... for clarity. 3:31:51: 107 Commissioner Smith: Well, I think your clarification of "by" and "in" are absolutely dead-on, Chair. So, it would be -- the survey would be done IN March 2020. ### 2022. The education would be done BY March 2022. The idea being that we are 100 percent complete with all of our documentation, all our planning, all our funding -- everything -- BY March 31, 2022. And in April, City Council is saying OK, this is the plan. This is what we're doing. 3:32:21: Dave Yuan: So, in April, are we releasing the survey? 3:32:33: **: No, it's only ... 3:32:34: Commissioner Smith: No. In ... 3:32:36: Commissioner Jackson: Commissioner Smith is saying, change "IN April" to IN May -- "IN March." ... 3:32:42: Commissioner Smith: Yes, I am. Yes, I am. So, Dave, to answer your question, in order to make the survey -- um -- to get it out to people, I would probably say it would probably be the end of January. And give them a 60-day notification period. Something like that. It wouldn't be -- It would end of January. ### Commissioner Smith may be assuming that the survey would be conducted by mail. But previous surveys have been conducted by phone. So, the whole month of February, the whole month of March. 3:33:05: Chair Forssell: It's -- 3:33:08: Commissioner Jackson: I'm feeling like this is getting a little micromanagy. 3:33:09: Chair Forssell: Yeah. I think so, too. 3:33:12: Commissioner Danaher: Yeah. So, let me -- let me try this again. Just -- I'm trying to make it between what our high- level objectives are and then what we want to do in between. And it's very much just a mix of what you have. Number 1), ... 3:33:25: Dave Yuan: Should I write that ... 3:33:26: Commissioner Danaher: Yeah. This is a recommendation. 108 1) Build out fiber backbone in a manner designed to support citywide FTTH. 2) Proceed towards city-ISP to offer FTTH service. 3) By March 31: * complete Magellan Phases 2 and 4, * complete detailed city-ISP model, including mix of insource and outsource, * conduct community engagement and customer survey, * complete risk analysis, * determine best financing mode. 3:33:56: Dave Yuan: Commissioner Danaher, can you share your screen instead, and show us? If you have it typed up? 3:34:00: Commissioner Danaher: Ah -- OK. Let me try that. 3:34:05: Dave Yuan: Then I could take a screen shot of that. 3:34:06: Commissioner Danaher: Ah -- Let me get back to you on that. Where's my "share-screen" button here? 3:34:12: Dave Yuan: It should be on the bottom -- next to ** 3:34:14: Commissioner Danaher: Ah -- Here it is. Well, I cannot start the screen-share while the other participant is sharing. 3:34:21: Dave Yuan: ** stop sharing. 3:34:27: Commissioner Danaher: Ah -- Let's see -- Well, let's go back to my shared screen here. Ah. There we go. Is this show -- Is this sharing now? 3:34:39: Commissioner Scharff: No. 3:34:41: Commissioner Danaher: All right. Again -- [pause] Now, let's see if it's sharing now. 3:34:55: Dave Yuan: Try again. I'm trying to stop sharing. 3:35:00: Commissioner Danaher: OK. Maybe I need to go side-by-side. Let's try that. 3:35:04: 109 ### Commissioner Danaher's screen now shows on the video. 3:35:05: Commissioner Jackson: Here we go. We got it. You got it. 3:35:08: Commissioner Danaher: OK. I got the numbering wrong. ### The screen says 2), 3), and 4), not 1), 2), and 3). 3:35:15: Commissioner Danaher: It's all your idea. I'm just trying to put down the objectives and how to get there. 3:35:33: Vice Chair Segal: I think the only thing is the ... 3:35:35: Commissioner Jackson: Right. So, just ... 3:35:40: Chair Forssell: Go ahead, Vice Chair Segal. 3:35:43: Vice Chair Segal: It would COMPLETE community engagement. Right? 3:35:46: Commissioner Danaher: Oh. OK. Got it. Sure. 3:35:52: Commissioner Smith: And I -- I would prefer that we not drop education. And then "proceed towards city-ISP to offer fiber-to-the-home service," I think, is less strong than the previous wording. 3:35:07: Commissioner Danaher: OK. All right. "Establish city-ISP to offer fiber-to-the-home service"? Is that ... 3:36:18: Commissioner Smith: More direct. Yes. 3:36:19: Commissioner Danaher: All right. OK. Yeah. It's somewhat ... ** ... somewhat subject to the analysis that comes forward. But I think that's understood. Sorry I had the numbers wrong here. But -- 3:36:37: Commissioner Jackson: Can we say "Establish CITY as ISP offer a ** service"? Is that too -- 3:36:42: Commissioner Danaher: Oh. "City-operated ISP"? 110 3:36:37: Commissioner Jackson: Yes. Sure. Great. Love it. 3:37:00: Chair Forssell: How about the piece about evaluating federal and state granting -- 3:37:07: Commissioner Danaher: Oh. I think I'll just add there "including the availability of grants." Oopsie 3:37:18: Chair Forssell: I think it's also -- It's not only "complete" Magellan Phases 2 and 4. It's "combine" them. Because it's a deviation from the existing plan. 3:37:30: Commissioner Smith: And then, finally -- back to "complete community education, engagement, and customer survey," I think we also need to accelerate it. I think that was a word that was dropped. And I ** ... 3:37:41: Commissioner Jackson: Well, it's by March 31st. It's all happening. 3:37:44: Commissioner Smith: Yeah. But -- 27,000 people. Or, sorry. 27,000 homes. It's ... 3:37:52: Commissioner Danaher: OK. What's -- So, what wording do you want? 3:37:53: Commissioner Smith: "Accelerate and complete community education engagement and customer survey." 3:38:05: Commissioner Johnston: Why don't we make that point number 3). And then, point number 4) is the "By March 31." 3:38:14: Commissioner Smith: Oh, that -- that we complete. We could do that. Absolutely. 3:38:18: Commissioner Danaher: Like this. And then move this one up here. 3:38:22: Commissioner Johnston: Right. 3:38:31: Commisisoner Danaher: Oops. Well, we got the -- all right -- sorry. 3:38:42: 111 Dave Yuan: You're doing great, Commissioner Danaher. 3:38:44: Commissioner Danaher: [laughs] 3:38:49: Commissioner Jackson: So, now you can delete the "accelerating ..." 3:38:53: Commissioner Danaher: I tried to -- I thought I had deleted -- Yup, I deleted it. 3:38:57: Vice Chair Segal: And, I don't know, on the last bit, about the availability of grants, if it's important to say -- um -- government grants. Or ... 3:39:08: Commissioner Danaher: OK. Sure. Federal grants. However you want. 3:39:15: Vice Chair Segal: Well, state and -- what did it say? State and federal? I can't remember. ... 3:39:19: Commissioner Jackson: ** challenges -- So, is this good enough? Are we getting good enough? Close enough? Or do we really need to do more? I'm just asking. We can decide we need to do more. 3:39:32: Chair Forssell: You mean on the motion? 3:39:34: Commissioner Jackson: Yes. 3:39:36: Chair Forssell: I do have one question. Which is if City Council is going to get the same report and slides that we do, then we haven't clarified our preference for the -- for not stranding 40 percent of the City, with no specific plan for how you would finance or build it. 3:39:59: Commissioner Danaher: About the citywide? 3:40:01: Chair Forssell: Yeah. 3:40:03: Commissioner Jackson: Yes. 3:40:05: Chair Forssell: I think that does it. 112 3:40:07: Commissioner Danaher: All right. Might as well be consistent. 3:40:08: Dave Yuan: ** the staff report. 3:40:09: Commissioner Scharff: Well, you also dropped the 5 years. And ... 3:40:14: Commissioner Danaher: Ah -- Ah -- OK. "Within 5 years"? 3:40:17: Commissioner Scharff: Yeah. Or you could say 5-7. But, 5. Yeah. 3:40:20: Commissioner Danaher: OK. 5 or 5-7, whatever you want. 3:40:23: Commissioner Scharff: Go with 5. 3:40:24: Dean Batchelor: I like 5. 3:40:26: Chair Forsell: [laughs] 3:40:27: Commissioner Jackson: 5. 3:40:30: Chair Forssell: All right. Commissioner Scharff, it's still your motion. Are you happy with this motion? 3:40:38: Commissioner Scharff: Um -- Yup. I just think that we should -- Not to nitpick, but I do this we should use similar language on the federal grants, which says federal and state grant funding options. 'Cause what we're telling them to do is go start writing grant proposals, I think. Right? 3:40:58: Commissioner Danaher: All right. 3:41:00: Commissioner Scharff: OK. I'm good with that. 3:41:02: 113 Commissioner Jackson: I re-second. 3:41:05: Chair Forssell: All right. Um. Is there any further discussion before we move to a vote? [pause] All right, then. I'll start the roll call. Vice Chair Segal. 3:41:20: Vice Chair Segal: Yes. 3:41:23: Chair Forssell: Commissioner Johnston. 3:41:25: Commissioner Johnston: Yes. 3:41:27: Chair Forssell: Commissioner Scharff. 3:41:28: Commissioner Scharff: Yes. 3:41:30: Chair Forssell: Commissioner Smith. [pause] 3:41:35: Commissioner Smith. Sorry. Yes. 3:41:37: Chair Forssell: Commissioner Danaher. 3:41:39: Commissioner Danaher: Yes. 3:41:40: Chair Forssell: Commissioner Jackson. 3:41:41 Commissioner Jackson: YES. 3:41:42: Chair Forssell: And I vote in support, as well. 3:41:46: Vice Chair Segal: [laughs] I don't know if -- Do we just need a -- include mix of insource and outsource what? You know, ... 3:41:53: 114 Commissioner Danaher: Oh. Insource and outsource functions? 3:41:56: Vice Chair Segal: Yeah. 3:41:57: Commissioner Danaher: Is that all right with people? 3:41:58: Commissioner Scharff: Yeah. That's fine. 3:41:59: Chair Forssell: Yes. 3:41:59: Commissioner Jackson: Yes. 3:42:02: Vice Chair Segal. Sorry, I don't if that ... 3:42:04: Commisioner Jackson: Ship it. 3:42:04: Commissioner Danaher: Fair enough. 3:42:05: Chair Forssell: I think it's clear. Again, If they're going to get the same report that we got, it's clear that -- what we're talking about, I think. 3:42:12: Commissioner Jackson: This is fine. 3:42:13: Chair Forssell: All right. Great. So, the motion carries unanimously. Thank you, everybody, for your input. We're on the home stretch ... 3:42:22: Commissioner Danaher: David, you got what you needed? 3:42:25: Chair Forssell: Say that again. 3:42:26: Commissioner Danaher: Dave said he ... 115 3:42:29: Dave Yuan: Yeah, I got a screen shot already. Thank you. 3:42:31: Commissioner Danaher: OK. Great. Thanks. 3:42:34: ### End of Item VII.1. 701-32 DOCUMENTS IN THIS PACKET INCLUDE: LETTERS FROM CITIZENS TO THE MAYOR OR CITY COUNCIL RESPONSES FROM STAFF TO LETTERS FROM CITIZENS ITEMS FROM MAYOR AND COUNCIL MEMBERS ITEMS FROM OTHER COMMITTEES AND AGENCIES ITEMS FROM CITY, COUNTY, STATE, AND REGIONAL AGENCIES Prepared for: 06/01/2021 Document dates: 05/12/2021 – 05/19/2021 Set 5 Note: Documents for every category may not have been received for packet reproduction in a given week. 116 Baumb, Nelly From:Jeff Hoel <jeff_hoel@yahoo.com> Sent:Thursday, May 13, 2021 5:19 PM To:Council, City; UAC Cc:Hoel, Jeff (external) Subject:TRANSCRIPT & COMMENTS (Part 2) -- 04-21-21 UAC mtg -- FTTP CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Council members and Commissioners, Part 2 of the TRANSCRIPT. Jeff ################################################################################################# ################## Video: https://midpenmedia.org/utilities-advisory-commission-31-4212021/ Staff report, including the presentation slides (pages 47-102) https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2021/04-21-2021-special/id-12118-item-no-1.pdf 1:12:01: ### Slide 11 Chair Forssell: I'm not seeing any hands up. Why don't you go ahead. 1:12:04: ### Slide 12 John Honker: Great. OK. So, this -- When we start talking -- thinking about fiber-to-the-home, you know - And you guys have had a lot of experience with this in the past. And you've, you know, analyzed it. Looked at it. So, I wanted to just kind of level-set on, you know, what the problem is. And why cities really consider it. You know, we think about the digital equity issue in places like Palo Alto. Do residents and businesses have equal access to high-speed internet? You know, as we did our initial review of the market, we found that you do have AT&T providing fiber in some areas. But in some areas, you can only get 25 megabit from AT&T. ### And in some places (like my house), AT&T offers at most 768 kbps down and even slower up. In other areas, we found, you know, cable service up to a gig. ### 1 Gbps down, but only 35 Mbps up. And in some areas, we found cable service up to 300 meg. ### In general, upload speeds are important too. So, you know, one of the key issues is really understanding the equitable access for residents and businesses across the City. And also, you know, the speeds people receive are really "up to." So, your mileage may vary, based on where you - 117 live in the City, and how far you are away from the provider's node. So, these are two issues that we see. And, as we move into the survey work in this next phase, you know, that -- those issues will teased out to a much greater degree, through the survey questions. To be able to understand what people actually have, AND what kind of speeds they're actually receiving, compared with what they're actually buying. So, the survey work that we would propose to do would measure, you know, what they pay for today versus what they actually get. And we'll be able to, in real time, speed test those customers' homes, and be able to see how much bandwidth they're actually getting through those areas. 1:13:56: So, those are a couple of issues that we see. And then, also, do residents and businesses have choice in Palo Alto? And in some cases, more than one option exists. For high-speed internet. In other cases, only a single provider exists. ### Will the survey notice that AT&T is no longer accepting new DSL customers? Finally, are prices affordable? Given the existing monopoly/duopoly market that we see in Palo Alto? Right? The cable company and the telephone company really control the market. And they do in most cities. Right? In most cities, you have two options, and in some places, you only have one. But, you know, the greatest law of economics is that when consumers have alternatives, providers have to compete on price. And I think what we SEE in Palo Alto, in some areas of the community, there IS no price competition, because there is no competition. So, you may have one high-speed service that's providing 300 megabits. The alternative is a 25-meg DSL service. That 300-meg cable service doesn't have to compete on price. 1:14:59: So, these are just -- Really, this is just more of a framing slide, for -- as we start to talk about fiber-to-the-home. And some of those key issues, that, again, we think are really going to be teased out well in the survey, coming up here in the next couple months. ### However, UAC ended up advising Council that the City should educate the public about the FTTP opportunity BEFORE doing the survey. 1:15:13: ### Slide 13 1:15:15: Commissioner Scharff: So, wait. Is that actually true? 1:15:16: ### Slide 12 again Commissioner Scharff: I mean, you guys looked at it. I mean, I thought we basically had AT&T and Comcast throughout the entire City. But I could be wrong. I -- ### BroadbandNow says https://broadbandnow.com/California/Palo-Alto AT&T claims that in 28.2 percent of Palo Alto's census blocks, at least one premises has access to AT&T Fiber. And that in 99.8 percent of Palo Alto's census blocks, at least one premises has access to some kind of internet service. 1:15:24: John Honker: You do. 1:15:24: Commissioner Scharff: And then some other people have something else, I noticed. There's at least one or two other providers that people have once in a while. - - 118 ### BroadbandNow mentions some wireless providers, and some satellite providers, and Sonic (which, I think, in Palo Alto uses AT&T's wired infrastructures). https://broadbandnow.com/California/Palo-Alto 1:15:33: John Honker: And -- And .... 1:15:33: Commissioner Scharff: Did you do the research and look at that? 'Cause it doesn't seem true. 1:15:35: John Honker: We did, Commissioner Scharff. So, when we looked at the different -- The goal is -- You have to understand, you know, you do have AT&T and Comcast everywhere, ### Not exactly. BroadbandNow says Comcast claims that in 100% of Palo Alto's census blocks, at least one premises has access to Xfinity cable service. But the Palo Alto Hills Broadband Working Group says it's not available in their neighborhood. (See pages 10-12 here.) https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2021/04-07-2021-special/04-07-2021-public-letters-to- uac.pdf But they don't have the same speeds everywhere. So, when we look at AT&T, for example, they have fiber, you know, to some portions of the City. And provide gig service in those areas. But in other areas, we found only 25 meg. And in other areas, we only found 100 meg. So, there's three different tiers of service, depending on where you live in the City. ### Not counting the 768 kbps tier available to my house, in Midtown. (But this service might not be available anymore.) The cable provider was more ubiquitous, meaning they advertise the same speeds across the City. The key on that will be to understand if consumers are actually receiving those speeds. Or if they're getting, you know -- The question really becomes, have they really upgraded that entire plant to support gig? Or are there some areas of the City that are not -- that are not yet upgraded. And that's a big question. We see that in a lot of communities where they're advertising the full market, but there's less than gigabit service everywhere. 1:16:42: Commissioner Scharff: OK. 1:16:44: Chair Forssell: It looks like Council Member Filseth has a question as well. 1:16:47: Council Member Filseth: Yeah. Thanks. Sorry to crash. But, continuing on Commissioner Scharff's question, I saw in the staff report that AT&T says that they are "able" to provide up to 10,000 households in Palo Alto with fiber-to-the- home. If they wanted. Right? Is that true? 1:17:10: John Honker: So, from the data that we found, that's what they are reporting publicly -- is that they have fiber to up to 10,000 homes. Now, that "up to" is a very -- There's a lot that goes into that. Because in the FCC data, when they -- when we look at the census blocks that -- where they report that service, they only have to serve one customer within that census block for it to be considered served, with those kind of speeds. 1:17:39: Council Member Filseth: I see. 119 1:17:40: John Honker: So, it really becomes a question of ground-truthing the areas where they have service. And the best way to is really to reach out to the residents directly. I ask them what they have, what they're paying for, and then, really, speed- test their local service, so you understand what they're actually getting. ### This approach won't find the premises that AT&T passes but doesn't connect to. But OK. 1:17:59: Council Member Filseth: Oh. And -- Just, by the way, I have Sonic. But I believe they work over the AT&T network. So, I'm not sure they count as a third alternative. ### Right. 1:18:09: John Honker: You're correct. We looked at them, as well, and they use the AT&T local loops for providing service. So, it's the same -- the same baseline copper infrastructure that they're providing service over. ### I think Sonic can also use AT&T's FTTP infrastructure where it exists. 1:18:24: Commissioner Danaher: To your point, I've been dropped twice from this meeting already by my supposed "high-speed" data connection. ### Very good point. What is that connection? Provider? speed tier? Any concurrent traffic? 1:18:37: ### Slide 13 John Honker: OK. One other important point, as we start to think about fiber-to-the-home. Think about it as a platform for broadband. But it's also a platform for innovation for the City. So, when we really consider building fiber-to-the-home - - When you look at the cities that have done it, they're using the networks for a lot more than just broadband. Right? Because now they have fiber effectively to every street in the city. ### Not all cities that have municipal FTTP choose to deploy it citywide. But Palo Alto should. And that's, again, as we talked about the backbone enabling all the applications you see here, fiber-to-the-home is doing the same thing. ### Excellent point. So, why not consider doing all the "other" applications on the FTTP infrastructure, not on the backbone? So, we have a customer, BrightRidge, in Tennessee. 65,000 meters or so. And they're deploying fiber-to-the-home. ### Not citywide, however. They're integrating their AMI collectors with their fiber-to-the-home deployment, so they can keep their costs down, to reach -- to deploy AMI. ### Chattanooga was perhaps the first municipality to do this. The Broadband Communities website used to have an online database of FTTP networks. This article shows a 2015 snapshot of what the database had for muni and PPP FTTP networks. https://www.bbcmag.com/pub/doc/BBC_Aug15_CensusCommunityFiber.pdf Note that 20 munis said they were using the FTTP network for smart grid. (And I assume some of the munis listed were using the network for smart grid but failed to report it here. I also assume that most, if not all, of the munis that were doing smart grid were doing AMI.) - - 120 And it's going to save them a couple million dollars to actually deploy that without -- without having to put a bunch of additional wireless infrastructure into the city. So, they're basically leveraging their fiber network -- or, their fiber-to-the- home network -- for other utility purposes beyond just providing broadband. ### This is a very important point. And in almost every city that's been doing this -- Chattanooga, in Tennessee; Longmont, in Colorado; Fort Collins - - they're all using those -- that broadband. So, when you're thinking about fiber-to-the-home, don't box it in just for broadband. The enabling opportunities are much greater. 1:20:20: ### Slide 14 Chair Forssell: Commissioner Danaher has a question, I think. 1:20:22: Commissioner Danaher: Oh. Yeah. There's not a convenient place for this. But perhaps about demand for "up to" 1 gigabit, I want to know the likelihood that YOU think that people are going to want to exceed that, in their homes and offices, going forward. I think of the need for telepresence, higher-quality video, virtual reality, multiple users of the household, telemedicine, remote management of robotics -- on and on -- that the 1-gigabit is going to be seen as base case pretty soon, not the ceiling. But what's your reaction to that? 1:20:59: John Honker: No, we see that. I mean, we see a lot of of cities that have now deployed 10-gigabit. To the home. And it's still in its fledgling stages. But we know that, between ... ### Slide 13 again ... as you mentioned, telepresence, gaming, VR, ... 1:21:16: AUDIO SILENCE 1:21:18: ... virtual health -- a lot of that is driving heavy bandwidth. And, I would say, the most near-term driver is probably VR that's really pushing it up. Right? It's really coming from our kids. And they're driving it. And they're driving bandwidth. Because VR bandwidth at 4k is something like 650 megabits per stream. Upload. Right? So, we -- now we have -- We're going to need at least a gig upload for multiple streams. Right? And just one stream is 650 [Mbps]. So, we see those needs growing. And we see more providers and cities getting ready to equip their networks for 10 gig. The good thing about that is that, when you're building fiber-to-the-home now, you're not -- you don't have a forklift replacement, where you have to expand to 10 gig, and spend $10 million to $20 million. It's usually built into the network. You just have to turn it on as a feature, with additional licensing and some additional electronics. ### Is Honker saying that Palo Alto's first electronics should support 10 Gbps both down and up? And that future upgrades shouldn't have to be "forklift" upgrades (where all premises must be upgraded at the same time)? What technologies allow that? 1:22:18: Commissioner Danaher: Thank you. 1:22:22: John Honker: Sure 1:22:22: 121 ### Slide 14 again John Honker: So, what are other communities doing today? This is really just a good overview. We always like to provide this, because it gives you a sense of what other cities in the U.S. are doing, in terms of broadband. So, as we look at this, the yellow dots represent citywide municipal fiber-to-the-home networks, where the city is providing service. And the blues are citywide dark dark fiber. ### No. The "blue" dots are less-than-citywide FTTP networks. And the purple are dark fiber networks that may be less than citywide. ### Yes. I assume that most dark fiber networks are less than citywide. So, maybe a partial deployment. Considering what you have today, you would be categorized as basically a, you know, municipal network that's less than citywide. ### Here's an online interactive version of the map. https://muninetworks.org/communitymap Click on a symbol in the left column to toggle its visibility on the map. ### Yes, Palo Alto is a "purple" dot that has dark fiber. But the map doesn't say whether the dark fiber is citywide or not. I'm not interested in viewing the purple dots, and I don't know why staff and consultant are. ### The "blue" dots do NOT represent cities with citywide DARK fiber. They represent "communities with some publicly owned [FTTP] fiber service available to parts of the community (often a business district)." ### Yes, the "yellow" dots represent "63 municipal networks serving 125 communities with a publicly owned FTTH citywide network." In other words, some "yellow" dots represent multiple cities. 1:23:04: ### Slide 15 ### The meanings of the symbols in this slide don't correspond to the meanings of these symbols in the cited map. It would be better not to use those symbols in Slide 15. John Honker: As we look at these networks. these are the statistics on how cities are actually managing those networks. 63 of them, the city IS the ISP. Meaning they're providing all internet services. In some case, voice and video, but predominantly, internet. ### The cited map has an "Open Access" symbol that says which gray dots, yellow dots, blue dots, and purple dots offer open access. 43 of the 63 yellow dots offer open access. 286 cities provide wholesale or dark fiber. ### "Wholesale" and "dark fiber" don't mean the same thing. ### The cited map says there are "more than 120" dark fiber networks. ### The map says that 300 communities have some kind of FTTP network -- 63 citywide ("yellow" dots) plus 237 less- than-citywide ("blue" dots). And 71 are public-private partnerships. ### No. The map has a PPP symbol. The map displays the "PPP" symbol only in conjunction with a "yellow" dot or "blue" dot or "purple" dot. The map shows 23 PPPs, of which 8 are "yellow," 9 are "blue," and 6 are "purple." The map doesn't show how many of its PPPs are public-private partnerships and how many are public-PUBLIC partnerships. So, you can see, a massive amount of dark fiber. 122 ### The map says there are "more than 120" dark fiber networks. It doesn't say how "massive" each deployment is. Again, a lot of cities have dark fiber. So, they're using it either in dark fiber leasing, like you're doing today, or in wholesale. ### I don't know what Honker means by dark fiber being wholesale. 63 ISPs and 71 partnerships. ### No. There are 300 communities that have some kind of FTTP network: 63 citywide + 237 less-than-citywide. And 17 of those FTTP networks are PPPs. 1:23:45: Chair Forssell: And then, Mr. Honker, quick question on the previous slide with the map, 1:23:49: ### Slide 14 again which had things broken down differently. Of the "yellow" dots that provide municipal fiber-to-the-home, how many of them are in the same position as Palo Alto in that they have other providers operating also in that city? 1:24:05: John Honker: Almost all of them. And, in some cases, they may be smaller. Right? They may be more underserved. But in these cases, they all have competitive providers in the city. 1:24:17: Chair Forssell: That provide broadband as well? At least somewhat? 1:24:20: John Honker: Exactly. It may be a cable company and a D- -- a telephone company. Or, in some cases, just a telephone company, if it's a very small community. But most of these -- When we look at the cities that are providing services, generally, you know, they are 10,000 population, up to 100,000 -- 120,000. 1:24:43: Chair Forssell: But none of them you characterize as sort of having had -- having needed to do fiber-to-the-home in order to provide internet service at all. Like there were other options, and they wanted to improve on the experience for their community. 1:24:59: John Honker: Exactly. Exactly. A good example is in, like, Waverly, Iowa, which is a customer that we helped build out about three -- four years ago now? You know, 10,000 homes and businesses in the city. They had a cable company, MediaCom, and a telephone company. Not happy with the service. Not getting the upgrades that they were promised. And they decided, look, we have our own electric utility. We have some fiber today. We're going to build it. We're going to bond it. We're going to go forward. And today, they serve about -- Well, the network's fully built out. They serve about 42 percent of the community. With service. Or, I should say, 42 percent of the population is taking service from them. ### That is, the take rate is 42 percent. 1:25:48: Chair Forssell: Got it. Thanks. 1:25:50: 123 ### Slide 15 again John Honker: Sure. 1:25:52: ### Slide 16 John Honker: So, when we look at the fiber-to-the-home business case, you know, the goals for us were to help you g - you understand the dynamics around fiber-to-the-home, and, really, what the options would be. So, we tried to answer the following questions. But one: * What were the benefits that the City would achieve with fiber-to-the-home? * What are the market dynamics, and how they impact the business case? * What are the costs and advantages and disadvantages that drive costs? And then, * How can we reduce costs? What are the strategies we can use? * What are the minimum take rates needed to deploy. And that's really important, because, as we look at Palo Alto, not every community -- not every neighborhood costs the same to build out in. Some are very expensive. Some are very inexpensive. * Based on all that information, what are the scenarios that result in a feasible business case? * And, really, what are the variables that have to hold true in those scenarios? So, there -- we've built, really, two -- well, three -- separate financial models for Palo Alto, that your staff has. And that we've gone through a really deep due diligence on variables sensitivities. as -- And options, as we looked at the different ways to build out. And try to find the best possible solutions for the City, that keep the costs down, and also get those services out to the community. 1:27:22: ### Slide 17 So, as we went through this process, think about these as your key options. At the bottom, regardless of what business model you choose, you have the City fiber-to-the-home network. Meaning, the physical fiber plant. And we think that, in almost every case, you're going to have to potentially build that network to get improved service out to the community. Now, based on that fiber, we can pick one of two business models. The City being the ISP. Or the partner being the ISP. And each one of those has a different risk profile. Different tradeoffs, in terms of control. And different costs associated with it. Which we're going to review now. 1:28:07: ### Slide 18 So, the City ISP -- Again, the advantages of that are, really, the City has full control over the network, pricing, ownership, operations, the customer experience, and anything else related to broadband. The benefits -- The advantages that the City has of that are -- you know, the City basically gets a network that's not only utilitized for broadband but for all the other applications that you're building in the backbone for. You have a low cost of capital. And, you know, you can still contract services with key vendors, to lower your costs. Or outsource certain functions of broadband, if the City's not comfortable providing those internally. For example, technical support. Does the City want to provide technical support, as part of its ISP service? Or does it want to outsource that? We work through a number of options to help you understand what those different insourcing and outsourcing models would be. 1:29:11: As we look at the disadvantages for the City, of course, high execution risk and a steep learning curve. Right? It's a new business. It's a new utility. And it's going to take time to learn that. And it's a competitive business. Does the City have a culture of competition and competitive service that it can develop -- it can cultivate -- in this new fiber-to-the-home network? Your overheads also generate higher costs for you, in terms of staffing. And we also identified the fact that, you know, there may be an impact to the debt rating, depending on how you finance the network. So -- 1:29:50: 124 Partner ISP, in contrast, the City doesn't have to provide internet service. It doesn't have any of those competitive forces. Although, by. you know, bringing the partner in, you're basically relinquishing control. You're still spending a significant amount of capital. But you're relinquishing control of the network. To the provider. And that provider better perform. Otherwise, the fees that the provider charges -- Or, the fees that you charge the provider may not get paid. Right. Because, at the end of the day, in the partner model, you're still on the hook for significant capital investment, to built the physical fiber network. And you're going to be looking for lease fees back from the partner for the use of that network. Right? For wholesale use of the network. And that partner has to be capable of competing, and growing this business in a competitive environment, so that you effectively get those lease fees. Right? So they're able to make payments to you, and you're able to make payments on your financing. 1:30:57 So, you know, when we think about these two business cases, it's important to put them in a perspective of risk, reward, and control. And those three factors are very different when we look at the two options. 1:31:13: ### Slide 19 Chair Forssell: I think Commissioner Scharff has a question. And then Commissioner Danaher. 1:31:17: Commissioner Scharff: Yeah. So, I noticed, on your slide of the country -- I though you had like 73 and sixty-something - - 73 did the partner ISP and sixty-something did the city ISP. But it looked like you said that it's a relatively new model ... 1:31:37: ### Slide 14 again ### Slide 15 again This is a relatively new model. Whereas, don't you have those 73 to look at, and see what their exp- -- 71. Or 63. To see what their experience was. ### Again, slide 15 was completely wrong. The map resource from MuniNetworks says that (as of January 2020) there were 63 citywide municipal FTTP networks. Of these, 8 are PPPs and 55 aren't. That doesn't tell you all you need to know in order to know who the ISPs are. Slide 15 reported incorrectly what the "blue" dots on the map were. MuniNetworks says they're less-than-citywide FTTP networks. Of these, 9 are PPPs and 228 aren't. And that doesn't tell you all you need to know in order to know who the ISPs are. I was going to ask you if you could sort of tell us what their experiences have been, and if there have been any disasters. Or if it's mostly been good. Or what it looks like, with a difference. 1:31:59: John Honker: Yeah. No. That's a great question. And, you're right, the partner is a newer model. And it's -- it's -- You know, the track record is relatively short on it. We -- You know, we don't have significant metrics to measure the success of partnerships. If you look at the partnerships that have been created, most of them have been within the last 5 years. Some of them are citywide. Some of them are only part of a city. So, for example, Google and Huntsville, Alabama. Right? Google partnered with Huntsville and is building out there. ### MuniNetworks' map shows Huntsville as a "purple" dot -- just dark fiber. Google has permission to use the dark fiber to deploy FTTP. But, in theory, so do other ISPs. But that's been only 3 years. And, you know, it's going to take a track record of at least 7 years to get good numbers and good understanding of the mechanics of those. So, when -- we always -- You're correct. We look at the city ISP model as being much more established. We see most of the providers that are providing -- Most of the cities that are providing ISP services directly. Generally, they've been doing it a longer amount of time. You know, 7-10 years. Some of them are newer. Like Fort Collins and Loveland, in Colorado, are just launching their service. But the majority of those are pretty time-tested. And we have a full list of them. So, we're happy to provide those, if you guys would like. 125 1:33:18: Commissioner Scharff: Have you looked at other models for our City in terms of where we -- the City provides the ISP but doesn't necessarily run it though the Utilities. I mean, have a separate -- They set up a separate organizational corporation, call it something else, and it hires -- And, you know -- simply outside of the way cities tend to do it. For instance, it might have a 401(k) plan instead of -- You know, it basically hires more like a Comcast, and that kind of thing, as opposed to a City utility, with its higher cost structure. Have there been any hybrid models like that? 1:33:59: John Honker: It -- it -- We didn't create one for that. But that's definitely something that -- to look at. I think the big question -- Because we do have some customers that do it that way. I was mentioning BrightRidge in Tennessee. And they -- You know, they WERE a city utility. They were a Johnson City Electric Authority. Or, I'm sorry, Johnson City Electric Utility. Part of the city of Johnson City. And they became their own authority so they could be more autonomous, and also have different corporate and capital structure than the city. And it's helped them in some ways. They still have a lot of regulations that require them to, you know, have the overheads and the pensions and everything else that drives the costs up for them. But, in some ways, they've been able to reduce costs as well. So, I think that's something to look at. I guess my question would be, how -- in what sort of governance framework we should do that. What would the structure look like? Would it be an authority, or a non-profit, or -- Are questions. Because we do get that question a lot. And it always comes down to sort of a governance issue of how -- If the City is investing -- let's say tax dollars -- how do you keep the governance under control? And what does the governance structure look like? That's been some of the challenges we've faced with those. 1:35:24: Commissioner Scharff: You know -- And I think some of the other utilities in some of our neighboring cities have slightly different governance structures. You know, where they have their -- basically, their own Utilities Board, that runs their utilities. As opposed to, say, the City Council. And I'm not necessarily proposing any of these. I just think there are models out there that you could look at. I mean, I think there's a whole bunch. There's joint power authorities that you could create. That have -- And some of those don't have --aren't in PERS, and don't have the same cost structures. Other ones do. And I'm not advocating any of this. I'm just thinking -- That seems more of a -- There seems more advantages along that route. Whereas, I see very little advantages, off the top, of partnering [with an] ISP, frankly. 1:36:09: John Honker: Yeah. 1:36:09: Commissioner Scharff: I mean, your argument -- and I'm sorry if I've put words in your mouth. But the argument that I'm getting is that the reason you might want to partner is that the City is not used to customer service. Whereas, I think Palo Alto actually does extremely well at its customer service. And when you say "a competitive environment" -- you're not used to being competitive -- I'm not sure what you mean by that. 1:36:29: John Honker: Well, I think what -- In terms of the competitive environment, the City -- to provide ISP services -- you know, you have to have sales and marketing. You have to have market intel. You have to be able to flex your pricing structure quickly. And make market changes -- make pricing changes -- make package changes -- dynamically, as the market changes. As your competitors change. And that whole culture is different from typically what cities do. Now, you would HIRE for that. Right? So -- 1:37:11: Commissioner Scharff: That's what I was thinking. You'd hire for that. That's why I was asking about a separate organization. 'Cause it seems that you'd hire someone who's had those experiences -- who did that. 1:37:17: John Honker: Right. 126 1:37:17: Commissioner Scharff: But maybe you could do it WITHIN the utilities. I mean, I don't know. 1:37:21: John Honker: Yeah. I think you would. I think where we do find some challenges -- and we're really sort of just providing the education on these different models. We always look at this in a lens of, you know, the City could partner. Or the City could move into a retail play. We always think that the retail option -- given the City's -- the way that they -- the goals that they're trying to achieve are more easily achieved in the city model -- the city-as-an-ISP model -- than in the partnership model. Right? Because the partnerhip model. Because the partner becomes a variable that's difficult to control. And, we're -- also, when we bring the partner in, we're injecting private-sector returns into the economics of the network. Right? So, now we have to account for what was a non-profit, effectively -- or a zero-profit business. Now we have to account for a private rate of return. Which can throw a number of different dynamics into the economics of providing service. Right? Higher costs. Higher rates. Less competitiveness. There's -- You know, one of the motivations of the partner. So, there's a lot of dynamics at work. So, there's pros and cons to each of these. We think that the city-ISP model makes a lot of sense, if you can overcome some of those hurdles of the steeper learning curve and the competitive environment. But, you know, we want to highlight both. 1:39:01: Commissioner Scharff: So, one of the things we've been asked to do tonight is to give direction that staff would like to explore public-private partnership opportunities, and models for fiber-to-the-home. I fear that, while it's easy to say, yes, we should explore that, what exploring that does is come with a cost. At least, in the last 10 years I've followed fiber-to- the-premises, every time we try to go out and do some sort of a, you know, public-private partnership, either people don't bid or it falls apart. And if you read the staff report, it sort of goes through the history of that. And, you know, it's -- the more you explore that, it seems, the more there is opportunity for delay. And so, I guess the question is, while it's easy to say we should explore it, I'm just really looking for your feedback a little bit on whether it's -- that there are cons to explore, it seems. And whether or not it wouldn't make more sense to put those staff resources into how we would actually have the city-ISP. Or whether or not you think it really is worth exploring. I mean, the one example you gave was Google, who is, you know, headquartered down here in Mountain View. But they seem to be out of that business. So, I don't think they would be the one partnering with us on that. And so, I guess you'd find some smaller ISP who would like to get in the business, and have a good fi- -- I'm just really wondering if it's worth exploring those partnerships. Or if we should just make that decision. Or how to solve the problems, and what that looks like, if we just went with the city-ISP. 1:40:38: John Honker: I mean, those -- They're tricky. The partnerships are tricky, you know, because, you know, there's almost no "sweet spot." Right? There's either a big provider, that's going to come in and dominate -- And, in those cases, there's very few of those big providers who want to do it, because they have the capital to do it. And if they want to come into town, they'll do it themselves. And they'll overbuild. Because they want to keep control of everything. Then there's the small providers, who aren't capitalized well. Meaning they can't afford to build out in Palo Alto. So, they're basically banking on the City's credit rating. Right? To finance the network, so they can grow their business. And that's not great for the City either, because then, you know, you have a small company, that's sort of in the process of growing, and you have all the growing pains along with that, in terms of, you know, bringing people into market, to setting up a sales office, - - You know, there's just a lot of things that they may not be able to do, because they're not well capitalized. So, you know, it's hard to find a sweet spot for a mid-sized provider, who's -- one not already doing fiber-to-the-home, that -- or, that's not doing it themselves -- that wants to potentially partner with the City. So, it's -- I kind of share your grief with the partnership options. And It is a challenge. I think it's question of whether the City wants to see what's out there. But will any of these partnership options fulfill the City's goals? That's -- That's really a big unknown. 1:42:14: Commissioner Scharff: Hmm. And I think my concern is how long it takes. And whether or not that ends up delaying things, and, frankly, killing it. Because it takes forever to get it done. Because we're continuing to look for partners, as opposed to -- OK, if we're going to do a city-ISP, what does that take, what does that look like. And what delves into the details, and what's the structure we need that makes the most sense. Which seems complicated in itself, frankly, to me. I mean, there are a lot of issues. Thanks. 1:42:46: 127 Chair Forssell: We've got a lot of hands up. I think Commissioner Danaher was next. Then Commissioner Johnston. Then Jackson, and Smith. 1:42:53: Commissioner Danaher: Thanks to -- the excellent questions of Commissioner Scharff, I can be brief. I view these not as alternatives but as more of a sliding scale. Depending on how much you contact out. ### I think outsourcing -- "contracting out" -- is completely different from partnering. And I thought it would be helpful to emphasize that more. And maybe in the next report, break down the different functions that would have to be performed. And which of those could be done by vendors -- would not be done by the City. So we had a more granular view of the opportunities for how that can be operated. And I just don't feel, without that, educated enough to really think about it intelligently. 1:43:32: And then, I had one other question. You don't have to address now. But maybe if you can address when you get into costs and the like. And this is really -- It's a naive or elementary question. Which is: I don't have an understanding yet of -- When you connect homes to this, is it just the people that sign up, and you charge them at the time, or you bear the cost? Or is there a model of where you go in and do the whole neighborhood? And is it more cost-effective to do that? And pay for it with bonds? Or -- with on-bill charging over time? And how's our right to partner, versus the City's? So, I don't understand how that process would go, and what the alternatives are on that. But it does affect costs. And it affects budget, and the like. And so, when you get to the right part of that, if you could explain the alternatives, and educate me. As I said, I have a naive understanding about how that's done right now. Thank you. 1:44:28: John Honker: Sure. No. Happy to do that. And I think we'll go through that in the next couple of slides, as we get into the costs. So, I'll kind of explain the -- you know, the build-out. And how customers are connected to the network -- how residences and businesses are connected. 1:44:47: Chair Forssell: Commissioner Johnston. 1:44:49: Commissioner Johnston: Thank you. I guess I'm trying to understand what it means, as a practical matter, if the City is an ISP. What kind of services, in addition to just connecting people to the network, what kind of service would the City have to provide in order to attract enough subscribers to make the -- to make the whole thing work? I mean, do we have to provide 500 channels of television, and streaming services, and so on? What -- How does this work? 1:45:26: John Honker: Sure. Sure. That's a great question. So, predominantly, when we think about the City as an ISP, the key service is providing internet. Right? Providing high-speed internet service. But, depending on the competitive environment, you MAY want to offer other services. So, you know, we think about, the -- You know, Internet is a must. Right? Because that's what most people are interested in. But there may be an opportunity to provide TV and/or home phone service. Also, business services. So, you're going to provide business services. And then, optionally, you can provide business telephone services. Which are actually very profitable, and are always in high demand for businesses. So, it's really a portfolio of services, depending on what the market wants. Now, when we think about Palo Alto, one of the things that's really important, when you decide what services you want to provide, is whether you provide TV or not. And, you know, in high-tech places like Palo Alto, generally, you're going to have a high rate of cord- cutting. Meaning that very few people still subscribe to cable. Linear TV. This is -- We'll be able to find this out in the surveys. 'Cause this is some of the questions that we ask. Is, you know, 1) do you currently subscribe to linear TV -- or cable TV -- from your provider? And, if you do, do you have plans 1) to either cut the cord in the next 3 years? Are you cutting the cord now? Or are you going to keep your linear TV? Because that will give us a market share of how many customers still want to have TV service. And how many are cord-cutting. Because the cord-cutters aren't going to buy TV. They hate traditional cable. They don't want it. - 128 ### The question I'd want answered is how many people won't subscribe to City internet service unless they can also subscribe to traditional TV from the City? But I'm not sure how this question should be asked. And they're only going to buy internet from you. They're also not going to buy home phone. So, the question of whether TV or not is an important one, because the requirements to provide TV service are pretty onerous. And if there isn't a large enough market share of customers -- citizens in Palo Alto -- ### I don't think Palo Alto wants to insist that all of its customers be citizens. that subscribe to it, you probably don't want to provide it. Now, if there is, what we really have to be concerned about then is, an equivalent product. Right? If we have the two competitors that are out there today, that both have TV, and Palo Alto doesn't have it, how much market share will we lose because those customers don't want to switch and have two providers? You know, two bills, two separate providers, two separate services. We will lose some market share based on that. The question is how much. The survey will help us understand how much market share is still in Palo Alto in terms of cable TV. And then we can make a good judgment call of whether it's enough to need to provide TV services or not. ### In 2013, Longmont, CO, decided to move forward with citywide municipal FTTP without a TV service. https://muninetworks.org/content/longmont-city-council-approves-fiber-network 1:48:22 Home phone service is the other. Right? There's -- Generally, home phone service in the U.S. is down to about 27 percent. So, again, through the survey, you'll be able to understand whether home phone service would be a valuable service to provide or not. Chances are, it's marginally valuable to the community. But it may be more valuable to businesses. So, if you're going into a new -- a business in Palo Alto, and selling the service, you know, they're going to be looking for internet AND, potentially, business phone service. Which, you know, may be 20 phones for a business office. Plus a voicemail. Plus caller ID. Plus all the other features that come along with it. So, it's really a question of what services you're going to want to provide, that are complementary to internet. And then, how you'll support those services with your customer -- with your network operations, and your staff. 1:49:23: Commissioner Johnston: So, am I -- Sorry. Am I right in thinking that your having those answers, based on the survey - - is -- would be important for us to make the decision of whether the City should be an ISP or whether it should partner with someone? 1:49:33: John Honker: I don't think that that decision -- I don't think the results of the City ### survey (not City) will change your decision on whether to provide services directly or partner. Because -- although it is more difficult to provide TV and phone, it's not -- we don't think that that would be a game-changer, where the City would want to move to a partnership instead. Meaning that to manage those services, for residents and businesses, there's an incremental lift, in terms of the staff that you need. And the systems. But we don't feel that it would be enough to sway your decision of whether to provide services directly or partner. 1:50:34: Commissioner Johnston: OK. Thank you. 1:58:37: John Honker: Absolutely. It was a great question. 1:50:40: Chair Forssell: Commissioner Jackson. 129 1:50:43: Commissioner Jackson: Yes. Thank you. So, I guess, my model -- to look at this slide that we're showing right now -- ### That is, slide 15 in the city-as-ISP model, there's -- although it really hasn't been articulated clearly yet, or detailed, there's sort of two separate models within city-as-ISP. One is, like, the City employees -- or Utility employees -- do everything. And then there's another one, which is actually what's outlined in this report -- or the presentation -- is, City -- Utility employees do a lot of it, and then, on a selective, opportunistic basis, certain departments, or key functions, are outsourced by that Utility as city-ISP. So, I think those are both very fine models. I think that the third thing, that I hadn't thought of before -- and this relates to something that Commissioner Scharff brought up -- is, maybe there's a way of structuring that business not as a utility but as some other legal entity, under -- you know, that's interesting. I don't have any input on that. 1:51:49: So, great. And then, I think -- So, at the top level, it's really city-as-ISP or partner-as-ISP. And this gets back to another question, as Commissioner Scharff said. To me, you could decide -- the City -- you know, the Council could decide - - We're mainly interested in city-as-ISP. And if that's your direction, there's no need to go explore partners. If you can make -- if you can make that call -- the earlier you can make that call -- you don't have to go look for partners. ### Absolutely. So, we're going to get to this after more of the presentation, when we get into the recommendations. But I agree with you that you cannot make -- you can just -- if you decide to go with city-as-ISP, you can decide there's not need to go look or a partner. 1:52:33: John Honker: And, I think, Commissioner Jackson, you know, what you mentioned, the outsourcing model is, you know - - Most cities get scared about some of the competitive -- and, you know, the technical -- and, you know, how are we going to do all of this internally? We've got to hire a million people. You know, you can offload that. Right? To contractors. And a lot of cities do that. They'll offload it to a contractor that's in the business of doing that. So, maybe they're just providing technical support as a crutch to help the City with some of those key functions, where it just doesn't make sense for the City to do it directly. So, I almost look at it -- I almost think about the city-ISP model as having a blend of, you know, City staff doing certain functions and key contractors that are doing other functions. Right? In a fee- for-service model. OK? 1:53:22: Chair Forssell: Commissioner Smith. 1:53:24: Commissioner Smith: Um. Yeah. Just a couple of points. One, I'm a little conscientious of time. ### Slide 16 again, slide 17 again, slide 18 again, slide 19 again. We're approaching 8:00, and we're halfway in. And what I really want to see is this next portion of the presentation. ### Slide 20 Because I think it's going to clarify a lot of the questions. Secondly, I want to echo what Commissioner Scharff called out - - and, I think, accurately. Why are we exploring a public-private partnership when, as you will see, the numbers just aren't going to -- they're not going to support that. And then, finally, just to edit -- just to add to Don Jackson's -- Commissioner Jackson's actions -- comments -- Slide 44 does actually provide a detailed view of what could be outsourced. I think that is absolutely logical. And I think the City should pursue something of that nature. Thank you. 1:54:19 John Honker: So, let me move ahead a little bit. 130 ### Slide 22 (skipping slides 19, 20, and 21) 1:54:24: Chair Forssell: Actually, I'm also conscious of time. But I -- Also, we usually take a break somewhere around the halfway point, 'cause three hours is a long time to sit and stare at the screen. And we're over the halfway point. I'd like to propose a short recess. And then we'll come back and take it from here. So, it's 7:56 by my clock. How about we all come back at 8:05. Refreshed and ready to finish out the discussion. 1:55:02: John Honker: We'll dive right into the numbers then. That's perfect. 1:55:05: Chair Forssell: All right. Thanks. 1:55:06: Commissioner Danaher: Yup. 1:55:07: Commissioner Smith: Thank you. ################################################ BREAK ################################################ 2:04:49: Chair Forssell: Commissioners, if you don't mind turning your video back on, so we can tell if you're back. There we go. All right. I think we're good to go. Carry on, Mr. Honker. 2:05:05: John Honker: OK. Thanks, Commissioner Segal. ### Chair Forssell (not Vice Chair Segal.) Um. So, really, I thought it would be important for us to jump directly into financials, because they kind of explain a lot around the two different models. Then I'll talk through that, while we're going through this. So, really what this slide is showing is the analysis of two financial models that we created for the City: 1) the city-ISP, and 2) the partner-ISP. Take rates are a little different. Again, using a VERY conservative take rate: 32 percent of residential and business customers in the City. So, 32 percent of citizens and businesses would take service from the City. ### Again, "citizen" is not a synonym for "resident." Again, very conservative. That is, you know, 10 -- about 10 percent lower than the average. But we wanted to be conservative as we looked at what the City could potentially receive under sort of base-case scenarios. We think partner- ISP take rates could be higher if you get the right partner. So, we modeled that at 43 percent. But, you'll see, we also have sensitivity analysis built into these. So, we can look at the -- you know, the up side and the down side of each one of the models. ### Why is the assumed partner-ISP take rate so much higher than the assumed city-ISP take rate? 2:06:17: 131 So, this first slide looks at capital expenditures. As we look at the two models, capital expenditures for the fiber feeder, or distribution network, are the same. The feeder or distribution network is basically the equivalent of your electric service plant. Right? All the distribution -- all the electric lines that run throughout the City -- you'll effectively have equivalent fiber lines ### To torture the analogy, maybe the the 4kV-and-up electric lines are more like the fiber backbone. that carry the internet service throughout the City. ### The fiber distribution network also potentially carries other FTTP services -- and, potentially, even dark fiber -- not just internet service. ### The fiber distribution network "passes" all premises in the City. So, in both models, we see that those would be the same. Because, again, the city-as-an-ISP has to build the network. And, if a partner's coming in, chances -- In almost every case where there's a partnership, the City is still required to build the network. So, we look at those as both equivalents in costs. We did find that, with the new fiber backbone, there's about $4.5 million of savings that the City is recouping in building fiber-to-the-home. So, that original $22 [million] to $28 million backbone is actually netting the City about $4.5 million -- less -- in less -- in lower fiber-to-the- home costs. In the build-out. ### If the backbone network didn't have to support anything other than FTTP, how inexpensive could it be? How many nodes would it have? Why isn't the City's existing dark fiber network sufficient for that? ### And if the proposed FTTP distribution network had to support not only FTTP but also AMI, SCADA, and all the other things that the proposed all-singing-all-dancing backbone network would support, how much extra would that cost? 2:07:29: So, our revised fiber distribution costs are $65 million. Our fiber drop costs are $9 million for ISP -- city-as-the-ISP -- and $12 million for the partner-ISP. And fiber drops are effectively from the fiber line from the street to actually connect the home to the network. And those are variable capital costs that will change depending on how many customers are connected. So, you see that, in the city-ISP, where we're at 32 percent, we're at $9 million in capital required. But because our take rate's higher on the partner-ISP, you're at $12 million. Right? More fiber drops because more customers are connected. And I think this gets back to the commissioner's question about how we would build the plants to pass homes. Right? When do you actually connect homes? So, think about it like your electric plant. Meaning, you have to build the distribution network first. Right? That goes throughout the City. All the neighborhoods. All the business districts. You have to build that up-front, so service is AVAILABLE to customers who want it. But the service drops -- or fiber drops -- don't -- aren't built until a customer signs up for service. So, in these cases, you won't build fiber drops to every customer. Only those who sign up for service. That way, you control those costs to some degree. And you're building them on demand. In addition for the fiber -- So, those two costs become your fiber plant costs. All of your outside plant infrastructure. 2:09:07: Data center and headend costs. ### The term "headend" is TV-centric and out-of-date. I guess the consultant is talking about the switches in huts and the switches in the central office. So, in the city-ISP model, there's about $7 million of data center costs. They're lower in the [partner]-ISP model because the partner is taking care of a lot of that. And has those facilities already. The other cost categories are home equipment and installation. So, effectively, all of the equipment needed inside the customer's home to provide service. And equipment needed to power businesses and connect businesses. In the city-ISP model, of course, you own that equipment. You're providing it to customers. And you're renting it to them. So, you can charge between $5 to $9 per month for the rental of the equipment that's in the home. In the business- -- in the partner model, there's really none of that, because in those cases, the partner is taking care of the equipment inside the home. Right? As the ISP. ### It's not true of all FTTP networks that the "ISP" provides of the electronics. In "open access" networks (UTOPIA, Ammon, etc.) the municipality provides the electronics -- and wholesale packet-moving services -- and ISPs provide the retail services. 132 So, the difference between the two models is really about $5 million in capital. It's not substantial. And that $5 million is in lower costs of data center and headend equipment and in the home installation and business installation. 2:10:24: ### Slide 23 So, relatively equivalent costs on CapEx. If we look at funding for the two different models -- We worked with your staff to identify, you know, potential ways that this could be funded, with the goal of kind of bringing down the City's bonding requirements. ### To begin at the beginning, why is this a good idea? Could we -- Could we fund this -- you know, with existing funds that are out there today? So, we look at, again, the $85 million [city-ISP] and the $80 million [partner-ISP] for the capital expeditures. We also need to work -- set aside some working capital for start-up costs. Right? So, you know, in any business, you don't make money from day one. Right? You're going to lose money for the first few years. And, because those expenses are higher than revenues, as you're building the network and growing, you're going to need to finance those some way. So, in the city-[ISP] model, we're looking about about $12.5 million in working capital needs. And that's much lower in the partner-[ISP] model. Where you're not operating. The partner is operating. It's about $6 million. So, overall, total funding required for the city-ISP is about $98 million. And in -- $86 million for the partner-[ISP]. 2:11:17: When we looked at ways to potentially fund this -- to bring bonding requirements down -- there were, really, a couple of different funds that could be utilized: 1) the balance of the fiber fund for fiber-to-the-home expansion. ### The presentation hasn't talked about what the "balance" of the Fiber Fund is. So, the intent was to use the Fiber Fund for the bac- -- the initial backbone. ### Ah. That strikes me as a bad idea But then also have the departments and the electric contribute to the fiber backbone, to fund their piece of the network, effectively, that's being built. So, if we did that, we would be left with $17.5 million in the Fiber Fund. And then, there's also a $15 million electric projects -- special projects reserve -- that's out there today, that could be used to fund a portion of this. And that gives us a total of $65 million -- Well, I'm sorry, at total of $32.5 million in existing funds, that could be used for fiber-to-the-home, bringing down the bonding requirements. So, at the end of the day, the bonding requirements for, you know, the city-[ISP] model: about $66 million. And about $54 million for the partnership-[ISP]. 2:12:49: Commissioner Jackson: I have a question. 2:12:50: John Honker: Sure. 2:12:50: Commissioner Jackson: And it's not really for you, Mr. Honker. I think it's more to Council Member Filseth or Director Batchelor. So, on this loan from the Electric Special Projects Reserve for $15 million -- Is that like that's totally no problems? That's totally within all legal -- No one's going to sue us because we tried do that? I mean, you know, nobody -- you know, you can never say never. But, that -- Is that $15 million loan -- is that like totally rock-solid? As a possibility? 2:13:33: Council Member Filseth: I couldn't tell you offhand. 133 2:13:35: Dean Batchelor: So, Commissioner Jackson. So, we did check with our legal. And since that money is for -- been in there for electric projects reserves, that -- we were told that we would be able to take that as a loan. And then pay that back during this period of time. ### What period of time? So, yes. The answer is yes -- that we've checked into it, and legal says it's fine. ### At some point, should the City produce a document that says so? 2:14:01: Commissioner Jackson: Great. Thank you. 2:14:05: Chair Forssell: And, just to be clear, it's a loan. So it would -- over time, it would be paid back to the Electric Special Projects Reserve. Is that right? 2:14:12: Dean Batchelor: That is correct. Yes. ### Where would the money to pay back the Electric Special Projects Reserve loan come from? What would the interest rate be? ### Did anyone ask the question of whether money in the Electric Special Projects Reserve could be used to FUND a part of the backbone? That is, could it be used to PAY for part of the backbone, rather than just as a loan? After all, one of the functions of the backbone, as proposed, would be of use only to the electric utility. A 144-strand cable within the backbone, as proposed, would be dedicated to electric. I'm not saying that the backbone, as proposed, is a good idea, because I think it isn't. ### Did anyone ask the question of whether money in the Electric Special Projects Reserve could be used to FUND a part of the FTTP network, instead of the backbone, if the FTTP network could be used to provide the SCADA capabilities the electric utility needs? 2:14:21: John Honker: OK? 2:14:22: ### Slide 24 So, we also wanted to look at not only those funding sources but also the commercial dark fiber business. Right? Because this -- you know, I think the way we've discussed it with staff is, it could be a potentially expansion of the existing dark fiber business. Right? Because dark fiber -- the business right now, you know, highly profitable. This is what the revenue expectations would be like -- would look like over the next 20 years, if the dark fiber grew at 2 percent a year. So, this -- We were talking about this tonight -- as the -- you know, how much could the dark fiber business with the new backbone. Right? So, these are those conservative numbers. It's really, right now, throwing off $2 million a year. Which -- This grows cumulatively, year by year. And that -- Those balances could help support the fiber-to-the-home deployment by adding additional cash. The goal of this would be to really bring the two businesses together, so that you've got that funding. And that gives you an opportunity to reduce ongoing costs and ongoing working capital. 2:15:30: Commissioner Scharff: Wait a minute. You said that's 2 percent a year. How's that possible? It goes from [$]2 [million] to [$]4 [million]. That's 100 percent. And [$]4 [million] to [$]6 [million] is another 50 [percent]. 134 2:15:39: John Honker: Yeah. This is a cumulative graph. So, the net revenues in the first year are [$]2 [million]. Net revenues in the second year -- So, there's a -- Because the revenues from the dark fiber business haven't been spent. They've been accumulating, year by year. Which -- Right now, you guys have like a $30 million Fiber Fund reserve. This is just showing what that reserve -- the new reserves -- would grow to, in time, just from dark fiber. Right? So, this year, it will generate $2 million. Next year, if you hold onto that cash, you'll have $4 million. The next year, $6.1 [million]. The next year, $8.2 [million]. And so on, and so forth. So, this just gives you a cash balance at the end of each year. 2:16:20: Commissioner Scharff: OK. 2:16:21: Council Member Filseth: So, it's really a fund balance, not revenues. 2:16:23: Commissioner Scharff: Yes. Correct. 2:16:24: John Honker: Fund balance. Exactly. 2:16:29: ### Slide 25 John Honker: This is what the net revenues balance. Again, think about this as a fund balance for the fiber-to-the-home business. And this is the city-ISP. You know, starting in Year 1, we have a cash balance of $8.2 million. Which is going to drop over time. Right? So, we have have these negatives. This is typical, because we have some cash in the first years. But as we start to operate -- build the network and operate -- your operating expenses, you know, are highest as we start getting into Years 3, 4, and 5. So, we have a deficit in these years that we have to make up, with revenues from elsewhere, effectively. So, the proposition is that, you know, as we grow the fiber-to-the-home business, it IS going to be profitable over time. Right? It's going to -- Fund balance is going to grow, to, potentially, $38 million, over 20 years. Under that same conservative estimate of 32 percent take rate. But we still have to kind of consider these deficits, and how we're going to pay for them. 2:17:28: ### Slide 26 So, if we look at the -- 2:18:31: ### Slide 27 If we look at combining these fund balances, we bring in the fiber -- the existing dark fiber business AND the fiber-to-the- home business, you know, the dark fiber business helps subsidize the fiber-to-the-home business in the years where there's a deficit. And you can see that the net fund balance at the end of each year stays positive. So, you know, instead of getting those negatives in those years, we still have a positive cash balance of $2 million. For example, in Year 3, $1 million in Year 4, and $3 million in Year 5. After we get through that period, then our cash balances start to grow considerably over time. So, you know, the dark fiber business -- bringing that together -- helps cushion some of the deficits in the fiber-to-the-home business, and lets you be able to, you know, potentially, borrow less. Because we don't need to fund that externally. 2:18:27: 135 Chair Forssell: Quick question. How do you figure on $8.2 million of net revenues in Year 1, for the fiber-to-the-home business? 2:18:34: ### Slide 26 again John Honker: Sure. So, this -- This is, again, a fund balance. So, think about this -- Yeah. And I should have -- We should rename that to -- we're looking for the right term. But consider this the fund balance. So, there's a fund balance of $8.2 [million], because some of that working capital hasn't been spent. It's still sitting in the bank. Remember, we talked about a $12.5 million in working capital required to ... 2:18:58: Chair Forssell: So, that's the working capital ... 2:19:00: John Honker: That's the balance ... 2:19:00: Chair Forssell: ... balance. 2:19:01: John Honker: Exactly. 2:19:02: Chair Forssell: Got it. 2:19:04: John Honker: And that will then pick up -- And these deficits would effectively picked up by the fiber business -- Or, the dark fiber business. 2:19:11: ### Slide 27 again 2:19:12: Chair Forssell: So, a different way to think about it would be, you actually need more working capital if you don't want to go negative. ### Great point. 2:19:19: John Honker: Right. 2:19:20: Chair Forssell: Twelve point -- $12 million being a somewhat arbitrary number. And if you didn't want -- If you didn't have the cushion from the -- from the business fiber, ### It would be better to say "dark fiber," because FTTP will also have business customers. then you would need ... 136 2:19:32: John Honker: You would need to, basically ... 2:19:34: Chair Forssell: ... you'd need $20 million -- or something of -- 2:19:36: John Honker: Another $3.6 [million] -- plus interest. 2:19:39: Chair Forssell: Ah! OK. Right. Because it's cumulative. Yup. 2:19:43: John Honker: Right. So, we would say, you know, [$]12.5 [million] -- you know, [$]16 [miliion] -- We would say [$]16 million if we didn't want to use the Fiber Fund to subsidize the fiber-to-the-home fund. ### Honker is confusing two different things: 1) using what's in the Fiber Fund, and 2) counting on ongoing dark fiber net revenues to keep adding to the Fiber Fund. 2:19:54: Chair Forssell: A useful graph might be to just show the annual operating -- how big of a deficit it is in Year 1, 2, 3. And -- to see the inflection point, where it turns profitable. 2:20:08: John Honker: Sure. We can do that. I mean, a more traditional pro-forma. 2:20:14: Chair Forssell: Um hum. 2:20:15: ### Slide 26 again John Honker: OK. I think it's also important to point out the differences here between the partnership[-ISP] and the city- ISP. So, again, we're going to look at both of these. The partnership[-ISP] model, in terms of the fund balance. Versus the city-ISP, in terms of the fund balance. 2:20:34: ### Slide 25 again So, remember, we looked at this graph. Right? So, we have our deficits in the early years. And then we grow, year after year, about $3 million a year in net revenues. That grows the fund balance up to about $38.7 million at the end of 20 years. If we look at the partnership[-ISP] model, ### Slide 26 again you know, again, with the City investing a similar amount of capital -- $5 million less -- our net fund balance at the end of 20 years is only $15 million. We still have the need for some additional working capital there. So, we really need $8.5 million in working capital for the partnership[-ISP] model. And it doesn't create nearly the return that the city-ISP model does. So, the net defic- -- The difference is the $5 million capital investment. Right? The partnership[-ISP] model is a $5 million LOWER capital investment. But if you look at the net return to the City -- $38.7 million versus $15 million. You know, a much larger magnitude. So, really, we look at the partnership[-ISP] model as being very -- you know, much less 137 profitable for the City. Although profit's not important, you know, what's happening is, effectively -- The private-sector return that's REQUIRED in the partnership model is sucking that additional cash out of the balances. Right? Meaning that, in this case, with the partnership, the City is charging the partner a wholesale fee to use the network. And that wholesale fee can only be so high. Because the partner still has to make its required return, and pay its own operating expenses. And when we put those two numbers together, you know, the delta on the cash balance back to the City is significantly lower than in the city-ISP model. So, I think that's really important for you guys to think about. Is, you know, because that private-sector return is in there, it's going to limit the City's ability to 1) charge a rate to the provider for wholesale. Meaning, there's going to be a ceiling on that. Because that ceiling that the City charges -- Or, that rate that the City charges the provider has to be still market-friendly. Meaning, that charge becomes an operating cost to the provider. They still have to make their required return, pay their operating expenses, and deliver service to the market at a market-friendly rate, or they're not going to be competitive. So, they get squeezed to some degree. But the City also gets squeezed, because it can't -- it can't charge a higher rate, and potentially recoup some of the difference between the partnership model and the city-ISP model. So, you know, nine times out of ten, we always see this being the case. There's a lower cash flow back to the city, because that partner is effectively having to meet its required return. 2:23:37: ### Slide 25 again In the city[-ISP] model, you're effectively just paying your debt service. And there is no private return on that. There is no required return. There is no IRR. ### Internal Rate of Return. So, those cash balances grow, year after year. It's a big difference. Right? We're looking at $38 [million] -- almost $39 million -- versus $15 million. We're looking at about a $20 million difference between the two. $25 million difference between the two. So, I think that's important to think about, as you're considering the two models. It's a big difference in what this nets out to the City. 2:24:18: ### Slide 28 And here's that same graph if we looked at the partnership model, and we used the Fiber Fund to, potentially, subsidize the early years. So, the Fiber Fund, again, grows at the same rate. But, you know, we still are, you know, much lower in cash flow. So, our cash balances in the city-ISP model are $71 million at the end of 20 years. And in the partnership model, they're $47 million at the end of the 20 years. The Fiber Fund stays the same. The same amount of cash flow coming back to the City. But the fiber-to-the-home business is just much -- creating much less cash for the City than the retail business would. 2:25:03: ### Slide 29 So, as we start to think about the differences in risk, between the two models, I think this is the good framework to use, to think about what could change the financial outcomes of retail-ISP versus partnership. So, when we look at retail prices - - Fluctuation in the retail price definitely has an impact on the City's overall financial feasibility of the project. Right? Now, we don't expect finan- -- prices to move considerably. Because when you look at the competitors, they're very, very inelastic, in terms of changing their prices in the local markets. Because those have tendencies to change prices in larger markets. So, for example, the cable company and a telephone company both operate in your neighboring communities, and throughout the Bay Area. Changing -- Lowering prices in Palo Alto forces a price-lowering impact in other communities that's very similar. So, they're going to be very, very hesitant to lower prices considerably. But they may use promotions to do that. Take rates are really -- are a very sensitive variable. So, as we look at the take rates for city-ISP versus partnership-ISP, fluctuations in those definitely have impact in cash, and overall sustainability. 2:26:37: So, the goal is, you know, how do you mitigate that risk. Right? You utilize -- You hire the right staff. You outsource functions that can be outsourced, to improve service quality. You enhance your sales and marketing opportunities, wherever possible, to increase your penetration. And you deliver great customer experiences. Right? That's what we 138 see most of our customers -- most of our clients doing, in terms of improving their take rates. Operating costs are also a factor, that are -- it's a sensitive variable, as we look at overall financial sustainability. And then, finally, construction costs. And we talked a lot about construction costs tonight. And changes in construction costs impact to the overall project. 2:27:26: ### Slide 30 So, as we look as these -- These are just a few sensitivity analysis graphs. And we're doing this just for the city-ISP version. ### Good. So, for example, this graph will show you an impact on the final cash balances -- or the fund balances -- at different take rates. So, at 24 percent, which we found is the break-even, the cash balance, almost every year, is zero. ### Compare this with the City's 09-28-15 staff report on FTTP, which claimed that breaking even would require a take rate of 72 percent, if the Fiber Fund didn't "subsidize" the effort, or 57 percent if the Fiber Fund provided a "subsidy" of $20 million. And there's a deficit of about $5 million, that would have to be covered by another fund or working capital. Now, that could be covered by the Fiber Fund. Or it could be covered by another loan. Or something similar. So, think about when we're considering the city[-ISP] model. you need to get to at least 24 percent to break even. But as we start to go up, at 30 percent, you can see we're cash flow positive. At 35 percent, you know, more cash flow positive. Our cash balances are up around $53 million at the end of 20 years. And then, at 40 and 45 [percent], you can see we are considerably higher. So, you know, break-even -- down, showing on the yellow line -- and that our cash balances are higher on these additional take rates. 2:28:41: Most utilities land around 40 percent. Somewhere between 40 and 45 [percent]. So, you can see, at those numbers, your cash -- let's say at the end of Year 10. And the fund balance at 45 percent is $34 million. And, at 40 percent, it's $25 million. ### The slide doesn't explain the color codes for the take rates. But they are: 25 percent is orange, 30 percent is yellow, 35 percent is light blue, 40 percent is green, and 45 percent is dark blue. So, it's actually generating pretty significant cash for the utility. 2:29:08: ### Slide 31 If we look at construction costs -- You know, if construction are 20 percent lower, you can see what it does to our fund balances. Right? Significantly improved cash flow. If they're 20 percent higher, they're still positive. But we have a bit more of a deficit in the early years. So, we used $100, again, for the underground rate. Average of $100. So, this would -- 20 percent higher would be $120 a foot for construction; 20 percent lower would be $80 a foot for construction. We think you're going to land right in that $100 mark. So, you know, your cash flow graph is going to be very similar to what we showed you in the prior slide. 1:29:51: ### Slide 32 So, as we look at the two business models, again, I think, to sum it up, I think it's really a decision of whether the City is -- is most interested and well-positioned to move into city-ISP services. And, if not, the partner-ISP services. I mean, if we look at the difference in the funding, it's not significant. But if we look at the difference in the value, I think that it creates, for the community and for -- just in terms of financial return for the City -- the city-ISP makes a lot more sense. And, again, as you look at this, you have a lot more control over the network. You have a lot more control over the customer experience. And as we said -- I mean, the partnership models are still in development. Right? So, there's no 139 benchmarks. It's challenging to find comps out there, that we could go and say, hey, here's a partnership that's working today. And it's achieved the City's goals -- you know, over the past 7 years. So, those are kind of the considerations we wanted to bring up as we look at these two models. You know, I'd love to hear some thoughts from the team, based on some of those high-level numbers. If you guys would like to chime in anything. ### Who is the "team" in this case? UAC? 2:31:12: Chair Forssell: So, this -- that concludes your prepared presentation? Is that safe to say? 2:31:17: ### Slide 33 John Honker: We have one other model that we looked at, that really reduces the City borrowing. That -- I'm not sure what -- how everyone feels about the time. Are we still good for another maybe 5 minutes to walk through this one? 2:31:32: ### Slide 32 again (for no good reason) Chair Forssell: Let's see. Commissioner Scharff had a question. So, maybe we'll take his question, and then we can go to your -- 2:31:37: John Honker: Sure. 2:31:38: Commissioner Scharff: Just briefly. I saw -- on -- I think it was the previous slide -- which talked about -- on the aerial, significant -- 2:31:44: ### Slide 31 again (for no good reason) It was more expensive because it was significant pole replacement that was required. ### Pole replacement was mentioned on slides 10 and 29. It was unclear to me why the electric utility really wouldn't pay for the pole replacement. I'm assuming that a lot of that significant pole replacement would be driven by -- the poles are older, and all of that. And I guess I'm just curious, as -- since we're letting people put -- Since we're letting AT&T and Verizon put their stuff on our poles anyway, why us putting that stuff on the pole would necessitate us -- necessitate the fiber paying for the pole replacement. So I wasn't sure why that assumption was in the model that way. And if you looked at it without pole replacement, does it change the costs significantly? 2:32:27: John Honker: Um. I'll answer part of that question. And maybe I can kick the other part to Dr. Batchelor. So, we definitely think the pole replacement -- There will be some pole replacement. But those costs could potentially be split with the different departments. Or, it could be split with electric. Or it could be split with, you know, City departments that are also paying for a portion of the network. So, I think it would be split three ways -- is kind of the way we had modeled it. The question was just uncertainty around how many poles may need to be replaced. And we would be able to find this out sort of in this detailed engineering phase pretty quickly. ### The 09-28-15 staff report said a pole might have to be replaced if it's not tall enough, or if it's not strong enough. In a public-information meeting leading up to 09-28-15, I believe staff estimated that if might cost about $7 million for needed 140 pole replacement AND make-ready on poles that didn't need to be replaced. But the 09-28-15 staff report didn't provide further details. ### When a pole has to be replaced because it's too old, all the parties (the City, AT&T, and Comcast) have to share the cost of replacement. And a few years ago,I believe that the City adopted a policy that when a pole has to be replaced because it's too old, the City should make sure the new pole is tall enough and strong enough for the City's fiber infrastructure, and that no make-ready is required to deploy the City's fiber infrastructure. (Before that, the City apparently didn't always do this.) I'd love to see the document where this is written down. I'd love to know how staff makes sure that it is always following this policy. 2:33:03: Commissioner Scharff: I guess later we could look at the question. But, would it need to be split, or could we just have the electric utility pay for it? I mean, ... 2:33:09: Dean Batchelor: So, I'm not sure if -- you know, if -- We would have to take a hard look at that, Commissioner Scharff. And the reason for that is, is that, right now, the pole calculations are fine, we'll say. And then, when we start adding on this additional fiber. And then, the pole calculations then go to the negative side, where the pole needs to be increased in size, because you have more weight onto that. And typically, whatever project -- It could be A&T that could unbalance that. It could be the electric side. Or, in this case, it could be the fiber. That's causing that pole to be out of whack at this point. And so, then, at that point, we think that the Fiber Fund would have to pay for that pole. It would not be shared at that point. ### As I understand it, the agreement with AT&T and Comcast says that AT&T and Comcast wouldn't have to share in the cost. But I don't know whether it constrains what part of the City has to pay for it. 2:33:59: Commissioner Scharff: I mean, I think that's a legal issue, because -- Right? I mean, -- Because if we could have the electric utility pay for it, I think we should. But, I mean, the notion that the last person on the pole, who breaks the camel's back, with his last bit of weight, is the one who pays for it -- I'm not sure that's a good model, frankly. [chuckles] Even if I was thinking of it from a pure public policy point of view. But -- you know, but obviously, I think we could just have legal tell us whether or not we could do that. And what our options were. And it could be a public policy choice. But I was just wondering if, when Magellan looked at that, whether or not they had those inputs, or if those were just decided that way. And it's a question to you. I guess you were given that -- on the pole replacement -- that that's how we were going to do it. Right? When Magellan -- when you looked at it? 2:34:49: John Honker: Right. Yeah. We -- well, we've thought about it from the perspective of, it could be -- It would need to be paid by fiber. But the City could contribute to it if the City's paying for a portion of the backbone. Or, the City departments are paying for a portion of the backbone. And a portion of the backbone is being paid for by electric, then would that charge be split three ways? Or, would, sort of, fiber be reimbursed for a portion of those charges? It may still be paid for by fiber, but reimbursed by the other two departments. 2:35:25: Commissioner Scharff: I guess my takeaway from all of this is that we need to get those costs down by about 20 percent, because that provides the right cushion. In your graph. Right? I just think that we need to be -- look carefully about how we get that done. Because, obviously, if we go 20 percent over budget, that causes a huge negative to that whole graph. So, that was really my takeaway. Thanks. 2:35:55: Chair Forssell: All right. I'm just thinking. We've got -- This as an action item. And we've a staff recommendation. And the staff recommendation includes some pieces that we haven't really talked about yet. Mr. Honker, you mentioned that you've got a little bit more to present. 2:36:18: 141 John Honker: We've got a couple of slides. 2:36:19: Chair Forssell: Is it general interest? Or is it sort of directly relevant to the recommended actions? 2:36:26: John Honker: It really was just another iteration of the model, where you could, potentially, not utilize bonding. And build out on a much longer time scale, though. Over a 10-year period. 2:36:41: Commissioner Danaher: I think that's an important topic, actually. I've been studying those slides. 2;36:45: Chair Forssell: Yeah. Why don't we go ahead and take those. But if you've got any way to move quickly, -- 2:36:50: John Honker: Yeah. We can move through it in about 5 minutes. And then start ... 2:36:52: Chair Forssell: OK. 2:36:53: John Honker. ... start with some questions. 2:36:55: Chair Forssell: Great. 2:36:56: John Honker: So, the concept was -- right? -- there's new bonding out there. You know, is there an alternative to bonding that could allow the City to still deploy a network, over, potentially, a longer period of time, by using excess revenues that are generated in the initial deployment, to expand the network? So think about -- let's build a little on the front end -- because we have $32.5 million in funding to be able to build some fiber-to-the-home. ### Again, the $32.5 million is the sum of $17.5 million (from the Fiber Fund after the backbone takes whatever it takes) and $15,000 (borrowed from the Electric Special Projects Reserve). ### Elsewhere in the presentation, the Fiber Fund is said to be $30 million. But in the 4Q20 Utilities Quarterly Report, it's said to be $33.065 million. https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/reports/uac-informational-reports/2021- informational-reports/02-03-2021/id-11731.pdf So, to do that, we would basically look at the areas where we would build first. Which would be very revenue-generating areas. Low-cost construction, and high-density areas, where you would get a lot of bang for your buck. That could start generating "exce-" -- revenues early -- and "excess" revenues that you could use to reinvest for future expansion. And then, also, in conjunction with that -- because we're looking on a longer time scale -- 10 years -- are there opportunities for companion projects, where possible, to reduce costs? You know, it could be gas. ### As a rule, gas is usually on the other side of the street. Also, the "opportunistic" deployment of conduit for fiber in the Upgrade Downtown project was truly a disaster. Maybe Magellan should take a look at that specific project and comment. It could be undergrounding. 142 ### The City already has a program for deploying conduit for fiber when the electric is undergrounded. But lately, the City's electric undergrounding program has slowed way down. It could be, you know, water. ### As a rule, water is usually on the other side of the street. It could be streets. Wherever there's a companion that could have a joint trench -- ### Elsewhere in the presentation, it says trench is more expensive than boring. could -- that could potentially create some more opportunities to reduce costs. 2:38:13: ### Slide 34 So, when we looked at this, we ran a separate financial model. And this graph really shows what that incremental deployment would look like. In the first 3 years, you can see in this map -- with the City boundary -- the areas in green would be the designated areas for deployment. In Years 1-3. Right? ### How did Magellan determine the boundaries of each of the areas on the map? And, again, these are -- these are sorted for highest density and lowest cost. ### How were these computed? ### I see that Underground District 41 (bounded by Middlefield Road, Colorado Avenue, Cowper Street, and Oregon Expressway) is shown as too expensive to get FTTP in the first 10 years. But this district has conduit for fiber. In fact, some residences even paid to provide conduit for fiber from the street to the residence. So, if anything, the true cost to do FTTP here ought to be even less than in aerial districts. Can the computer program that did these estimates be refined to make them more accurate? To generate, you know, significant revenues for the City. That it can then reinvest into future builds. So, if we did that, it would allow us -- for the $32 million, we would be able to 12,500 homes and about 550 businesses. Right? ### I initially confused Slide 34 (PDF page 80) with Slide 20 (PDF page 66) of "take rates needed to achieve break even." That would give you sort of a foundation, to start generating new cash flow, that could be used to invest in future build-out without bonding. In Years 4-10. So, Years 1-3 utilize the $32.5 million that's out there in funding today. Years 4-10 use all of the "excess" revenues -- revenues that are generated from phase 1 -- from these first 3 years. Now, as we build out new areas, two things happen: 1) we don't get as much bang for out buck, because we've already taken the most -- the lowest-cost areas off the table; and 2) these areas are less dense. So, in Years 4-10, we can build out to almost 7,100 households and 537 businesses. Well, what we have left over -- Oh, you can see those in yellow. Right? All these yellow areas would be the second phase of build-out. 2:40:05: And then, in Year -- What you have after that is, you still have 7,000 households remaining, and 209 businesses. These are the most expensive areas. They're predominantly underground, where construction costs are high. And those are the ones that we would really have to be looking at -- other opportunities to get out there and deploy. It could be an undergrounding project. Or a joint trench. Something that would allow us to reduce construction costs. But the City would have a longer time scale to be able to look for those opportunities. Not to say that all 7,000 houses could be built out. But you could probably get some -- some of those built to. So, as we looked at this model -- And it's more of an incremental model. 2:40:51: ### Slide 35 143 It doesn't take any bonding. The first phase gives us 12,500 homes, with 558 businesses. Total capital expenditures for that are about -- almost $30 million. There's some working capital that's required. Not a whole lot, because it's a smaller build. And, then, we're using, again, the funding that's out there today for the $32.5 million -- funding traunch. 2:41:21: ### Slide 36 The future phases -- you know, we only get to 7,000 -- or 7,100. But our total homes built in the City is about 19,500. So that's about 65 percent of the total homes. We get to about, well, 1,100 businesses. And the second phase really costs about $21 million for the build-out. You're basically building about 1,000 homes a year, over -- between Years 4 and 10. So, it's not super significant. Because in the first three years, you're building about 7,000 homes a year. Or, no. I'm sorry. About 4,000 homes a year. So, you're building slower. You're building what you can with the cash you have on hand from the first phase. 2:42:05: ### Slide 37 So, over the 10-year period, it allows the City to potentially build to 70 percent of the homes and businesses without any bonding. The initial deployment, in the first 3 years, would be to about 46 percent of all homes. And the incremental deployments would add another 25 percent or so of homes. The total funding for that would be the $32 million. And then, the secondary funding of the $21 million. So, it would be about $53 million in total funding. But, again, no bonding. ### Slide 38 What would be left -- 7,000 homes and 200 businesses -- Again, these are the most expensive to build and the lowest density. So, it still requires a lot of capital, because this is almost all underground infrastructure. So, we would just look for those opportunities wherever we could, to build out without the need to go -- you know, build new. And a new construction. But that would really be the challenge to solve, is, how do you get to these additional 7,000 homes? And do it, you know, in advance. Do it more quickly than waiting until the 10 years is up. Because you could start that process now, and look for ways. So, this just another option, as we look at, you know, funding strategies. And if there's alternatives to sort of the traditional build-all-at-once route that's generally utilized. 2:43:41: ### Slide 39 So, you know, again, it's sort of a business case summary. You know, regardless of whether you're looking at partnership or city-ISP. Number 1) is bond, and build out to 100 bus- -- 100 percent of the homes and businesses over a 5-year period. ### Why 5 years? Longmont built out citywide FTTP in 3 years. https://muninetworks.org/content/watch-how-longmont-colorado-built-community-network-year And their winters prevented building out during the winter. And their soils are significantly rocky. Or 2) is, no-bond, and build out to most of the homes and businesses, with about, you know, 7,500 that will remain over that 10-year period. You know. So, these are really the two options to think about. Or, you know, some combination of them. Maybe we look at some bonding for the more expensive homes. And use the existing funding, not to build out the 12,000 that we had talked about. ### The presentation doesn't explain why "no bonding" might be a good idea. So, that ... 2:44:30: Commissioner Jackson: I had a quick question on this. I have a question on this slide. 2:44:36: 144 Chair Forssell: Go ahead. 2:44:36: Commissioner Jackson: So, my question is about what "bond" really means. And it's really more to Council Member Filseth or Director Batchelor. So, if we say "bond," do we mean -- ah -- do we have to go to the voters for the bond? Or do we just -- can Council just say, we're just going to vote a bond, and we're going to do it? And, if we have to go to the voters, then is it a majority vote? Or is it a more-than-a-majority vote? ### In 2004, staff looked at a number of financing options for FTTP -- six, I think -- and didn't like any of them. But the public didn't get to see a staff report about it. 2:45:07: Council Member Filseth: I assume it would be done with a COP, which doesn't go to the voters. 2:45:15: John Honker: So, maybe instead of "bond," we should just say "borrow." It's some kind of borrowing. It may not be a bond. 2:45:23: Commissioner Jackson: OK. We could do this with a certificate of participation. 'Cause we can -- I guess -- Certificates of participation -- I know very little about this -- but they -- the -- the collateral is the network it is that you're building. Is that roughly true. And then, could you -- can you collateralize the network that you're building? 2:45:45: John Honker: The City of Boulder is doing that right now. So they're -- the backbone they're building -- they issued $20 million of COPs to build the backbone. And they were able to collateralize that with the infrastructure itself. 2:46:01: Dave Yuan: This is Dave. We've also done this for other CIP projects, like the emergency water supply. We backed it up with the other utilities. Revenue from the electric, gas, and wastewater as well. So, that could be the collateral. ### More details would be interesting. Were these also COPs? 2:46:17: **: Um hum. 2:46:19: Commissioner Jackson: That answers my question. Thank you. 2:46:22: Chair Forssell: I have a quick question on the map that you showed, with the green and yellow and red. 2:46:27: ### Slide 34 again And you said that most of the alternative deployment neighborhoods are already undergrounded. Which really surprised me, 'cause I didn't think we had that much of the City undergrounded. And I don't know if you're the right one to speak to that, or Director Batchelor is. It's just that -- As Commissioner Scharff sometimes asks, it that really true? ### I'm glad that Commissioner Scharff's style has been an inspiration to others. 145 Um -- 2:46:56: Dean Batchelor: So, the underground split throughout the City is about a 60-40 split. 60 percent being overhead, 40 percent being underground. ### How is this measured? Miles? Premises passed? The 05-07-03 staff report to UAC on FTTP was based on a 70-30 split -- 70 percent of premises passed would be aerial, and 30 percent undergrounded. (Due to a disastrous upgrade of the City's website, this report is apparently inaccessible at the moment.) I guess I'd be surprised it the split has changed that much since then. So, we looked at this. And Engineering worked with Magellan, to give them the statuses of where those underground areas are. The -- It's a pretty true number. 2:47:17: John Honker: And also, don't think about this as everything is underground in the red areas. There -- It may be partial underground, partial aerial. This is - These are just the areas where -- let's call them the "fiber zones" -- where deployment would happen. So, in these areas, you may have a preponderance of underground, but it may not be all underground. 2:47:37: Chair Forssell: Sure. No, I understand it's not a one-to-one match. I actually didn't think we had a -- I didn't realize that as much as 40 percent of the City was already underground. But it makes it more plausible. ### Continued in Part 3. 146 Baumb, Nelly From:Jeff Hoel <jeff_hoel@yahoo.com> Sent:Thursday, May 13, 2021 5:18 PM To:Council, City; UAC Cc:Hoel, Jeff (external) Subject:TRANSCRIPT & COMMENTS (Part 1) -- 04-21-21 UAC mtg -- FTTP CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Council members and Commissioners, Here's part 1 of the TRANSCRIPT. Jeff ################################################################################################# ### Video: https://midpenmedia.org/utilities-advisory-commission-31-4212021/ Staff report, including the presentation slides (pages 47-102) https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2021/04-21-2021-special/id-12118-item-no-1.pdf 0:00:00 Chair Forssell: All right. Well, hello, everybody. Welcome to the April 21st special meeting of the Utilities Advisory Commission. We're doing a special meeting today because we have an agenda item that we expect a lengthy discussion on, and it was sort of too big of a topic to squeeze into our regular meeting agenda, which was already quite full. So, thank you, everybody, for making time to meet today. We'll go ahead and start with roll call. I'm just going to read out the names on the -- in the order that they popped up on my Zoom screen. Vice Chair Segal. 0:00:40: Vice Chair Segal: Here. 0:00:42: Chair Forssell: Commissioner Johnston. 0:00:44: Commissioner Johnston: Here. 0:00:45: Chair Forssell: Commissioner Scharff. 0:00:47: Commissioner Scharff: Here. 0:00:49: 147 Chair Forsell: Commissioner Smith. 0:00:50: Commissioner Smith: Here. 0:00:52: Chair Forssell: Commissioner Danaher. 0:00:55: Commissioner Danaher: Here. 0:00:56: Chair Forssell: Commissioner Jackson. 0:00:57: Commissioner Jackson: Here. 0:00:59: Chair Forssell: All right. And, obviously, I'm here as well. So, we have everybody in attendance, which is great. ### The Zoom screen shows that other attendees include Council Member Eric Filseth (UAC Liaison), Dean Batchelor (Director of Utilities), and John Honker (CEO of Magellan Advisors). ### Other participants throughout the meeting include: Dave Yuan (staff), Jory Wolf (Magellan), Cole Henkle (Magellan), Andy Poggio, Mayor Tom DuBois, John Kelley, ** (0:03:48) 0:01:04: Chair Forssell: There's only one item on the agenda today. And there are no revisions. We're going to be talking about fiber today. Are there any oral communications from the public? Any public comment on a topic that is NOT on the agenda? There will be time for public comment on the agenda item right before we start discussing it officially. 0:01:30: Dave Yuan : Chair Forssell, we do have one speaker, **. 0:01:33: Chair Forssell: OK. That's great. We usually allow three minutes. Go ahead, Mr. Kelley. 0:01:48: John Kelley: Thank you very much. Thank you for your time. I'll be very brief. Chair Forssell, Vice Chair Segal, commissioners. I believe that there are inconsistencies between the City of Palo Alto's stated sustainability and housing goals, on the one hand, and the actual policies followed by the City and the City of Palo Alto Utilities regarding electric, gas, and water services. These inconsistencies include what I regard as discriminatory new service, hearing (?), metering, and connection policies, that operate to penalize citizens in ADUs, *DUs, and associated dwellings. And that also, in my opinion, discourage the creation of more housing, especially more lower-cost housing. In the last couple of days, I've written to you in a preliminary way concerning these matters. And I understand from City staff that those letters will be part of the materials that you'll be receiving in connection with your main meeting. I do not know whether there are any committees or subgroups of the UAC that are specifically concerned with such matters. And I don't know whether there are any specific members of the City of Palo Alto Utilities staff to whom I should address my questions and concerns. But I will seek to identify such persons. And if there are any, and they want to reach out to me, I would certainly welcome hearing from them. I will likely address you further on these matters at your main meeting. But, on the 148 eve of Earth Day, I thought it was particularly important to bring them to your attention, And I hope that, as time goes on, that you will give them more consideration. Thank you very much for your time. I won't take up more of it. I'm sure you have a lot to talk about tonight. Thank you. 0:03:26: Chair Forssell: Thank you very much for that. As you probably know, we can't respond right now. But -- Thanks for writing in as well. 0:03:37: Chair Forssell: So, let's see, our next item of business is usually approval of the minutes. But I'm not sure any -- that our minutes from the last meeting were included with this packet. 0:03:48: **: Chair Forssell, at this point, the only thing that we're doing is the agenda item number 1. ### That is, agenda item VII.1. ### In years past, it has been traditional for for staff members to identify themselves when they start participating. The official draft minutes don't say who this speaker is. So there will be no minutes to approve. And no Director's Report. ### Later, at 0:08:24, Director Batchelor asks to give a kind of a Director's Report, and at 3:42:56, he gives it. 0:04:00: Chair Forssell: OK. Great. And we have no unfinished business either. So, we'll skip items IV, V, and VI, and go straight to it. So, then, let's call for public comment on the topic of the day. Which is a review of the fiber network expansion report: review and discussion. ### Actually, the item title says "direction," not "discussion." And the item is an action item (which is great). 0:04:24: Dave Yuan: If anyone from the public would like to speak, please raise your hand. Let's start with Mr. Poggio. 0:04:37: Chair Forssell: And, Mr. Poggio, we usually allow three minutes for each member of the public. 0:04:42: Andy Poggio: Thank you. I'm glad this topic has come before the UAC. And I'm glad we're addressing it. I think everybody knows the value of fiber-to-the-premises for Palo Alto. So I won't spend a lot of time on that. If anyone had doubts in the past, I think the pandemic, and the HUGE increase in working from home, has brought home the value of fiber-to-the-premises. So, I really have only one brief point to make. And that is, as I was reading the Magellan information, they said they'll be doing a survey. And then, in sync with and beyond the broadband survey, they'll provide - - the City will provide educational outreach and launch a community engagement platform. The order that you do that in, I believe, is critically important. I believe that fiber-to-the-premises in Palo Alto has to be MARKETED -- and people have to be FULLY INFORMED about it -- before you take any survey. Otherwise, the results of the survey will be much, much less valuable. One might say useless. The marketing and information has to take place first. So people understand what they're being surveyed about. So, I urge the UAC to make sure that full-blown marketing, educational outreach, community engagement -- all of those activities -- happen before any survey takes place. Otherwise, the survey results will not be very useful. Thank you for your time. 0:06:17: Chair Forssell: Thank you very much. Are there any other members of the public? 149 0:06:25: Dave Yuan: Yes. Our next speaker is Mr. DuBois. 0:06:30: Mayor Tom DuBois: Hi, everybody. It's Tom DuBois, speaking for myself, not as a Council member. I just wanted to share two quick thoughts. First, it's really easy to say no, and hard to say yes. We don't often look at the opportunity to create a new utility. And I'd ask you guys tonight to keep an open mind, and really look for solutions. And the second thing is, let's see if we can be creative about construction. The construction costs are a key driver. And this network becomes more achievable if we can use lower-cost construction techniques. So, thank you. And I look forward to listening to your discussion tonight. 0:07:14: Chair Forssell: Thank you very much. Are there any other members of the public who want to speak? 0:07:23: Dave Yuan: Are there any other members? If so, please raise you hand. Yup, we have one more. Mr. Adams. 0:07:32: Chair Forssell: Go ahead, Mr. Adams. 0:07:34: Douglas Adams: Hi. I just want to say that I think this is super, super important. I'm not generally involved in Palo Alto politics. But this is so important to me that -- here I am. So, I'm really excited for this. And I hope you guys proceed. 0:07:54: Chair Forssell: All right. Thank you, and welcome. Are there any other -- go ahead -- 0:08:02: Dave Yuan: I was going to say, last call for public comment. I think the floor is yours. 0:08:08: Chair Forssell: All right. Director Bachelor, why don't I hand it over to you. I assume that staff and some representatives from Magellan have some remarks and a presentation to start us off. 0:08:24: Director Bachelor: Sure. Good evening, Chair Forssell, commissioners. Council Member Forssell -- or Filseth -- sorry. I do have one update that I would like to talk about tonight. So, I don't really want to break the flow, since we're moving forward on this. But I would like to -- before the evening is over -- to talk a little bit about the recent three large outages that we had. And I think it's important that I talk a little bit about that to all of you. So, I think what I'll do is, I think I'll wait towards the end of this meeting, at this period of time. And we'll just move into the agenda item. And so, tonight, we have with us John Honker from Magellan, that we've been working closely with to put this presentation together. Also, too, is that I wanted to thank the subcommittee -- Commissioners Loren Smith, Lauren Segal [who is also Vice Chair], and Don Jackson -- for all their work -- that they worked with us, and with Magellan, to put this presentation together. So, I truly appreciate all the work that you did with this. So, with that, I'm going to turn it over to John, that can introduce his team. And then, we'll roll through the presentation. Feel free to ask questions during the presentation. 0:09:52: ### Slide 1 150 And then we'll have a Q&A time afterwards. So, with that, I'll turn it over to John. 0:09:57: John Honker: Great. Thanks, Dean Batchelor. And thank you, commissioners and Chair Forssell, for the opportunity to present sort of the next phase of the Fiber Expansion Plan to the UAC. A lot of work has gone into this over the past six months -- seven months -- since we met with you last August. A lot has happened since then, too. So, we appreciate the guidance and the efforts that you've all made to help us -- help -- keep us aligned, as we help develop the best solutions for the City of Palo Alto's Fiber Expansion, both on the fiber backbone side -- which we'll talk first about -- and, secondly, on the fiber-to-the-home side, which we'll talk -- discuss in the second item. So, as we go through this tonight, please interrupt me with any questions. What we'll try to do is keep this presentation to about 40 minutes. And then just go directly into Q&A. But don't hesitate to interrupt as we go along. Because we're going to cover a lot. And we're going to try to keep it kind of concise. But if there is specific detail that is further than we're showing in the presentation -- We have all the financials. We have maps. We have all the detail -- work that's gone into the project over the past six months to get to the point that we're at today. 0:11:24: ### Slide 2 (not exactly the same as in the staff report -- it doesn't say "recap from our last meeting") So, without further ado, I'll go into -- quickly -- and agenda of what we're going to cover tonight. Section 1 will be a little shorter, because it's a little more concise, and it will cover the fiber backbone expansion. And discuss why the City should expand its fiber backbone. And how the City should do so, based on the findings that we came up with cooperatively with both the team on the phone here today, the CPAU, and a number of City departments that we worked with interactively, to conduct a formal needs assessment with them, for expanded connectivity and fiber. 0:12:03: So, we'll cover that first, followed by the fiber-to-the-home expansion. Looking for the opportunities that exist for the City. And, then, what it really takes to provide fiber-to-the-home in Palo Alto. And, finally, we'll talk about the recommendations and next steps, which are really proceedings to this presentation, to move into detailed engineering, community engagement, partnership investigation. And then also exploring additional funding options, a number of which we are going to show you today. But there are a number of additional funding options that could -- let's say -- complement what Palo Alto would be looking at funding directly. 0:12:45: ### Slide 3 So, today's presentation will cover, really, two phases. If you remember, from our last meeting, we -- you had requested that we move ahead and fast-track the fiber-to-the-home business case, and make it part of the initial planning. And we were able to do that, and meet the deadlines, to get that completed by, of course, tonight's meeting. And we'll cover, really, that business case for fiber-to-the-home and fiber backbone. As we look at our next steps beyond that, then -- and based on your guidance -- we would move into detailed engineering design. As we mentioned before, the community engagement. And understanding community needs for different services -- speeds, pricing, affordability, what drives citizens and businesses to buy broadband. And what they're looking for from the City of Palo Alto. And we'll also, then, move into the detailed backbone design, to expand the City's EXISTING backbone, to accommodate your existing needs and your future needs. 0:13:55: ### Slide 4 So, we'll talk first about the fiber backbone expansion. 0:13:56: ### Slide 5 151 So, why should the City expand its fiber backbone? When we look at fiber, we see so many opportunities and use cases for expanding the backbone in Palo Alto, across all of your civic functions. Right? Looking at your existing utilities -- electric, gas, wastewater, storm, and even the fiber business, all those utilities have an additional need for fiber connectivity in this City. And the existing network is somewhat at capacity. Right? As we worked with your different departments, and we worked with the fiber department inside CPAU, we realized -- we discussed some of the limitations on the existing network. And those limitations translate into, you know, unmet needs for things on the -- functions on the list here. So -- energy management, public safety, traffic management, smart parking, electrification, economic development. You know. Everything that, basically, a City does has a use case for fiber. And as we went -- walked -- through the use cases with the departments, we found that, you know, there were opportunities across the board to -- that they could utilize if they had fiber connectivity. ### I'd be interested in more detail about the way Magellan asked the different City departments what their "fiber" needs were. If they said, "We probably won't get citywide FTTP any time soon, so how many dark fiber strands do you need," they'd get one answer. If they said, "When we get citywide FTTP, what department communications needs do you think could NOT be met by FTTP," they'd get another answer. 0:15:12: We also think about it as important for external stakeholders as well. As you look at your local schools, libraries, any regional collaboration, you know, in the Bay Area. And, finally, to your residents and businesses, through fiber-to-the- home. So, you know, when we think about the fiber backbone, we don't just think about IT or utilities using it. This becomes a citywide infrastructure that strengthens your abilities -- your capabilities -- to be able to govern and empower the community. 0:15:46: ### Slide 6 0:15:47: Chair Forssell: Mr. Honker. Sorry, you invited questions as we went along. Is it all right if I ask a question on that last slide? 0:15:53: ### Slide 5 again John Honker: Absolutely. 0:15:54: Chair Forssell: So, can you -- can you just give an example of fiber being essential for -- you know, just pick one of these ... 0:16:05: John Honker: Sure. 0:16:05: Chair Forssell: ... one of these City functions. Sort of, like, what can't be done now that fiber would enable. Sort of more specifically. 0:16:14: John Honker: Absolutely. And I'm going to invite Jory Wolf to answer that question, because he actually worked with each one of your departments. So, Jory, do you want to talk about some of the use cases, for Chair Forssell. 0:16:26: Jory Wolf: Sure. Absolutely. So, we can talk really about congestion ma- ... 152 0:16:31: VIDEO SILENCE 0:16:37: ... alliance of traffic management, smart parking technologies that would not be supported without fiber optics. And those technologies include high-bandwidth cameras. Wireless technologies, to support both traffic signalization and synchronization. As well as bicyclists' sharrows, and other bike lane technologies, to improve traffic flow, for new alternative methods of transportation. Back to you, John. 0:17:13: John Honker: I think another -- Chair Forssell -- And I think another really important one that we found as we went through the needs assessment was really for CPAU and the electric utility. Looking at the existing fiber, and expanding the existing fiber really provides higher levels of reliability to the electric grid. And that's really important as we start looking at, you know, not just supporting, you know, the up time of power to homes and businesses but also being able to manage resources in the field more easily. And have the redundancy necessary so that if there IS a fiber hit -- if there is a failure -- that disconnects substations, immediately, we have millisecond wraparound -- millisecond redundancy -- to make sure that those substations can always communicate with one another. And Dr. Batchelor team has the information technology they need to be able to both troubleshoot the issues and be able to proactively mitigate them. ### Chattanooga, TN, pioneered doing, using their FTTP network for the communications. ### Dr. Batchelor? 0:18:20: Chair Forssell: Thanks. Thanks for those examples. 0:18:22: John Honker: Sure. You're welcome. 0:18:24: ### Slide 6 again So, putting it in context, you know, we like to look back at the original fiber backbone, that was built back in 1996. And it was originally used to connect City facilities. ### It was also, from the beginning, intended to serve other customers besides the City. So, the backbone is 25 years old now. And it is still, you know, doing some amazing things for the City. And, you know, when we think about what the backbone's original purposes were for, and what it was actually used for, it's really shocking to realize how much value was derived out of the investments that the City made in the original fiber. Being -- You know, today, that network generates $4 million in gross revenues. And has yielded a $30 million fiber reserve for the City. That's -- that's in -- you know, in dollars -- in cash -- that's been growing, you know, over those years. We're connecting City facilities. We connected the substations. The water facilities are connected. Traffic signals are connected. ### Not all traffic signals are connected by fiber. For example, in 2018, when the Upgrade Downtown project tore up a half-mile stretch of University Avenue to replace water and gas pipes, it also put in conduit for fiber, because no conduit for fiber previously existed. The traffic signals were on the other side of the street and remained connected only by copper wires. You know, Palo Alto U.S. schools are connected. ### Maybe Honker was trying to refer to PAUSD (Palo Alto Unified School District) schools. 153 Business parks are connected. ### Dark fiber "nodes" are in or close to many business parks. But that's not the same as being "connected." And over 220 business customers have access to dark fiber, where they otherwise wouldn't -- Or, they would, but they might be significantly higher prices. ### According to the City's 4Q20 Utilities Quarterly Report, https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/reports/uac-informational-reports/2021- informational-reports/02-03-2021/id-11731.pdf there are (only) 94 customer accounts. And there are (only) 201 active dark fiber connections, counting both the City's connections and business connections. Honker may be trying to say that there are over 220 business premises could connect to the dark fiber network if they wanted to, but only 94 have taken advantage of this "access." So, when you look at that fiber, what it was originally intended for -- And we look at what it was able to do for the City -- I mean, it's a -- It's a -- It definitely paid for itself, and then some. The value that it's generated is huge, in terms of not only the financial -- the revenues generated -- but in also the capabilities that it allowed the City to manage, across all these different departments. 0:20:07: So, you know, today, as we went through the analysis of the existing network, we did find -- and this is true -- there's - - You know, there are now limitations. Right? That network is jammed full of customers and applications. ### Some segments of the dark fiber network are more "jammed" than others. Some segments of the original network used (only) 144-count fiber cable. According to this 02-07-18 staff report, https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2018/02-07-2018-meeting/item-5-fiber-utility-update.pdf "Since the late 1990s, the fiber backbone has been expanded to approximately 49 route miles of mostly 144- or 288-count single-mode fiber." Specifically, "The route from PAIX at 529 Bryant to the Park Boulevard Substation has been completed. ... The new fiber installed for the backbone rebuild is 312-count single-mode fiber (2 x 144-count single-mode fiber, plus 24-count single-mode fiber)." ### Most dark fiber customers choose Equinix (PAIX) to be the other end of the dark fibers they lease. So, the segments around PAIX are no doubt more heavily used than most segments. Still, IF all of the City's 201 active dark fiber connections went through the segment from PAIX to the Park Boulevard Substation, it wouldn't use up all the strands in that segment. And now, the goal is to -- for you is, really, to take that network ... 0:20:27: ### Slide 7 ... and expand it for the future. And for the next 25 years. The foundation of that would be, really, a new fiber backbone. Expanding access across the City. And, you know, we've identified some very high-level opportunities for this, you know, through the needs assessment. But, you know, this is probably just a small smattering of what the fiber will be able to do for Palo Alto. So, when we look at utility modernization -- you know, supporting the AMI project -- which is, you know, starting now -- managing the field resources that are electric field resources, and also, supporting reliability and resiliency, for electric service. 0:21:11: We think about smart city infrastructure. And this is something that is very burgeoning, still, in cities. But it's -- there's some applications that are happening every day. When we look at departments that are using technology, to manage their communities more effectively, they need the connectivity to be able to do that. And that happens across, you know, City IT, parks, emergency preparedness, education, public safety, transportation, and smart parking. We talked about some of those applications before. But, you know, we see this time and again with cities who have fiber. They're deploying more sensors. They're deploying more -- uh -- more things in the field that are connected to fiber, that are helping them manage their resources. 154 0:22:03: The other aspect of this is really commercial fiber leasing. Right? As we worked with the CPAU team, we found that there's -- there are new opportunities for commercial fiber leasing, in areas where the fiber backbone doesn't currently pass. ### Again, the dark fiber network doesn't currently "pass" any premises. So, this gives the City a new resource to generate revenue, and also to serve economic development needs. 0:22:24: And, finally, ### Last but not least. Fiber-to-the-home. Right? When we look at the fiber backbone, think of this as not a -- you know, this isn't a fiber-to-the- home network, but it's an enabler for the fiber-to-the-home network. So, it becomes a foundation that you utilize to now reduce the cost of fiber-to-the-home, and also improve the way that you can deploy -- and deploy more flexibly. Rather than, you know, deploy all at once, this gives you the opportunity to deploy fiber-to-the-home in a way that best meets the needs of the community, and also in an incremental fashion. 0:23:00: ### Slide 8 So, like I mentioned, the new fiber backbone is really an enabler, and is a prerequisite for fiber-to-the-home broadband. Right? Now, it doesn't CREATE fiber-to-the-home broadband. But the backbone is needed to be able to get the signal across the entire City and connect individual neighborhoods to one another. So, what's required, as an increment beyond the backbone is, really -- you know, greater funding. Right? So, we can look at incremental fiber-to- the-home, where it's being potentially built out over multiple years. And we'll show you a model that allows the City to do that with, you know, minimal bonding. To citywide FTTH, in a more rapid deployment. And -- you know, which can happen in a shorter period. So, think about -- you know, depending on how much money you allocate and how quickly you allocate the money, that will determine how much the network can -- how quickly the network can be deployed, and to how many residents. ### Honker seems to think that "FTTH" is just for residents. It's also for businesses. Right? And then, we also have to consider that -- you know, the business model that's being used. Now, expanded dark fiber leasing -- you're already doing today. And you're already generating $4 million a year off of that, with your existing network. So, this is the opportunity to generate more. Because you're already doing that, we don't see this as any additional risk that the City would be taking, beyond what it's doing today. ### The staff report doesn't discuss in any detail how the City would go about finding more dark fiber customers. 0:24:20: But as we move into, you know, fiber-to-the-home, we see, obviously -- not -- a business model decision. Whether it's a partnership with an ISP, who's going to assume all the retail functions of providing broadband. Effectively, they're the front face of the customer. They're providing all of the services. The City is just providing the infrastructure. The fiber plant. And is effectively sort of a passive owner of that fiber plant. ### I don't like this option. By the way, who does the drops? All the way to the next model, which is City ISP. The City ISP model is, Palo Alto is providing all services, owning the network, providing customer service, providing network operations, and managing all of the customers. So, we think about that as, you know, there's a risk, reward, and control balance, as you make additional investments, and - - Depending on which business model that you select. And we'll go through this in more detail as we get to fiber-to-the- home. But the point -- the take-away for this slide is, really -- think about the new fiber backbone as a necessary component for fiber-to-the-home. And because you're building out this expanded backbone, it's actually not costing you anything additional to equip it for fiber-to-the-home. Meaning that the backbone you're building for all of the City purposes 155 is going to, actually, allow you to reduce costs for deployment of fiber-to-the-home. And, by building the capac- -- build -- sort of a -- we call it engineering the backbone for fiber-to-the-home, you can do so at no additional cost. 0:26:01: ### Slide 9 0:26:02: Commissioner Scharff: Did you model -- I had a quick question. 0:26:04: ### Slide 8 again Did you model how much extra you make if you build out the -- expand the dark fiber? That $22 [million] to $28 million in the report? 0:26:12: John Honker: We did. So, we looked -- We looked at the expanded dark fiber. We didn't use -- because dark fiber is very difficult to model, in terms of, you know, what kind of growth you could expect. Fi- -- The other retail services -- fiber-to-the-home is relatively easy, because we know the number of customers. It's a retail service. It's almost like a utility. Dark fiber is much more of a one-off business, where you may have a couple of customers, here or there. Timing is difficult to plan. So, what we did instead is, we said, let's just grow the existing fiber-to-the-home biz -- oh, I'm sorry -- the existing dark fiber business by 2 percent a year. Right? To cover those additional co- -- those additional customers that come in. So, we're basically increasing the revenues by 2 percent a year, just in perpetuity. 0:27:01: Commissioner Scharff: But if you're going to spend [$]22 [million] to [$]28 [million], and build out the dark fiber, wouldn't that 2 percent be very conservative? 0:27:09: John Honker: It is. 0:27:10: Commissioner Scharff: I mean, 2 percent seems like you're almost not doing anything, really. I mean, you could probably raise the costs 2 percent a year. ### The dark fiber utility has different rate schedules for dark fiber. EDF-3 is for customers who signed contracts after 09-18-06. Rates haven't increased since then. EDF-1 is for customers who signed contracts before 09-18-06. Rates are lower than EDF-3 rates, but are permitted to rise at something like 2 percent per year. The City plans to switch customers from EDF-1 to EDF-3 once EDF-1 rates wouldn't be lower than EDF-3 rates. (There's also an EDF-2 rate schedule, but let's not talk about that.) https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/reports/city-manager-reports- cmrs/attachments/attachment-n-fy-2021-proposed-dark-fiber-rates.pdf 0:27:17: John Honker: And I think, Commissioner Scharff, one of the -- One of our concepts about that was, you have a lot of the dark fiber market already, locked up. Meaning, the customers that you have in Palo Alto today, you have a good chunk of them, and the market's somewhat mature. So, we don't see huge growth opportunities in dark fiber. There's going to be a couple along the way. But today -- versus maybe 5 or 10 years ago -- the market's more competitive for dark fiber. It still gives you opportunities. But we don't want to hinge those opportunities -- We don't want to make -- create a revenue model to say that, hey, the fi- -- the dark fiber could pay back the backbone. Right? We want to show that, rather, dark fiber revenues will increase over time. Let's just increase them slightly. So we're not really developing a very aggressive revenue model on it. 156 0:28:13: Commissioner Scharff: OK. So, would you build out the dark fiber if we weren't going to do fiber-to-the-home? 0:28:20: John Honker: You still would. Absolutely. Because you still need the dark fiber to meet the City's internal needs, today, and growing into the future. 0:28:28: Commissioner Scharff: OK. So, it's really an internal City growth, as opposed to increasing that $4 million a year. ### The $4 million is gross revenues. It's more traditional to cite net revenues. That's really ** take ** on that. 0:28:36: John Honker: Exactly. Think of it, almost, as a capital project. And a sunk cost. Rather than an enterprise fund. Right? Meaning that you're going to be investing -- It's sort of like roads. Right? You invest in the roads. You're not generating any revenue off them, per se. So, you're investing in the dark fiber because -- Indirectly, you are. But you're investing in dark fiber to support City needs. And -- just a side effect -- a side -- positive impact of that is -- you have that additional fiber. To be able to lease. And then, support fiber-to-the-home as you grow. 0:29:06: Commissioner Scharff: So, one more question. I won't belabor this, but if we're going to be providing extra dark fiber, and spending $22 [million] to $28 million -- I mean, we treat it as an enterprise fund. So, then, shouldn't we be charging the City for the utilities? Or whoever uses that? Frankly. To cover that? I mean, it seems -- And shouldn't you be modelling that revenue, therefore, from the City? 'Cause you'd have a captive audience. So, you would actually know what you were going to get. 0:29:33: John Honker: Yeah. So, we actually did that. So, that's in the models. We combined that into the fiber-to-the-home. So you'll see the revenues coming in -- Actually, the -- There's two ways to do it. One would be an up-front contribution from the -- different -- the City, and from the utility. From the electric utility. Or there could be ongoing revenues from the City or the electric utility. Right? It's either sort of a lease or buy-in program. Right? So, they could put up-front capital into it, or they could lease that service from the fiber enterprise over time. 0:30:09: Commissioner Scharff: OK. Thank you. 0:30:12: John Honker: You're welcome. 0:30:12: ### Slide 9 again So, this is just a snapshot of the backbone design. I realize this map is a little small. But what you can see here is, effectively, it covers the majority of the City's -- So, the white outline you see here is really the City of Palo Alto. City boundary. And the red lines show the new fiber optic backbone. And the blue lines show the extensions of that backbone for the electric utility to reach substations and other field resources. So, this backbone is much more substantial than what you have today. For example, you know, your -- this new backbone will be at 432 strands of individual fibers. So, you know, massive capacity. 144 strands of fiber in a separate cable would be -- will be utilized just for electric. Right? And the electric -- We almost always see electric utilities like to have separate fiber. Because it's so essential. And they don't want anyone in that fiber, you know, disrupting -- potentially disrupting electric service, or 157 disrupting communications between the substations. So, we actually engineered an overlay of electric capacity on top of the City backbone. So, there's two separate networks. They're along -- in the same path. There's two separate networks. That gives CPAU the reliability and the protection it needs, while not really increasing costs any -- very substantially. It's 43 miles of total fiber throughout the City. So, we have dedicated fiber for each department. Dedicated fiber for the commercial fiber leasing business. And then, a dedicated allocation of fiber for future fiber-to-the- home. Right? Which can be utilized to really help reduce the costs of your fiber-to-the-home build-out. 0:32:11: And the network was designed, effectively, you know, to support all of the connections across the City. And there's 100 or so connections that would be made into this fiber network with City facilities, electric facilities, SCADA switches that are in the field. So, a lot's going to be connected to the network. But, as you can also see, it intersects -- it bisects a lot of the corridors in Palo Alto. And it was designed in a way to basically keep fiber-to-the-home as part of the equation. Right? When we look at some of the routes that we've designed for this, they intersect neighborhoods, to reduce the costs of building out distribution. Right? So, by -- when we went through the engineering for this, we were able to really look at the City in total, and say, what paths should we take to minimize the extra fiber that has to be built to reach homes and businesses across the City? So, the network's really been optimized for fiber-to-the-home, to keep those costs down, without any really additional cost, in terms of routing. Because we still use our least-cost routing algorithms, which allow us to, you know, value engineer the network, but still make it support fiber-to-the-home in the long term. 0:33:39: Commissioner Smith: But may I ask, when you're looking at the dark fiber expansion, are we looking at, primarily, an aerial distribution? Or is this all subterranean distribution? 0:33:48: John Honker: It's a combination of both. And -- So, it's a combination of aerial and underground. You know, underground is challenging in Palo Alto. It's more expensive than aerial. But in some places, you, frankly, don't have poles. So, it would be the only choice for your -- for new fiber. The aerial's going to be easier. And it will be lower cost. But it's -- Yeah, it's a combination of both. 0:34:13: Commissioner Smith: Thank you. 0:34:14: Chair Forssell: Another question: Do you have a map of our existing fiber backbone? How does it compare to this? 0:34:25: John Honker: We do. So, there's about 27 percent of the existing backbone that overlaps with the new backbone. And the rest is all new routes. And the reason for that is, in your existing backbone, you have -- you have some routes that you're running out of capacity on. So, what we did is, when we worked with the fiber team, we identified where those were, and we used those routes to basically give you more capacity in those areas of the City, that give you -- that allow you to, you know, kind of grow. And also manage that existing network more easily. 0:35:01: Chair Forssell: So, how many miles are there on the existing fiber backbone? 0:35:08: John Honker: Um. Let me ask Cole that. Cole, how much -- Do you remember how many miles we have on the existing fiber? 0:35:15: Cole Henkle: Um. I don't, offhand. 158 0:35:18: Dave Yuan: I think it's roughly about 45 or 47 miles. Currently. ### I think this includes only routes between dark fiber nodes, not the "mega-drops" from nodes to customers. 0:35:24: Chair Forssell: So -- So, it's on the order of the same -- the same number of miles of fiber. And then, it sounds like on the order of 10 miles will be running along the same route? 0:35:37: John Honker: Correct. 0:35:36: Chair Forssell: And then the two backbones will have, each, on the order of 30 miles where they are -- where there's old versus new, and not overlapping. 0:35:47: John Honker: Correct. 0:35:50: Chair Forssell: OK. And I think you answered my other question. I was going to ask, and how many miles of this backbone are sort of "extra," to prepare for fiber-to-the-home, versus essential for City services? 0:36:06: John Honker: Well, really, zero. So ... 0:36:08: Chair Forssell: OK. 0:36:08: John Honker: ... there's no additional fi- -- Think about it. We're not making any additional investments for fiber-to-the- home in the new backbone. Right? We're ... 0:36:15: Chair Forssell: It was all in -- It was all in the choice between two equal -- two equal low-cost routes, you picked one that would better set the City up for fiber-to-the-home. 0:36:26: John Honker: That was the goal. 0:36:27: Chair Forssell: OK. Thanks. 0:36:29: John Honker: Your welcome. 0:36:22: 159 ### Slide 10 OK. So, as we -- and this is just a summary of the construction costs for the backbone. Looking at the combination of aerial and underground, our low estimate for that is about $22.2 million. The high estimate is about $28.1 [million]. Those costs include all of the capital for construction. For everything, effectively, except pole loading and replacement fees that are not included. But we did include a 20 percent contingency in the construction costs, which we feel was going to be supported by the -- the costs that come in for pole loading and any pole replacement. The cost estimation that we did was rel- -- was very accurate. We actually had five current contractors that have done work in the area -- and two in Palo Alto -- quote the jobs. And they all came in relatively similar in terms of construction costs. I would say within 20 percent of each other. So, these are really an average of those costs, plus that 20 percent contingency. You know, underground construction is really the driver of your costs for new fiber. When we look at Palo Alto, your costs are about $100 a foot. That's what -- the numbers we used to calculate the total labor for construction. Materials are about 20 percent of the total budget. Labor is about 80 percent of the total budget. So, because the construction -- underground construction -- is relatively -- is higher than most communities, you know, your budgets are going to be higher than the backbone. But these are -- the estimates that we believe are very accurate, as far as your labor and materials cost. 0:38:32: Commissioner Scharff: Are those costs in Palo Alto driven by Palo Alto requirements? To be more expensive than our neighboring? And, if so, have you identified what they are, so we can get rid of them? 0:38:43: John Honker: We did. So, we looked -- And we'll talk about those in a later slide. But it's a good time to talk about it now. So, there are some things that just are laws of physics. Right? And one of the challenges in Palo Alto is that you do have a lot of underground congestion. And directional drilling, which is the construction method that would be used for most of the underground, is a slow process. So, really, it's a production issue in Palo Alto. Lots of underground utilities. Lots of, you know, utilities that -- more so than lots of communities would have. 0:39:22: We did find some drivers that are specific to Palo Alto. And we actually heard from the construction contractors that bid on the jobs. The three things they cited -- The first -- The most important thing that they cited was the work day in Palo Alto. We heard from two contractors that, you know, when we've built there in the past, our work day is limited to 5-6 hours. Versus, potentially, like, a 9-hour work day. And that was due to no construction during rush hour. I believe it was between, you know, at -- up until 9:00 in the morning. No construction of the LUNCH rush hour, which is 12:00 to 1:00. And then, no construction after 4:00. So, it really is limiting the production that crews can achieve in a single day. Now, you can mitigate that by adding more crews. But it's still going to drive up the cost. 0:40:15: The other thing that we heard was tree protection. As one of the things -- Actually, there were two sort of interrelated aspects we heard. And they were all around sort of permitting and construction standards. One was, the permitting process was -- um -- it took considerably longer for contractors to get permits approved than in other communities. And the tree protection requirements were actually really challenging. So, for example, if a construction contractor is boring along a roadway, and they hit a tree. Or, let's say, they come across a tree that's not on the initial plans -- We heard from one contractor that they had to -- they stopped work and had to have the arborist come out and create a plan to either avoid the tree or remediate any damage to the tree and the root system. So -- Now, we're encountering the same thing in Boulder, Colorado, which is a very similar community to you guys, in terms of its environmental sensitivity. And we're encountering the same thing there. Right? It's slowing down construction. So -- Now, that's a difficult one to change. But, you know, those are a couple of the aspects that we heard from construction contractors that were, you know, direct impacts from Palo Alto. Or, direct impacts from the City. 0:41:44: Dean Batchelor: I think, also, too, one of the big drivers is the prevailing wage that we need to pay in Palo Alto. John, was that about 40 percent? 0:41:54: 160 John Honker: It was. Yeah. When we -- So, we asked the contractors to quote both, the difference was about 45 percent. 0:42:00: Commissioner Scharff: But isn't the prevailing wage ALL cities, because it's a state law? I mean, I remember, Palo Alto said we'd get rid of it if it wasn't a state law. So -- 0:42:08: Dean Batchelor: That's true. 0:42:09: John Honker: Yeah. Any public works project in California -- If it's considered a public works project, it's usually -- nine times out of ten, [it] has to be prevailing wage. Jory, have you seen any others that are different than that? 0:42:23: Jory Wolf: No. They all adhere to prevailing wage laws in California. 0:42:30: Commissioner Danaher: Lisa, may I speak up? 0:42:33: Chair Forssell: Yes. Please. 0:42:35: Commissioner Danaher: Yeah. So, John, we've already talked to the building department about our permitting issues in Palo Alto, which are not satisfactory. I think if we did a project like this, I'd like to explore with them having one or two dedicated permitting people -- or whatever -- to the project. And make them part of the project. Make the building department part of the project plan. To minimize the permitting costs. And also, I could -- if -- the right time, one of your reports highlighted the permitting, and also the traffic issues, and the work day issues, as things that factor this. And it may be the City would agree to relax those on particular roads. It's not, you know, all the time. But getting -- If you're getting, you know, fiber-to-the-home, or -- in your neighborhood, you ought to be able to put up with a little extra traffic for the two weeks, or whatever, for going through that ... 0:43:29: John Honker: Sure. No, ... Commissioner Danaher: ... Thank you for finding those, and to Greg for asking the question. 0:43:35: John Honker: Absolutely. Thank you, Commissioner Danaher. Um. So, this is really the last slide on the fiber backbone expansion. Our next steps on the backbone, you know, per guidance from the UAC, would be to start the low-level engineering -- Right? The detailed engineering design for it. And I think, Commissioner Danaher, that it actually creates a very strong opportunity to look at the permitting. Because as we get into the detailed engineering, we'll actually be working with your permitting department, understanding how permitting is happening today. And can help advise on some strategies that may really fast-track permitting. I mean, what we've been able to do in Boulder -- And Boulder's a very similar community to Palo Alto. Plus, it's got -- you know, it's sitting on a granite base. [chuckles] So, you know, construction is really challenging in Boulder. But we've been able to -- We've been able to get the City to basically phase permitting. So, instead of having sort of street-by-street permits, we've been able to phase, you know, 10 miles at a time. And that's been satisfactory. So, we would envision the same kind of thing in Palo Alto, to kind of fast-track that permitting process. 0:44:47: 161 But I agree with you. It's really important to have dedicated resources. Because if we start talking about this project AND fiber-to-the-home, you know, how often is it that the City does a citywide capital project? Right? That touches every street? Or even a backbone that's touching the majority of the thoroughfares through the City? So, it's really important to make sure the City has the resources to be able to keep up with permits, and keep the construction contractors moving. Which is ultimately going to keep the costs down for you. 0:45:18: Commissioner Jackson: One -- This is Commissioner Jackson. One quick question -- or just comment -- is, while we're thinking about maybe putting Planning people on the team, you might also -- given the nature of this -- you may need Public Works people involved as well. Just because Public Works people "own the roads" ... 0:45:36: John Honker: Sure. 0:45:36: Commissioner Jackson: ... and sidewalks, and things like that. So -- just -- that's the only comment I wanted to make there. 0:45:40: John Honker: Yeah. No. I think, Commissioner Jackson, that's a great point. We would normally interface between Utilities, Public Works, Permitting -- AND Community Relations. Right? Because they need to also know what construction is going to look like, so we can minimize community impact. Right? Phasing construction for fiber backbone and fiber-to-the-home is -- you know, it's such a sensitive process. We want to work with the team, to really make sure that there's a good plan to, you know, start in the right places, avoid, you know, community events, avoid, you know, the busy times of the year -- which in Palo Alto is sort of all the time. [chuckles] But -- Yeah. The coordination with the City departments is really key. 0:46:32: Before we move on to fiber-to-the-home, are there any further questions you might have on the backbone? 0:46:44: Commissioner Scharff: I guess I do. So, I didn't really see any cons to doing this. And I guess your recommendation is, the City moves forward with this. 0:46:57: John Honker: We would recommend -- I think, when we went through this process, and we looked at what you have today, and what you're going to need in the future -- Again, you've got to have the infrastructure to be able to support it. So, our recommendation was, you had to build the backbone. 0:47:12: Commissioner Scharff: And it's relatively inexpensive. I mean, -- 0:47:18: Chair Forssell: I have a -- I have a question. Which is to play devil's advocate for a moment. What do cities do that don't have their own fiber utility to do city communications? And what do utilities do that are not municipal, and also happen to own a fiber backbone? Do they contract with the AT&Ts and Comcasts and Verizons of the world? And is there a cost comparison of what it would -- what it would cost the City to, rather than invest in building its own fiber backbone, to just lease the connectivity and services from one of the carriers that operates here in the City? 0:48:06: 162 John Honker: So, that's an option. I think what's challenging with that option is, it -- When you get -- When you lease the network, it doesn't give you any flexibility on what you can do with the network. Meaning that if you potentially lease it from one of the telcos that are in the market right now, you basically get a network that connects points on a map. Right? Connects City facilities. Connects substations. And there's a couple of challenges with that. One is, it doesn't give you the ability to connect anything that you want to connect. Meaning those -- that fiber has only specific points to connect in the City. And if you want to add something, well, then they're going to build that fiber to that point, and they're going to charge you for it. Right? So, everything addition that you want to connect is an incremental cost that's going to grow over time. And very substantially. Compared to if you're building it yourself. Two, it doesn't give you the security that you would have for electric or for the City departments to run across. So, you know, you're talking about, potentially, putting your fiber backbone for electric in a carrier's hands. And it doesn't give you the same level of security. Which is a challenge. And, I think, third is, it's definitely going to eliminate your opportunities to do fiber-to-the- home. Because it doesn't give you -- the carriers would -- that fiber doesn't give you the flexibility to be able to open it up, and be able to build off of it, into neighborhoods. So, you only are able to get connectivity from one point to another. You don't have any use of that fiber in between those points. And that's the big challenge, is -- And that's why cities -- most of the cities that we work with -- say. hey, we've had this in the past, with one of the carriers. We're going to invest in it ourselves. And that way, we have the capability to do what we want, at a potentially lower cost. If you present-value it back -- If you present-value most of these networks back over a 10-year period, you find that the capital to build them is much than the ongoing lease payments, over the long term. 0:50:20: Chair Forssell: Got it. OK. I was about to say -- You gave many reasons why having your own backbone is better. But didn't answer the part of the question about whether there's a cost comparison. But I'm -- but it sounds like the last part, there, where you're talking about the present value, is, your instinct is --or, your experience is that when it's modeled out, that building your own fiber tends to be ... 0:50:47: John Honker: Almost always ... 0:50:47: Chair Forssell: ... the better investment for a City. 0:50:49: John Honker: Almost always. Almost always. I mean, Jory, do you want to add anything to that? I mean, you've just -- from some of the California networks? 0:50:59: Jory Wolf: Um. Broadband. It's enabling cities to implement government innovation, where they would not be able to afford to do that, should they lease those assets from third-party providers. But in giving them control over those assets, the deployment of government innovation happens very rapidly. The cities that we see have broadband networks are able to address community issues, deploying technologies, connecting IP-enabled devices to solve community problems very quickly. ### Note the "IP-enabled devices" part. IP is one of the protocols that FTTP can use. No so the case with those communities that are depending upon assets from the industry. Um -- 0:51:41: Chair Forssell: Got it. 0:51:43: John Honker: Yeah. I think -- Just a good example of that. So, in Portsmouth, Virginia, we're just finishing a build of the city's fiber backbone. ### As far as I know, Portsmouth didn't already have a dark fiber network before building this fiber backbone. 163 https://muninetworks.org/tags/portsmouth-va This is in sort of the Hampton Roads area of Chesapeake. And, you know, the build is 80 percent complete. And the city has now -- Because of COVID, the city has now said, look, we're going to use our AARP money that's coming in to equip the fiber backbone with wireless points to reach public housing across the city, to allow our, you know, low-income and disadvantaged residents to be able to access job opportunities, and anything they need to do on the internet. ### Using COVID money to fund wireless is creative. I'm not sure Palo Alto could have done that (even if they had had a shovel-ready project). https://www.magellan-advisors.com/news/did-you-know-cares-act-funding-can-be-used-for-community-broadband.stml Palo Alto has used its dark fiber network to deploy some wireless nodes, but Council decided not to do any more, at least for now. ### Wireless is not on my list of things to do before FTTP. They were able to do that within 4 months. But just purchasing the wireless equipment, setting up connectivity at each one of the sites, and connecting it to their fiber. That would have been impossible to do with a commercially-leased network. 0:52:43: Jory Wolf: Now, another good example is: The city of Santa Ana, California, is looking at deploying CBRS wireless technologies to support online learning for their students in disadvantaged districts within their community. And they're partnering with the school district. That's a very similar -- Very similar projects are taking place in Fullerton. In Fountain Valley. Also in Oxnard, California. These communities already have fiber plants that not only make it a very rapid deployment, and inexpensive, but it also attracts third-party partners. Because it eliminates the expense and the barriers to entry for them to provide those services. 0:53:35: Chair Forssell: Thanks. We can go ahead and move on. 0:53:37: Commissioner Scharff: Wait. Can we do one thing before we move on? 0:53:39: Chair Forssell: Oh. Sorry. Yeah, I just meant we can consider MY question answered. [laughs] 0:53:42: Commissioner Scharff: Oh. OK. In the staff report, there were a bunch of things that I ** question the costs of building the dark fiber network backbone. And one of the -- I was a little confused -- it said the costs could depend on whether or not it's a, you know, 2-inch or a 4-inch. I was unclear about why you'd use 2-inch, and why you'd use 4-inch. And I didn't -- Maybe I missed it, but I didn't recall you talking about that. 0:54:04: John Honker: Yeah. So, let me explain that, Commissioner Scharff. So, really, there's -- Think about the networks as equivalent. There's really still a decision -- a final decision that has to be made whether the fiber would be installed inside a 2-inch pipe -- which is a, you know, underground duct -- a 2-inch duct. Or a 4-inch duct. When we talk about the 2 - - There's really two options we came up with. And those are contained in those numbers -- the $22 million to the $28 million. So, the one option is three 2-inch conduits, which give you enough capacity -- plus enough spare capacity for, you know, the next 25-30 years. Or, potentially two 4-inch conduits, which give you the same. They're basically two -- two scenarios, very similar. The 4-inch conduits, of course, are larger. And also, they're harder to construct. So, you know, boring two 4-inch conduits -- the size of the bore, the size of the pipe, and the potential impact to the community -- we think it's going to be much greater than if you're boring 2-inch. So, think about running a 2-inch pipe underground versus a 4-inch pipe. In a congested area. The 2-inch is much easier to work with. It's less expensive. And it's potentially going to allow, you know, less utility hits, less disruptions. You know, those are -- That's really what we're recommending. The 4-inch is another option. We think it's going to be more difficult to construct. Which is why, again, 164 we have the two cost estimates here. As we get into the detailed engineering, and we work through some of the details around where that conduit will actually be placed, inside of a utility easement, we'll start to really understand, is the 4-inch feasible? Or is -- should we just go with the 2-inch. Our recommendation right now is the 2-inch. But I think some staff has -- some of the staff have indicated that they would like to have -- look at 4-inch as well. ### I'd like to understand more about why some staff haven't yet been convinced that 2-inch is best. ### The Upgrade Downtown project on University Avenue actually deployed a random combination of 2-inch and 4-inch PVC conduit, depending on whatever the contractor could find, so as not to slow down the overall project. Could Magellan comment on the result? ### What material will the conduit be? My understanding is that PVC is inflexible and comes in 20-foot chunks, whereas HDPE is flexible and comes on large spools. 0:56:08: Commissioner Scharff: OK. So, that's -- Some of the staff wanted the 4-inch, but you don't think there's a case for that. Is that a fair statement? 0:56:14: John Honker: We think you can achieve exactly the same goals with the 2-inch, versus the 4-inch. 0:56:18: Commissioner Scharff: And the 2-inch is cheaper than the four-inch. Is that fair? 0:56:22: John Honker: It is. Correct. 0:56:23: Commissioner Scharff: That's good for me to know. And then, the other thing is, you talk a little bit about depths. I assume the deeper you go, the more expensive? Or is that not true? 0:56:32: John Honker. It is. You know, it's not [that] magnitude's more expensive. But, you know, if we're going very deep, it's -- You know, there's more sweeps. There's more construction that has to happen. So, costs will go up. 0:56:44: Commissioner Scharff: Because you said "24-36 [inches] unless Palo Alto has a greater depth requirement." Was there any sense that Palo Alto DID have a greater depth requirement? 0:56:50: John Honker: I don't think any requirement greater than 36 [inches]. Director Batchelor, maybe you could just chime in on that. But I believe 36 [inches] was the deepest that we had to go. 0:56:59: Dean Batchelor: Yeah, it was -- 36 [inches] was the deepest. You know, there may be a few situations where we get into congestion in some of the downtown areas. Or, you know, when there are a lot of other utilities pressing in the areas which we find today with -- when we do some water or gas replacements, we may have to go a little deeper. But on average, it's usually between 24 [inches] and 36 [inches] would be fine in this project. 0:57:24: 165 Commissioner Scharff: So -- I mean, it struck me that fiber's not like water and electricity. That fiber -- That water and electricity, if you break the pipe, is more -- Especially electricity. It's more dangerous, or more -- I don't know. It doesn't seem -- Fiber seems pretty inert. You break it, you lose your fiber connection. ### IF you break a fiber cable of the proposed fiber backbone, you might break up to 576 connections. So, I guess I was wondering -- And I would assume that this congestion issue was what drives a lot of costs. So, I noticed that there's a 12-inch separation from other utilities, unless Palo Alto has a greater separation. I was assuming we don't have a greater separation. But I was wondering if the 12-inch separation is necessary. And I was also wondering if we really need to be 24 inches deep. I mean, why not be 12 inches deep? 0:58:08: Dean Batchelor: So, I think that -- One -- to answer your first question -- is, we do need that separation, because, again, there is congestion out there. So,when we start ** to get into -- Maybe there's a water break. And maybe that conduit is on that same side. So, you know, we don't want to build right on top or right on the side of it, so that we would be damaging -- or that there would be a chance that we would damage that backbone that we would be putting in the ground. Or any of the fiber that would be going into the homes -- neighborhoods. So, we do want to keep at least a 12- inch separation from any of the utilities. Since we're going to be putting this in with no joint trench, or anything like that. So, we're worried a little bit about that. We do want to keep that 12-inch. And then, I think, going to your other question -- I'm sorry. Could you repeat your second question? 0:59:01: Commissioner Scharff: Yeah. So, it says "24 to 36-inch depth unless Palo Alto a greater depth requirement. So, I guess the question was, DO we have a greater depth requirement? And, you know, is there -- If it's a question of of cost or congestion -- or maybe it doesn't matter. Is it cheaper to go less than 24 inches? Or is 24-36 inches were we need to be? You know, I'm just trying to ask myself if we could save money. If these are rules that we developed for non-fiber stuff, like water and electricity. And maybe having them in a, you know, a different placement saves money, to make the risk of its being damaged in some way worth it. Or maybe it's not. I'm just really raising that question, so that we at least think about it. 0:59:47: Dean Batchelor: So, I think that goes along with the 12-inch separation portion of it. As you well know, the sewer lines are all gravity-fed, coming from homes. So, they come at different depths into the main portions of it. So, you don't want to go right over the top, or right on top, or right on the bottom side -- depending on what side of the street. You know, we try to keep all the water, gas, wastewater on one side. We try to keep all the electric on the other side. So, there are sweeps coming in from off the electric side that are going to the secondary boxes that are going into the sidewalks. So those have a gradual slope going upward. So, we don't want to be above that, because, again, now you're only going to be maybe 12 inches above that portion of it. Could be maybe just a little lower. But, depending on how the services run on that street, they will vary depending the size, or were the water main, gas main, or where the sewer side is. Because we're not going to be able to go down the middle of the street portions of -- where the storm drains are. So, we're going to have to push them a little bit closer to the side of the streets. 1:00:53: So, that's why one of the things that we find -- like when you start doing microtrenching and things like that, when you start having to dig up those services, you're going to to have to rip those -- that fiber -- conduits apart, because they're going to be at a surface level of maybe 8-12 inches. Which is too shallow. So, we're looking for trying to stay somewhere in that middle. And that it doesn't have any kind of influx with one of the other services that we have already in the streets. 1:01:26: Commissioner Scharff: OK. That was very helpful. And then, the last question was about the aerial versus the underground. I noticed we're going to do about 65 percent underground and 35 percent aerial construction. And I guess that confused me, because it seemed to me that most of Palo Alto has poles, and you could do aerial if you wanted to, if it was cheaper. I saw there were some cons about splicing into it. ### I don't understand this point. 166 But I guess I was confused about how we came up with that number, and why we don't think aerial would be cheaper. And do more aerial. ### Great question. In the 2002-2004 FTTP study, it was assumed that fiber for FTTP would be deployed where the electric was deployed, i.e., fiber would be aerial where electric was aerial, and fiber would be undergrounded where electric was undergrounded. And the study said that would mean that fiber was 70 percent aerial and 30 percent undergrounded. (I suspect that these percentages were "rounded.") Since then, more undergrounding has occurred. Anyhow, has that policy changed? ### I believe that the City has not always followed this policy for the dark fiber network. That is, it has deployed fiber underground in areas where the electric is aerial. Why did staff do that? ### Now that we're talking about where to put BOTH a new fiber backbone AND new fiber for FTTP -- on the same side of the street as existing electric and existing dark fiber -- what should the policy be? 1:02:00: Dean Batchelor: Well, I think that -- as John was mentioning at the very front of this -- when we looked at the backbone, you know, we were trying to look at for the future set-up of going fiber-to-the-home. As you well -- As he mentioned, our existing backbone that we have today is in the main thoroughfare. It really doesn't go into the neighborhoods. So we can take advantage of building this new backbone. And take advantage of going deeper into the neighborhoods. So, we have about 6,500 aerial poles throughout the system. And I believe that the backbone will touch about 3,000 poles -- 2,500 poles -- somewhere around there. And so, the idea was, you know, that we wouldn't have to go so much further with building this backbone, because it's carrying some of the future -- um -- for fiber-to-the-home. 1:02:57: Commissioner Scharff: OK. All right. Thanks. 1:03:02: Chair Forssell: I think I saw Vice Chair Segal has a question. 1:03:04: Vice Chair Segal: Yeah. I just wanted to follow up on the 4-inch / 2-inch question. If Magellan is recommending 2-inch, but you said staff was concerned, and was thinking about 4-inch, what is that concern? And are we -- you know, is there anything that we would be giving up in the future -- or having to possibly dig in the future -- if we went with the 2-[inch]? 1:03:31: John Honker: Sure. I can answer that, Commissioner Segal. The -- What we heard from staff was that they wanted to have enough space in exist- -- in the 4-inch to be able to kind of back-feed fiber. So, to be able to kind of re-feed fiber into the same conduit for different purposes. But when we look at that, the -- Usually, you are only that in sort of a legacy network. Right? Where you HAVE to do that. In the new backbone, everything is effectively preconfigured. So, you're really not going to have to back-feed fiber in the same conduit. And if you even needed to, you have the two additional spare 2-inch conduits, which you can use to do -- to accomplish the same feat. We don't like the idea of back-feeding fiber in-conduit unless you absolutely have to do it. And we've all done it. We've worked on many city networks where they have to do it, because that's just what they have to work with. But when you're designing a new network, you want to try to eliminate that. You want to design the network for all the capacity that is needed, you know, now and into the future. So you're not sort of re-using the same conduit twice for the same purpose. 1:04:42: Vice Chair Segal: OK. So, possibly, the ten miles that are already in existence, that are overlapping, might have that need -- versus the new? Is that what you're saying? 1:04:52: John Honker: Um. Well, the existing network ar- -- Yeah. I think -- I think we're saying the same thing. So, basically, where those -- where that overlap is happening, you know, some of that existing Palo Alto network is basically 167 congested. Right? Meaning that you're running out of capacity. And that's where that sort of back-feeding has to happen. So, the new network is going to basically take any of that -- um -- and eliminate it going forward. Right? Meaning you're not going to have to sort of duct-tape the network together to make it work. You're going to have the capacity that you need to sort of deploy the "right" way. And the old way wasn't the "wrong" way, it's what you guys had. It's the fiber network that was built. And, you know, it's done a number of things over the last 25 years. And you just had to work with what you had. But now, you know, when you're looking at network design, the goal is to equip the network with enough capacity so all the routes are -- all the fiber is utilized. And is utilized in the same way. And you don't have sort of rig the network to be able to accomplish what you need. ### I don't think he meant to say that the goal was that "all the fiber is utilized." The goal, for dark fiber networks, is always to have more fiber strands available if needed. 1:06:04: Vice Chair Segal: OK. Got it. And then, the only other question was, while we're digging, if there's any other work, laying any other pipes -- "purple pipes" -- whatever it might be -- so that those are laid for the future, so we're, you know, really living to our "dig-once" policies. Or even, you know, looking forward to not having to dig in the future. ### The City's current policy is that undergrounded fiber will go on the same side of the street as undergrounded electric, but water and gas will be on the other side of the street. 1:06:33: John Honker: Sure. I think we definitely have the opportunity to do that. As we get into the detailed engineering design, all the routes will be out there, so if there's an opportunity to put another utility alongside the fiber, and it's cost-effective, then we'll definitely work on that. 1:06:55: Commissioner Smith: John, if -- I have a couple of questions. Follow-up on this distribution. Will a 432-strand fit within a 2-inch comfortably? 1:07:06: John Honker: Yeah. Very comfortably. 1:07:08: Commissioner Smith: More than one? Or ONLY one? 1:07:10: John Honker: You could get two in a 2-inch cable -- uh -- 2-inch pipe if you needed to. ### The plan proposed in the staff report was to fit one 432-strand cable and one 144-strand cable (and that's all) in one conduit, both installed at the same time. Right? 1:07:15: Commissioner Smith: OK. Second question. When we had talked about this -- this distribution -- we looked at the possibility -- or, I believe we looked at the possibility -- we certainly asked the question -- about using abandoned pipe. Abandoned gas pipe. Is that something that happens in detailed engineering? Or is that something that is only related to fiber-to-the-home? Or is that something that would be considered for the initial dark fiber expansion? 1:07:42: John Honker: Yeah. Thanks, Commissioner Smith. So, what we did is, we looked at those really important opportunities to use it. Wherever you had a crossing that's expensive to get under, like the highway, the railroads, we used the abandoned gas. And we're going to use that pipe to avoid a lot of cost. To use it generally, along running lines, there are challenges getting in and out of that pipe. Because we're going to actually put another pipe INSIDE that pipe to run the c- . So we still have to -- We can't put the fiber directly in the pipe. We still have to put a conduit in that pipe, to protect the 168 fiber. Right? Because it -- We don't know the condition -- if part of it's collapsed -- if the wall are, you know, shaky. So, we still have to protect the fiber. So, you know, as we looked at that, and as we looked at the routes, we realized that, hey, this MIGHT save in cost, and in some cases, it might actually increase the cost. Because, as we try to get into that infrastructure, we need to pop in and out at different points. And where -- especially with fiber-to-the-home, you need a lot of access in and out of the network. Right? Because you're splicing in neighborhoods. You're splicing in streets. And, to use that infrastructure for fiber-to-the-home -- We feel it's best to -- to go through that in the detailed engineering, because then we can actually identify what points that we'll need to get -- come in and out of that infrastructure. And we can assess the cost of using it, versus the cost of not using it. So, that would be something that we would do -- You know, again, for the backbone, we're going to use it where those crossings -- those high-cost crossings exist. And then, for fiber-to-the-home, in detailed engineering, we'll do a value assessment on on how much of it could be used. 1:09:28: Commissioner Smith: Great. My last question -- and this is related to an earlier comment about the storm sewer. So, Dean Batchelor, our head of Utilities, was talking about storm sewer down the middle of the street. And in my own neighborhood, we just literally replaced the whole middle of the street. So, it's BIG. And one of the options that is -- that was presented to me over the course of the last six months -- and looking at fiber and fiber distribution -- was a unique product called CableRunner. ### https://cablerunner-usa.com/ And, essentially, it runs fiber in storm sewer and drain. Via -- They use a robot to do the installation. But it is literally - - They run the fiber down the sewer, in some type of raceway that is protecting .... 1:10:17: John Honker: Yeah. 1:10:17: Commissioner Smith: Is that something that you have experience with? 1:10:19: John Honker: We do. You know, we have a couple of customers that have used it. Or, not -- They haven't used that technology specifically. But we've actually installed fiber in storm drains. And in sewer mains. Or, not sewer mains. Water mains. We've installed inside water mains. But, again, it's where you have really long runs. So, if you need to get from one side of the City to the other side of the City, in a 60-inch water main, it makes a lot of sense. But if you have to come in and out of that water main, the integrity of the main's at risk. And every time there's an issue, you have to dig up, and you have to dig around that main. That main may be six feet down. So, if there's an issue, you may be -- your costs for maintaining that fiber may be considerably higher than if you're just building it new. So, the other issue is, with the water mains, if you're doing a water repair, all of a sudden, you have the fiber to deal with. 1:11:17: Commissioner Smith: Yes. It's harder. Understood. 1:11:18: John Honker: There's a lot of challenges. Again, we've found some good opportunities to do it where there's a large -- like a gravity main that we can attach the pipe to the under- -- the inside top of the pipe. But it's only been on like long runs. Like 5-10-mile runs, where you don't have to access it. You know. New mains, that have been installed. There's not going to be new valves installed. There's not going to be dig-ups. So, yeah, we -- those have been the use cases we've seen. 1:11:45: Commissioner Smith: Thank you. Appreciate that. 1::11:47: 169 John Honker: You're welcome. 1:11:55: John Honker: If there aren't any further questions, we can move to fiber-to-the-home. ### Continued in Part 2. 170 Baumb, Nelly From:Jeff Hoel <jeff_hoel@yahoo.com> Sent:Thursday, May 13, 2021 5:17 PM To:Council, City; UAC Cc:Hoel, Jeff (external) Subject:TRANSCRIPT & COMMENTS (Part 0) -- 04-21-21 UAC mtg -- FTTP CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Council members and Commissioners, Please make progress on bringing citywide municipal FTTP to Palo Alto. Please see more comments below. Thanks. Jeff =================== Jeff Hoel 731 Colorado Avenue Palo Alto, CA 94303 =================== ######################################################################################## Here's a transcript of UAC's 04-21-21 meeting, Item VII.7, which was about FTTP and related issues. Due to the limitations of my environment, I have broken the message into four email parts. Part 0 is my top-level comments. Parts 1, 2, and 3 are the actual transcript (with my detailed comments). ######################################################################################## COMMENTS: 1. I agree with the spirit of UAC's recommendation to Council -- which I think is: get FTTP moving ASAP. 2. According to UAC's official draft minutes for 04-21-21, here's what UAC's recommendation to Council is (highlighted in yellow): ACTION: Commissioner Scharff moved staff recommendation That's not exactly true. At staff's suggestion, Commissioner Scharff agreed to have the staff recommendation displayed on the screen, as a starting point. But UAC spent a long time wordsmithing (from 3:06:21 to 3:42:34), to come up with the final wording of their own recommendation. that the Utilities Advisory Commission (UAC) recommend the City Council: This line, copied from the staff recommendation, should just be deleted. It's not part of the UAC recommendation. Maybe there should be a line that says: "The Utilities Advisory Commission (UAC) recommends to Council:" 1) Build out fiber backbone in a manner designed to support city-wide FTTH -- 171 2) Establish city-operated ISP to offer city-wide FTTH service within five years Longmont, CO, built out citywide municipal FTTP in 3 years, despite the fact that they couldn't do construction during their winters and their soils are rockier. I don't think UAC spent much time asking staff why it should take longer than 3 years in Palo Alto. Council could consider doing that. 3) Accelerate and complete community education and engagement regarding FTTH 4) By March 31, 2022; a) Combine and complete Magellan phases 2 and 4 I'd like Council to consider directing staff and Magellan to consider an approach where the FTTP distribution network is designed first, and is designed to meet the City's requirements for not only FTTP but also AMI, SCADA, and whatever else staff can convince Council is necessary, and only then design a lean-and-mean backbone to support what the FTTP network needs. b) Complete detailed city-operated ISP model (include mix of insource and outsource functions) I agree with UAC: don't consider public-private partnership models any more. c) Complete customer analysis UAC's recommendation (at 3:41:27) said this point was, "Complete customer survey." (But I don't disagree that the survey should be analyzed.) UAC agreed with Andy Poggio (at 0:04:22) (and so do I) that the community education must precede doing the survey. d) Complete risk analysis e) Determine best financing mode (including availability of federal and state grant funding options) The staff report brought no information about financing alternatives to the 04-21-21 UAC meeting, so UAC didn't seriously consider this topic. In 2004, staff raised some concerns about many of the financing alternatives considered then, and that derailed the FTTP effort then. Did we learn anything ? What's different now? 3. When the presentation said (at 2:27:26) that in Palo Alto, citywide municipal FTTP could break even with a take rate of 24 percent, that was a real revelation and breakthrough. It means that staff and consultant Magellan Advisors estimate that citywide municipal FTTP in Palo Alto is feasible. At Council's 09-28-15 meeting, Council considered a staff report (347 pages!) https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/reports/city-manager-reports-cmrs/year- archive/2015/id-6104-fttp.pdf that said citywide municipal FTTP in Palo Alto would require a take rate of 72 percent. Or, if the City "subsidized" FTTP with money from the Fiber Fund, it would require less (see PDF page 163) For each $5 million in "subsidy," the required take rate would be reduced by 3.8 percent. So, if the "subsidy" were $20 million, the required take rate would be 56.4 percent. (Or if the "subsidy" were $30 million, the required take rate would be 49.8 percent. But the report didn't mention this.) Staff said that it was infeasible to achieve the required take rate, so the City should not move forward with FTTP. Council asked for more information, but was told that the consultant considered it to be proprietary. But Council wanted staff to come up with something. So staff came up with the fiber-to-the-node (FTTN) concept: build a fiber backbone to a number of "nodes" and hope that a private-sector partner would emerge with the financial resources to use that backbone to implement citywide FTTP. Later, staff morphed the FTTN concept so that the backbone could support not only FTTP but also a bunch of other things that the City "needed" -- AMI, SCADA, etc. I think that if Council had been told on 09-28-15 that FTTP was feasible, it would have chosen to proceed with FTTP, and it would not have asked for or been distracted by FTTN. 4. Citywide FTTP requires a distribution network which passes every premises in town and allows any premises in town to connect to a substation. It also requires a way for substations to connect to each other and to a central office. Staff says FTTP needs a "backbone" to do that. But I think it doesn't necessarily need a "fancy" backbone (at a cost of $22 million to $28 million) that can also do AMI, SCADA, etc. 172 How many FTTP substations should there be? If, for example, nine are enough, why not put them at the City's nine electric substations, which are already connected to the City's dark fiber network? Or, if staff doesn't like those places, let them pick nine other places -- ideally close to dark fiber network nodes. For any telecom function you can name, the FTTP network is a better place to put it than a backbone. Because the FTTP network is designed to be connected to easily and inexpensively. For most functions, a lit FTTP connection is more than adequate. For functions that "need" a dark fiber connection, put some extra dark strands into the FTTP network for this purpose. ######################################################################################### Video: https://midpenmedia.org/utilities-advisory-commission-31-4212021/ Staff report: https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2021/04-21-2021-special/id-12118-item-no-1.pdf 173 Baumb, Nelly From:Russell Hancock <hancock@jointventure.org> Sent:Thursday, May 13, 2021 3:54 PM To:Hancock, Russell Subject:Please join us May 18 for the next Joint Venture Roundtable, with Gary Dillabough CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Hello Silicon Valley Elected Officials: I'm writing to let you know how welcome you are to join us for the next Joint Venture Roundtable, happening this coming Tuesday May 18 at noon. The Roundtable features Gary Dillabough, founder and CEO of Urban Community and he'll be talking about new visions for sustainable urban design. The details are copied below. Just a word of background: Joint Venture roundtables are for the Joint Venture Silicon Valley board of directors and our invited guests. Often they feature our own board members talking about their work, and that is the case with Mr. Dillabough next week. Just as often, they feature national figures and thought leaders. They are an opportunity for being briefed on topics of regional significance, being exposed to cutting edge thinking, and for having dialogue and discussion with our expert guests. The invitation I shared with the Joint Venture board is below, and it contains more information and the pertinent zoom details. Please feel warmly welcome to join us. Yours, Russell Hancock President & Chief Executive Officer Joint Venture Silicon Valley Silicon Valley Institute for Regional Studies * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * Hello Joint Venture Board and Senior Advisory Council: I'm delighted to announce our next online Roundtable will be Tuesday May 18 at noon and that our featured speaker is Gary Dillabough, founder and CEO of Urban Community. Gary will talk expansively and in a personal way about his vision for sustainable urban design. He'll also talk about his passion for using architecture and planning as tools for creating community. The zoom details (and a link to register) are at the bottom of this message. We'll be listening to Gary at an auspicious moment in time: though the pandemic caused some to question the wisdom of dense urban living, scholarship and popular opinion most recently see cities as ripe for rebirth. The virus presents an opportunity to re-imagine them 174 as new engines of innovation and economic growth, as vibrant cultural centers, as a place to address social inequities, and as the most sustainable way to house people. Against this conceptual backdrop stands San Jose, a metroplex expected to have the fastest growing post-pandemic economy, driven by a rich tech ecosystem. The city's downtown is undergoing profound expansion and change, presenting ripe opportunities for community building, and this is where Gary's work is taking dead aim. He'lll talk about all of it and invite dialogue and discussion. Please register by following the link below, and by all means share the invitation with others you would like to introduce to Joint Venture. Yours, Russ * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * You are invited to a Joint Venture Silicon Valley Roundtable, via Zoom: "New Models for Sustainable Urban Development and Building Community" with Gary Dillabough, Co-Founder and CEO, Urban Community When: Tuesday May 18, 2021 12:00 to 1:00 PM Pacific Time (US and Canada) Register in advance for this meeting: https://zoom.us/meeting/register/tJIpf-CgpjMvG9WgMcxzf-c9RacSgKVDf3uo After registering, you will receive a confirmation email containing information about joining the meeting.   ........................................................... Russell Hancock President & Chief Executive Officer  Joint Venture Silicon Valley  Silicon Valley Institute for Regional Studies  84 West Santa Clara Street, Suite 800  San Jose, California 95113  (408) 499-8040 www.jointventure.org        1 Baumb, Nelly From:Minor, Beth Sent:Tuesday, May 18, 2021 3:45 PM To:Laura Beaton; Clerk, City; Council, City Cc:Neilson Buchanan Subject:RE: May 18, 2021 City Council Meeting - Agenda Item 1 Hi Laura,  We will include it.    Thanks and stay healthy.      BETH MINOR  City Clerk  (650)329‐2379 | Beth.Minor@cityofpaloalto.org   www.cityofpaloalto.org                         From: Laura Beaton <Beaton@smwlaw.com>   Sent: Tuesday, May 18, 2021 3:43 PM  To: Clerk, City <city.clerk@cityofpaloalto.org>; Council, City <city.council@cityofpaloalto.org>  Cc: Neilson Buchanan <cnsbuchanan@yahoo.com>  Subject: May 18, 2021 City Council Meeting ‐ Agenda Item 1    CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Clerk,    I noticed today that my May 13, 2021 email transmitting my letter regarding 955 Alma on behalf of Neilson Buchanan  was included in the Public Comment file for that agenda item, but my actual letter was not included.  Please ensure that  my actual letter, which is attached here again for your convenience, is provided to the Council in advance of the  meeting today, and is included in the public comment record for this project.    Thank you so much for your prompt attention to this matter.    Best,  Laura Beaton        • 3 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Tuesday, May 18, 2021 7:48 AM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: ‘Go Back to China!’: Real Estate Agent Loses Job After Racist Rant Caught on Camera CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From: Allan Seid <allanseid734@gmail.com>  Date: Tue, May 18, 2021  Subject: ‘Go Back to China!’: Real Estate Agent Loses Job After Racist Rant Caught on Camera    https://nextshark.com/gym‐manager‐real‐estate‐agent‐fired‐nyc/  ‘Go Back to China!’: Real Estate Agent Loses Job After Racist Rant Caught on Camera A real estate agent living in Brooklyn, New York is now out of work after telling an Asian gym manager to “go back to China.” The incident, which was caught on video, occurred at a Blink Fitness outlet in the neighborhood of Bushwick. 4 Image Screenshot via @asianswithattitudes The video, which went viral on social media, shows the real estate agent allegedly refusing to wear a mask inside the gym. “He threw his mask on the floor and proceeded to be extremely racist to the manager, who is by the way the nicest man,” wrote TikTok user @bobrosspoop, who filmed the incident. 5 Image Screenshot via @asianswithattitudes In the video, the real estate agent tells the gym’s Asian manager to “go back to China, that’s what you need to do.” He then walks away while appearing to make a call on his phone. • 6 Image Screenshot via @asianswithattitudes Yang Chen, an acquaintance of the gym manager, reposted the video on Instagram to help raise awareness of the recent increase in anti-Asian crimes. Chen, who has experienced racist attacks, wants perpetrators to be held accountable. “I can vouch that he is a very kind and generous man who would never go out his way to hurt somebody. He deals with everything in a professional manner,” Chen told NextShark. “So when I saw this video, I did not need to know the background story to figure out that he was in the right… I want people to know that these forms of hate crimes aren’t always made public. In fact, I’ve had people verbally harass me on trains and even attempt to spit on me due to the fact that I was Asian.” 7 Yang revealed in a tweet that the attacker had been fired by his employer. Thank you everyone! I’ve taken down my original post due to the amount of dms I’ve been getting (I get anxiety when a lot of strangers approach me at once) #StopAsianHateCrimes #StopAAPIHate if it wasn’t for social media we wouldn’t have found this person and gotten these results pic.twitter.com/HVqd1V1Hl9 — Master Yang (@Masteryangcheee) March 8, 2021 “We wanted to let you know that the affiliated Century 21 office has terminated this agent. We do not take this behavior lightly and will always work to ensure that we are properly addressing this type of behavior across Century 21 and our independent brokers’ offices,” a message from Century 21 reportedly said. Meanwhile, Blink Fitness commended the professionalism of the gym manager and affirmed its stance against anti-Asian violence. “At Blink Fitness, we applaud the professionalism our employee showed in the face of such a blatant racist attack. Our gyms were founded on the idea of bringing fitness to everybody, and the comments by the individual featured in this video in no way represent the views of Blink Fitness or the diversity and inclusivity that we value at our gyms,” a statement from Blink Fitness sent to NextShark read. It added, “Blink Fitness stands in solidarity with the #stopasianhate movement and will continue to support our employees and members of color in creating a respectful, welcoming environment. We do not and will not tolerate displays of racism or hatred in any of our gyms.” Feature Image Screenshots via @asianswithattitudes 8 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Wednesday, May 12, 2021 5:19 PM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: MAY 7, 2021 FRIDAY REMEMBERING MAMAS TODAY - allanseid734@gmail.com - Gmail CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From: Allan Seid <allanseid734@gmail.com>  Date: Wed, May 13,2021  Subject: VIRTUAL AUTHOR EVENT: JEANNETTE ARAKAWA MAY 27, 2021  Virtual Author Event: Jeanette Arakawa Next date: Thursday, May 27, 2021 | 07:00 PM to 8:30 PM Join us for virtual author event with Jeanette Arakawa, as she discusses her autobiographical novel, The Little Exile, based on her own experience as an internee in the 1940s at the Rohwer War Relocation Center in Arkansas. Her experience helped shape her advocacy and work in the Bay Area, in particular working with Asian Americans for Community Involvement (AACI). Jeanette donated free copies of her book, and they will be available on May 11 at the Mitchell Park and Rinconada Libraries, will supplies last. This author event is sponsored and 9 hosted by The Bill Lane Center for the American West of Stanford University. We're pleased to have our City Manager, Ed Shikada, moderating this discussion! Register Online\ When ---- Thursday, May 27, 2021 | 07:00 PM - 08:30 PM Contact RuthAnn Garcia ruthann.garcia@cityofpaloalto.org 10 Baumb, Nelly From:John Bae <byul1999@gmail.com> Sent:Wednesday, May 19, 2021 10:28 AM To:Council, City Subject:Channing house noise! parking space! trashing areas CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Hello,     My name is John and Sarah Bae, residents of Palo Alto.  We are having extreme difficulty due to Channing house.  Our neighbors even put signs on the street. "No parking by Channing house employees".    I am begging you to take this case as a priority.   It is impacting hundreds of residents and I am taking my time to drive this issue.    1. Noise: construction, trucks honking, junk yard grinding noise.  2. Parking space taken away by their trucks, their employees  3. Trashing areas, their trash is all over the place.    4.  Their employees are smoking area in NO SMOKING Zone        Regards,  John Bae  11 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Wednesday, May 19, 2021 6:48 AM To:Allan Seid Subject:Fwd: Asian Hate CRIME bill APPROVED BY CONGRESS; AWAITS PRESIDENT'S SIGNATURE CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.          From: Allan Seid <allanseid734@gmail.com>  Date: Wed, May 19, 2021   Subject: Asian HATE CRIME BILL APPROVED BY CONGRESS; AWAITS PRESIDENT'S SIGNATURE  SOURCE: S.J. MERCURY        https://mercurynews‐ca.newsmemory.com/eebrowser/ipad/html5.check.21030914/  Mercury News By Brian Slodysko The Associated Press WASHINGTON >> Congress approved legislation Tuesday intended to curtail a striking rise in hate crimes against Asian Americans and Pacific Islanders, sending President Joe Biden a bipartisan denunciation of the spate of brutal attacks that have proliferated during coronavirus pandemic. The bill, which the House passed on a 364-62 vote, will expedite the review of hate crimes at the Justice Department and make grants available to help local law enforcement agencies improve their investigation, identification and reporting of incidents driven by bias, which often go underreported. It previously passed the Senate 94-1 in April after lawmakers reached a compromise. Biden has said he will sign it. 12 "Asian Americans have been screaming out for help, and the House and Senate and President Biden have clearly heard our pleas," said Rep. Grace Meng, DN.Y., who helped lead efforts to pass the bill in the House. To many Asian Americans, the pandemic has invigorated deep-seated biases that in some cases date back to the Chinese Exclusion Act of more than a century ago. President Donald Trump repeatedly referred to the virus, which emerged in Wuhan, China, as the "China Virus" or the "Kung Flu." And as cases of the illness began to rise in the U.S., so too did the attacks, with thousands of violent incidents reported in the past year. Rep. Judy Chu, D-Calif., said it's painful for many to "open up the newspaper every day and see that yet another Asian American has been assaulted, attacked and even killed." In February, an 84-year- old man died after he was pushed to the ground near his home in San Francisco. A young family was injured in a Texas grocery store attack last year. And in Georgia, six Asian women were killed in March during during a series of shootings targeting workers at massage parlors. Prosecutors are seeking hate crimes charges. The women who were killed are mentioned in the text of the bill. " You start to think, 'Well, will I be next?' " Chu said. Yet to some activists, including organizations representing gay and transgender Asian Americans, the legislation is misguided. More than 100 groups have signed onto a statement opposing the bill for relying too heavily on law enforcement while providing too little funding to address the underlying issues driving a rise in hate crimes. House Speaker Nancy Pelosi listens during a news conference in Washington on Tuesday on the COVID-19 Hate Crimes Act. SUSAN WALSH — THE ASSOCIATED PRESS 13 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Tuesday, May 18, 2021 10:18 PM To:Joe Simitian; supervisor.ellenberg@bos.sccgov.org; Jeff Moore; Jeff Rosen; Raj; Council, City; city.council@menlopark.org; Jay Boyarsky; Planning Commission; Human Relations Commission; chuck jagoda; wilpf.peninsula.paloalto@gmail.com; Roberta Ahlquist; cindy.chavez@bos.sccgov.org; Anna Griffin; CA18AEima@mail.house.gov; Jack Ajluni; Lewis. james Subject:Democrats Pressure Biden on Israel as the party takes a Skeptical Stance ( about time)!!!!!! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    https://www.nytimes.com/2021/05/17/us/politics/israel‐gaza‐democrats‐biden.amp.html      Sent from my iPhone  14 Baumb, Nelly From:Rebecca Eisenberg <rebecca@winwithrebecca.com> Sent:Tuesday, May 18, 2021 7:19 PM To:Council, City; Clerk, City Subject:I'm here! You did not give me the unmute option!! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  I'm here! Please try again to unmute me!  Thank you!  15 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Tuesday, May 18, 2021 6:56 PM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: [chbb850] Tomorrow — “Documenting Hate, 2021: From the Capitol Riot to Anti-Asian Violence” CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From:  Allan Seid'  Date: Tue, May 18, 2021  Subject: [chbb850] Tomorrow — “Documenting Hate, 2021: From the Capitol Riot to Anti‐Asian Violence”  Source: PROPUBLICA    To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.ProPublica    Donate Hi Reader, From the January insurrection at the U.S. Capitol — which had ties to far-right extremist groups, as examined in a documentary from ProPublica and PBS Frontline — to the surge of hate crimes against Asian Americans, hate is on the rise in America. Last year, ProPublica concluded a three-year project called Documenting Hate, which addressed one of the most urgent and least understood corners of America’s criminal justice system: hate crimes. The project brought clarity to what hate crimes are; who perpetrates them and who is victimized by them; as well as why they are so poorly understood, investigated and prosecuted. Join ProPublica tomorrow for a virtual event: Documenting Hate, 2021: From the Capitol Riot to Anti-Asian Violence Wednesday, May 19 | 3:30-4:30 p.m. ET   Register Here  16 In a conversation moderated by ProPublica reporter A.C. Thompson, members of our panel will share their perspectives on tackling hate crimes and hate groups in 2021. With a focus on California, which has seen the most arrests from the Capitol riot, along with a high increase of anti-Asian violence this past year, experts will explore new waves of white supremacist groups and anti-Asian hate, interracial tensions beyond the Black-white racial binary, and the work they’re doing to examine, track and address these issues. We will also expand the discussion to broader narratives of hate across the country — and you’ll have the opportunity to ask your questions. Speakers include:  Damon T. Hewitt, acting president and executive director of the Lawyers’ Committee for Civil Rights Under Law  Aarti Kohli, executive director of Advancing Justice – Asian Law Caucus  Marshall Wong, senior intergroup relations specialist for the Los Angeles County Commission on Human Relations Hope you can join us, Simon Tran Proud ProPublican Supported by McKinsey & Company Learn more about event sponsorship opportunities.       17 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Tuesday, May 18, 2021 4:44 PM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: Wes is being honored! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From: Allan Seid, Michele Lew  Date: Tue, May 18, 2021 at 8:53 AM  Subject: Wes Mukoyama is being honored.    Hi all ‐ Wes Mukoyama is being recognized by Assemblymember Alex Lee on Thursday May  27th from 6 pm ‐ 7 pm.  You can register using the link below.     https://caasm.zoom.us/webinar/register/WN_Bc4vYDXkQNa0UklAUdYFyw  18 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Tuesday, May 18, 2021 4:37 PM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: The House Passes Anti-Asian Hate Crimes Bill - The New York Times CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.      From: Allan Seid <allanseid734@gmail.com>  Date: Tue, May 18, 2021   Subject: The House Passes Anti‐Asian Hate Crimes Bill ‐ The New York Tim      https://www.nytimes.com/2021/05/18/us/house‐anti‐asian‐hate‐crimes‐ biden.html?campaign_id=60&emc=edit_na_20210518&instance_id=0&nl=breaking‐ news&ref=cta&regi_id=153784146&segment_id=58386&user_id=3a475fdd7467e9084870aed2962b9a2 b  The House passes an anti‐Asian hate crimes bill, clearing it for Biden’s signature. May 18, 2021, To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.Representativ e Grace Meng (D-N Y), left, speaks during a news conference on the Stop Asian Hate Bill at the U.S. Capitol in Washington on Tuesday. Representative Grace Meng (D-NY), left, speaks during a news conference on the Stop Asian Hate Bill at the U.S. Capitol in Washington on Tuesday.Stefani Reynolds for The New York Times The House overwhelmingly passed legislation on Tuesday aimed at strengthening federal efforts to address hate crimes directed at Asian-Americans, clearing the measure for President Biden’s signature. The bill, approved in a 364-62 vote, is the first legislative action that Congress has taken to bolster law enforcement’s response to attacks on people of Asian descent amid an uptick in discrimination and violence against Asian-American communities during the pandemic. 19 “The Asian-American community is exhausted from being forced to endure this rise in bigotry and racist attacks,” said Representative Grace Meng, Democrat of New York. “Asian-Americans are tired of living in fear.” The measure, led by Ms. Meng and Senator Mazie Hirono, Democrat of Hawaii, would establish a position at the Justice Department to expedite the agency’s review of hate crimes and expand the channels to report them. It would also encourage the creation of state-run hate crime hotlines, provide grants to law enforcement agencies that train their officers to identify hate crimes and introduce a series of public education campaigns around bias against people of Asian descent. The bill was also approved by an overwhelming margin in the Senate, with only Senator Josh Hawley, Republican of Missouri, opposing it. He argued that it mandated an overly expansive collection of data around hate crimes that could slide into government overreach. In the House, 62 Republicans opposed it. Mr. Biden last month pledged to swiftly sign the legislation when it reached his desk, hailing it as putting “our nation one step closer to achieving justice and equality.” “For more than a year, far too many Asian Americans have woken up each morning increasingly fearful for their safety and the safety of their loved ones,” Mr. Biden said. “They have been scapegoated, harassed, and assaulted; some have even been killed.” Catie Edmondson is a reporter in the Washington bureau, covering Congress. @CatieEdmondson 20 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Tuesday, May 18, 2021 1:48 PM To:Joe Simitian; CA18AEima@mail.house.gov; Human Relations Commission; Council, City; chuck jagoda; Planning Commission; Jeff Moore; Jeff Rosen; wilpf.peninsula.paloalto@gmail.com; Roberta Ahlquist; city.council@menlopark.org; ParkRec Commission; Raj; Molly; michael.gennaco@oirgroup.com; Lewis. james Subject:Palestinians Rally New Support as Arab Street Moves to Web CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    https://www.nytimes.com/2021/05/18/world/middleeast/palestinian‐arab‐protest‐internet.amp.html      Sent from my iPhone  21 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Tuesday, May 18, 2021 1:31 PM To:Joe Simitian; supervisor.ellenberg@bos.sccgov.org; Jeff Moore; Jeff Rosen; Raj; Council, City; city.council@menlopark.org; Jay Boyarsky; Planning Commission; Human Relations Commission; chuck jagoda; wilpf.peninsula.paloalto@gmail.com; Roberta Ahlquist; cindy.chavez@bos.sccgov.org; Anna Griffin; CA18AEima@mail.house.gov; Jack Ajluni; Lewis. james Subject:Democrats Pressure Biden on Israel as the party takes a Skeptical Stance ( about time)!!!!!! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    https://www.nytimes.com/2021/05/17/us/politics/israel‐gaza‐democrats‐biden.amp.html      Sent from my iPhone  22 Baumb, Nelly From:Ann Balin <alafargue@mac.com> Sent:Tuesday, May 18, 2021 11:40 AM To:Council, City Subject:NYTimes: Investors Put Millions Into a Luxury Student Dorm. They Say They Were Ripped Off. CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Investors Put Millions Into a Luxury Student Dorm. They Say They Were Ripped Off.  https://www.nytimes.com/2021/05/18/business/dorm‐investors‐hedge‐fund.html?referringSource=articleShare      Sent from my iPhone  23 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Tuesday, May 18, 2021 7:50 AM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: A.G. BONTA HAS POWER TO REFORM POLICE CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    ‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐  From: Allan Seid <allanseid734@gmail.com>  Date: Tue, May 18, 2021 at 5:07 AM  Subject: A.G. BONTA HAS POWER TO REFORM POLICE  To: Allan Seid <allanseid734@gmail.com>        https://mercurynews‐ca.newsmemory.com/eebrowser/ipad/html5.check.21030914/  Mercury News By Jim Gonzalez When it comes to policing the police, state law invests the California attorney general with powers that can only be described as awesome. Now, in the wake of the successful Minnesota prosecution of the cop who murdered George Floyd last year, it is time for California's AG to use his authority to extinguish the same kind of racist atrocities in this state. Our new attorney general, Rob Bonta, sounded in his recent confirmation hearings like he is up to the task, ready to implement new laws to check abusive cops. The fact is, he already has plenty of power at his disposal. California's Constitution gives him "direct supervision over every district attorney and sheriff" in "all matters pertaining to the duties of their respective offices." These "matters" must include investigations of cops who act with impunity. 24 The attorney general's authority also positions him to break up the politically cozy relationships between local prosecutors and police unions that might sabotage aggressive pursuits of credible allegations of police abuse. Additionally, our government code gives Bonta the power to "take full charge of any investigation or prosecution" within Superior Court jurisdiction - with no disclaimer that says "except in cases where the accused wears a badge." Bonta needs to put out an information bulletin to let every cop in the state know that the days of police abuse are over. We know what state attorneys general can do to achieve justice in police abuse cases. In the Floyd killing, Minnesota Attorney General Keith Ellison took the case away from local prosecutors and gained the murder conviction against former Minneapolis police Officer Derek Chauvin. There's nothing stopping Bonta from exercising the same righteous judgement and muscle here. We have every confidence that Bonta meant it when he said that public trust in the police depends on holding them accountable for officer wrongdoing. Toward that end, the Legislature last year passed Assembly Bill 1506 by Assemblyman Kevin McCarty, D-Sacramento, to create a new AG police deadly force investigation division. It was gratifying to hear Bonta prioritize the need to jump- start that unit. We were further heartened by Bonta's announcement Thursday that his office would independently review last year's fatal shooting of Sean Monterrosa by the Vallejo Police Department - after Solano County's elected district attorney backed away from the case. Unfortunately, the Legislature watered down the division's AB 1506 authority before it investigated a single case. The enabling legislation signed by Gov. Gavin Newsom only requires that the unit investigate fatal officer-involved shootings of unarmed civilians. Before the amendment, the bill covered all police use of force cases where civilians died. Ironically, in its amended form, the unit would not have rolled out on Floyd's death. Nor will it be required to investigate the April 19 death of Mario Arenales Gonzalez, who stopped breathing during a police encounter in Alameda. 25 Under AB 1506, Bonta will only be required to investigate the 40 or so fatal police shootings of unarmed civilians that happen every year on average in California. But under his already-authorized powers, he will still be allowed to investigate and, if necessary, prosecute all officer-involved killings, period. Of course, California is in dire need of other police reforms - mainly, the decertification of bad cops. But when it comes to police accountability, the brave exercising of the attorney general's power stands as the best path for California citizens to expect results. As the state's top cop, Bonta needs to put all police jurisdictions on notice that he will vigorously prosecute anyone with a badge who dares act as judge, jury and executioner. Jim Gonzalez is a public policy consultant and strategist, and a former San Francisco supervisor. He wrote this commentary for CalMatters. 26 Baumb, Nelly From:Jeremy Erman <jeremy_erman@yahoo.com> Sent:Monday, May 17, 2021 6:43 PM To:Council, City Subject:Oral Communications presentation?? CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear City Council and Staff,    I am surprised that you are allowing members of the public to pool their time to give a presentation during Oral  Communications longer than the 2 or 3 minutes usually allotted to a single person.    I have seen people ask City Staff at council meetings if they could combine their time with other people in order to speak  longer, but were always told no. So if this is contrary to city policy, I do not understand why it is being allowed tonight,  and if it's a change in city policy, it should be clearly articulated so that others may have the opportunity to present  presentations to the council.    Please understand that I am in NO WAY criticizing the subject of the current presentation, or offering any opinion on its  worth whatsoever. I simply believe that city policies regarding public speakers should be consistent for everyone,  especially given how most members of the public usually have such a limited time to address the Council, no matter how  important their issues.    Thank you,    Jeremy Erman  27 Baumb, Nelly From:Becky Richardson <becky.richardson@gmail.com> Sent:Monday, May 17, 2021 6:02 PM To:onlineissues@duncansolutions.com; Council, City Cc:Brad McGowan Subject:Attempting to get Residential Parking Permits for 311 Grant Ave., Palo Alto CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Hello,     My partner (Brad McGowan, cc'd) and I (Becky Richardson) have been attempting to secure residential parking permits  for our soon‐to‐be new address at 311 Grant Ave, Palo Alto, in the Evergreen permit zone. We both have current  permits for downtown (where I've been for years, at 843 Kipling St.). We'd like to transfer these and secure new permits.  Given the difficulties we've had reaching anyone who can help with this, we'd appreciate it if both permits were offered  without the usual second‐permit fee.    We've tried emailing and calling and leaving voicemails with people in the transportation division (both Nathan Baird  and Sarah Wilson) and the city manager (at 650-329-2100). We've tried using Duncan Solution's site, although it doesn't seem to be applicable for the Evergreen zone. Despite a full week of this, we still haven't received any response from any division. We need these permits starting this coming weekend, as our new place does not have off-street parking for us.     With all the other stress of moving, this has been both frustrating and disheartening. Any help would be much appreciated -- and I hope a new system (or any system!) is on the horizon for the future.    Best wishes,  Becky Richardson  28 Baumb, Nelly From:Bill Blodgett <billhps@live.com> Sent:Monday, May 17, 2021 5:27 PM To:Council, City; Clerk, City Cc:'Judy Chang' Subject:La Comida Contact Info CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Thank you again for allowing us to share our situation at La Comida with you this evening.  Here is our contact  information for follow‐up.    Bill Blodgett, Board Co‐President                 billhps@gmail.com                 650‐686‐9710    Judy Chang, Board Co‐President                 Chang.judee@gmail,com                 650‐704‐6535  29 Baumb, Nelly From:tom tomvlasic.com <tom@tomvlasic.com> Sent:Monday, May 17, 2021 2:30 PM To:onlineissues@duncansolutions.com Cc:Council, City Subject:Impossible Website for RPP Program Permit purchase CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Good afternoon,    I want to register a compliant with Duncan and the Palo Alto City Council relative to the permit process for  getting renewal permits for the RPP program.  I'm in Southgate and have had permits every year the program  has been in place.  It has taken me over three hours today to try and buy permits for 2021‐2022.  I had two  calls to Duncan and in each case, there was no direct help only a referral to the City website for transportation  or to your Duncan "issues" email.  Even though I was able to talk to a real person at Duncan, they did not help  me, they only would refer me to the web site or the email.  I was finally able to find a link to purchase a permit  (I tried at City Hall only to find the permit desk and lobby still closed due to Covid and no reference on the  doors to where I should go for a RPP renewal.)    After finally finding the link on the Transporation web site, I was told I needed my permit number to log  in.  Since I did not remember the number, I put in my email and clicked on the "forgot number" link.  Ah yes,  we have your email, which showed, and we will send you your permit number.  That never happened and I  went through the process twice!!!  Perhaps it is because your system automatically makes the email address  all caps, I don't know!!!     Finally, I had to create a totally new RPP account using our other house email account mainly used by my  wife.  Finally, I could get in but now had to acquire totally new permits for a "new" account.  As a fifty‐year  resident at this address, I was extremely frustrated to be told to provide proof of vehicle ownership and  residency.   I assume this is the case because I was forced to start a new RPP account as your email back to my  original email account that was to contain my original account number NEVER arrived.  (And I did check all my  spam folders too!!!).    After providing all of the information you wanted for the new account including vehicle info, address, proof of  registration and proof of residency‐‐having to send you digital files of the registration and utility bills, I was  given a note to submit and check out.  But, I could not check out.   Every time i hit check out, I would be  returned to the purchase permit page.  Finally, there was a note that my purchase was in process, but I was  never told that meant I could not actually order the permit or pay for it until you made sure I could be  approved.  Frankly this entire process has been terrible and there is no "user friendly" to the web site or the  support from Duncan.        I hope that the City Council can direct staff to look into this and fix the process.  And, please get back to me  and let me know that my permit is ACTUALLY being processed and I will hear back from you as to completing  the "checkout" and getting the permits.  The permit is under Linda Vlasic, Mariposa Avenue.  30   Regards,  Tom Vlasic      31 Baumb, Nelly From:Roberta Ahlquist <roberta.ahlquist@sjsu.edu> Sent:Monday, May 17, 2021 12:18 PM To:Council, City; City Mgr; Aram James; Planning Commission; Cecilia Taylor; Joe Simitian; rebecca; WILPF Peninsula Palo Alto Subject:Fwd: Desegregate Foothill Park CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  PA Council and PA Recreation Department:  When wil Palo Alto begin to desegregate the 'Wall Street of the West'? (otherwise kown as Palo Alto). Let's rename  Foothill Park after LaDoris Cordell, a long time Palo Alto social justice activist .    I sent the letter below to Ms Cormackin  February, but others might benefit from a reading:  Dear Council Member Cormack:  You were the only council person who considered the impact of a fee on  people with a limited income wishing to visit Foothill Park. We believe  that the park should have NO fees, as parks all over the bay area are, for  the most part, open and free to all. This park has been paid for. The city  has ample funds for cleanup, and if needed people can donate to a park  fund, and even help with cleanup days. After the holidays we visited the  park during 'peak hours' (between 10am and 3pm) several times, and  found the park clean, quiet, and we counted only 18 cars in the parking  lots.  The council once again has reacted in the interests of keeping  some folks out of the park. What a limited vision we have for the health  and interests of the larger community. Thank you for your concerns.  Let's hope that the Parks folks, and Council reconsider their reactive  response and drop the fee.  Sincerely,  Roberta Ahlquist, Women's International League for Peace & Freedom‐ low  income Housing Committee  32 Baumb, Nelly From:mark weiss <earwopa@yahoo.com> Sent:Monday, May 17, 2021 10:47 AM To:Aram James Cc:Roberta Ahlquist; Council, City; Judy Adams; Representative Anna G. Eshoo; chuck jagoda; Cherrill Spencer; Carol Lamont; Mary Gallagher; Mark Mollineaux; paloaltofreepress@gmail.com; Rebecca Eisenberg; Shikada, Ed; Anna Griffin; Winter Dellenbach; Cecilia Taylor Subject:Re: Desegregate Foothill Park CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  For Al Young, Palo Altan, poet laureate of California, who died last month...(lyrics by Mark Weiss and Al Young, parody  song, music by Public Enemy...)     Sent from my iPhone      On Feb 3, 2021, at 6:50 PM, mark weiss <earwopa@yahoo.com> wrote:           Let’s rename the park, for a Black man. We’re all equal, not a sequel. With 2020 hindsight, we’d repair the funk All the other parks, they want the darks. We charge the poor to park the car, but we don’t tax the man, and drive Tesla. Poet laureate, poet laureate; the epitome of literacy. Life’s a brief candle, but he lit it. He hit it, he didn’t sh** it. For his game, he’s like the Willie Mays or Willie Mac, the Barry or the Bobby, meanings clearly or at bottom. We can’t change our past, but we can change our minds. There’s more than 1s and 0s, there’s more than of’s and “ahvs” A temple of listening. To see it glistening. Let’s rename the park. Let’s rename the park. aeiou! aeiou! We want to mingle, to hit a single. Even our squirrels think the new rules are uncool. They’re not dolts.     Sent from my iPhone      On Feb 3, 2021, at 6:25 PM, Aram James <abjpd1@gmail.com> wrote:  33 Thanks Roberta!! Well done! I’m still working on having the park named after Judge  Ladoris Cordell. When Rebecca and I, and I’m  pretty sure Mark Weiss, memory fading a bit with so many meetings, attended the  latest Parks and Recreation Commission meeting.... we received a boarder line hostile  response to our name change suggestions.    Although I’ve had major disagreements with Judge Cordell ‐ we go back to at least 1980‐  when she was a young judge and me a young criminal defense attorney/public  defender—her contributions to civil rights, a wide scope of sociol justice issues, a  culture warrior on so many levels ...are nearly unmatched anywhere. One woman who  zoomed into the meeting said no way to the Cordell name change —‐not verbatim here  ...but she essentially said: Cordell shoved the Foothills Park open to all idea down our  throats ..and she’s a controversial woman!!! I kid you not!     If Ladoris was white with the same remarkable contributions to justice for all —this  would not even be a close call. The Park would in fact be named after her. Straight up  vile sexism and racism still carries the day in majority white wing Palo Alto. Just my  thoughts and I’ll own them...take full responsibility for them ...speaking on my own  behalf ......     Best regards,    Aram     Sent from my iPhone      On Feb 3, 2021, at 2:46 PM, Roberta Ahlquist  <roberta.ahlquist@sjsu.edu> wrote:      Dear Council Member Cormack:    You were the only council person who considered the impact of a fee on  people with a limited income wishing to visit Foothill Park. We believe  that the park should have NO fees, as parks all over the bay area are, for  the most part, open and free to all. This park has been paid for. The city  has ample funds for cleanup, and if needed people can donate to a park  fund, and even help with cleanup days. After the holidays we visited the  park during 'peak hours' (between 10am and 3pm) several times, and  found the park clean, quiet, and we counted only 18 cars in the parking  lots.  The council once again has reacted in the interests of keeping  some folks out of the park. What a limited vision we have for the health  and interests of the larger community. Thank you for your concerns.  Let's hope that the Parks folks, and Council reconsider their reactive  response and drop the fee.  Sincerely,  Roberta Ahlquist, Women's International League for Peace & Freedom‐ low  34 income Housing Committee  35 Baumb, Nelly From:Virginia Smedberg <virgviolin@hotmail.com> Sent:Saturday, May 15, 2021 3:53 AM To:Council, City Subject:timely and open communications needed CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Council Members,    I am writing because I have just read about the difficulties the Palo Alto Weekly says it has had in getting  information from the city.  Since many of us rely on the media for information about what's going on, and  because the Weekly in my opinion does a good job of honest reporting, this concerns me.    I respectfully request that you of the Council, and the City Manager, consider this communication line to the  news media an important one, and that you do everything in your power to ensure that when they ask  questions on behalf of us citizens, those questions get answered with accuracy and timeliness.    Sincerely,  Virginia Smedberg  441 Washington Ave, PA        36 Baumb, Nelly From:Jeff Hoel <jeff_hoel@yahoo.com> Sent:Thursday, May 13, 2021 10:29 AM To:Shikada, Ed Cc:Council, City; UAC Subject:shrunken texts in "Letters From Citizens" documents CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  City Manager Shikada, In the "Letters From Citizens" document for UAC, https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2021/05-12-2021-special/05-12-2021-public-letters-to- uac.pdf associated with UAC's 05-12-21 meeting, https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/utilities-advisory- commission/archived-agenda-and-minutes/agendas-and-minutes-2021/05-12-2021-special/05-12-2021-uac-agenda.pdf one of my messages to Council and UAC (pages 5-8) was edited to shrink some of the text (to two different smaller sizes). When I view my message in "full page" mode, I think the smallest shrunken text is illegible. When I view it in "fit to width scrolling" mode, the smallest shrunken text is legible. Still, it's smaller than I intended. So, I think it shouldn't have happened. Why did this happen? In these pandemic times, when Council and UAC meetings are virtual, the City doesn't have to destroy any trees to print "Letters From Citizens" documents for the convenience of members of the public who attend these meetings. Who did it? At one time, the top line of each message from the public named the person who added the message to the "Letters From Citizens" document. But apparently that practice has been abandoned. So it's harder to fix problems like this. Thanks. Jeff =================== Jeff Hoel 731 Colorado Avenue Palo Alto, CA 94303 =================== 37 Baumb, Nelly From:Winter Dellenbach <wintergery@earthlink.net> Sent:Thursday, May 13, 2021 10:06 AM To:Council, City Subject:Non-responsiveness of City officials to press and public CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Council Members ‐ I am concerned about the increase in unreasonable delays to get important information to the public,  and even to you, the Council. In the not distant past this didn't happen. I know there are staff cutbacks and people are pressed  but I believe that doesn’t fully account for what I experience happening.   Two examples, but not all:     First ‐ One week ago today, Thursday the 6th, the VA’s toxic spill began to contaminate Matadero Creek. The City Manager  knew of the spill within 3 hours, yet our Barron Park neighborhood wasn’t alerted until the following Saturday morning via a  note from the VA sent by our neighborhood association. I then contacted some Council Members to ask what they knew, and  found they didn't, nor did the Parks & Rec Commissioner I talked to.     None had been told about a toxic spill into a Palo Alto creek. Totally unacceptable.     Neighbors have been stewards of this creek for decades, volunteering for creek clean‐ups, unfortunately monitoring past spill  mitigation, etc. And just enjoying living, watching all its wildlife and enjoying our kids splashing in our stretch of the wild creek  as it runs through Bol Park. Still, last evening I stood a couple hundred yards downstream from the so called spill containment  area, I could smell the fuel in the creek where I was. When I filled yet another jar with water and shook it, the smell was very  strong of fuel ‐ it is all through the Bol Park stretch of creek and not contained. Beyond?    Why there are no signs alerting people to the spill? Does the City have no worries about health and safety? You don’t have any  water tests or hard data with good analysis yet.  When I was there yesterday, a couple from Mt. View were there to see the  donkeys and Bol Park. She was cooling her feet in the creek.     When a toxic spill happens in our town, the City Manager or whomever, needs to tell the City Council, city residents and press  as soon as basic information is known ‐ that would have been sometime last Thursday, not Saturday by the VA. Then the City  needed to direct people to a simple site to go for any updates and additional ones at Council meetings.     Second ‐ the most recent canine use of force incident of June 25, 2020, was a tree falling in the woods that no one heard as if  it didn’t happen. Finally a local newspaper revealed it in January of 2021 through a routine check on claims against the City.  This is the third PAPD use of force and lawsuit in three years, so is notable as its own and cumulative. Some of you expressed  dismay that you hadn’t known about this sooner. Indeed.    Withholding or delaying information from the public, Council, Commissioners and press is worrisome and can be dangerous. I  heard that some people were thinking a conspiracy might be responsible for the power outages. Crack‐brained, yes. But it is  also completely irresponsible for the City to unreasonably hold back accurate information that would have prevented dumb  speculation. Palo Altans expect better.      Winter Dellenbach  Barron Park         38 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Thursday, May 13, 2021 10:05 AM To:Council, City; GRP-City Council; city.council@menlopark.org; rebecca@winwithrebecca.com; citycouncil@mountainview.gov Cc:Human Relations Commission; chuck jagoda; Planning Commission Subject:City of Santa Clara settles a wrongful death case from 2017 - police shot and killed a 24 yr old man experiencing a mental health crisis for 5.3 million dollars CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Follow the link below to view the article.  https://mercurynews‐ca‐app.newsmemory.com/?publink=363365e77_1345d75      Sent from my iPhone  39 Baumb, Nelly From:Robert Lancefield <rklancefield@comcast.net> Sent:Thursday, May 13, 2021 9:59 AM To:Council, City Subject:Keeping trust in our City staff, starting with City Manager, requires Manager and staff willingness to quickly tell full stories, CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Dear City Council, Please pardon my generic salutation. My name is Robert Lancefield. My wife and I have lived at 189  Walter Hays Drive almost 60 years. I’ve met some, but not all, of you.    My specific concern is to ask you to set a higher level of responsiveness and transparency with Ed Shikada and the City  staff when there are inevitable but embarrassing breakdowns in City equipment or repairs. Two recent examples are the  failed circuit breakers and the incomplete disclosure (and response?) to the diesel spill in Matadero Creek.    To put these incidents, and each of you, in a larger context, I hope you will read Michael Lewis’ new book, “The  Premonition.” Lewis describes various responses by doctors to the incipient pandemic.    Relevant to your responsibilities as City Council members are Lewis’ descriptions of various bureaucracies (e.g., the FDA  and CDC) and the motivations of staffs within them.    WE are all part of our fast evolving culture where quick and accurate disclosure of facts about city operations is more  essential than ever.    Respectfully,     Robert K. Lancefield    Sent from my iPhone  40 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Wednesday, May 12, 2021 11:20 PM To:Council, City; Planning Commission; Human Relations Commission; chuck jagoda; Roberta Ahlquist; ParkRec Commission; wilpf.peninsula.paloalto@gmail.com; city.council@menlopark.org; city.council@menlopark.org Subject:Sign now to call on the U.S. State Department and Department of Defense: Demand an end to Israel’s forced displacement of Palestinians from East Jerusalem CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    https://actionnetwork.org/forms/sign‐now‐to‐call‐on‐the‐us‐state‐department‐and‐department‐of‐defense‐demand‐an‐ end‐to‐israels‐forced‐displacement‐of‐palestinians‐from‐east‐ jerusalem?link_id=2&can_id=7d229df7acb50c275894bc92e2dc8a92&source=email‐sign‐if‐you‐agree‐palestinians‐have‐ the‐right‐to‐remain‐on‐their‐own‐land‐3&email_referrer=email_1167700&email_subject=sign‐if‐you‐agree‐palestinians‐ have‐the‐right‐to‐remain‐on‐their‐own‐land      Sent from my iPhone  41 Baumb, Nelly From:Annette Ross <port2103@att.net> Sent:Wednesday, May 12, 2021 7:56 PM To:Council, City Cc:City Mgr Subject:Transparency CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  In a message to P. A. Online subscribers, Weekly editor Bill Johnson expressed concern about the lack of transparency at  City Hall.  I share his concern and think the problem has worsened in the last couple of years.  The imposition of a poorly  explained curfew last year, this year’s abrupt decision to encrypt police radio communications, and the delayed  explanation of the multiple power outages may be the most obvious examples of the City’s transparency deficit, but the  problem is not new.  Residents have long complained about how difficult it can be to get an answer from City  Hall.  Maybe Communication Director Meghan Horrigan‐Taylor should be asked to focus less on spin and more on actual  communication.  Like responding to journalists in a timely manner.  I am pretty sure there are software programs that can track inquiries and the status of the City’s response.  Why not  invest in that and task Ms. Horrigan‐Taylor with following up with any manager who is letting inquiries languish and  issues go unanswered?  Surely that is within a Communication Director’s purview.  The City Manager could then report  on the City’s “Responsiveness Rate” at least once a month during his comments before CC.   In a year that has been defined by social upheaval, Palo Alto ‐ a college town and Silicon Valley hub ‐ should not be  suffering from a lack of transparency.  But it is.  I urge City Council to focus on this and take every opportunity to insist  that transparency be part of every City undertaking not subject to privacy laws.     Annette Ross  College Terrace  42 Baumb, Nelly From:John Guislin <jguislin@gmail.com> Sent:Wednesday, May 12, 2021 4:38 PM To:Council, City Subject:Lack of openness and transparency in city government CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Council:    Today the Palo Alto Weekly published a piece on how difficult it is to get answers from the City government.    Residents have been complaining about a lack of transparency and collaboration for a very long time and the problem is  getting worse under the current leadership.    While every presentation I see from city staff starts with a commitment to transparency, it is a hollow promise.    You bear the ultimate responsibility for this failure. Please listen to residents and the Weekly and take action to address  this failure of our city government.    John Guislin      Palo Alto Weekly May 12, 2021 Chasing accurate information. Readers tend to think that the articles based on lengthy investigations take the greatest effort, but there are times when journalists have to show inordinate persistence to get what should be simple answers to straightforward questions. Such was the case when reporter Gennady Sheyner looked into the three power outages that City of Palo Alto Utilities customers experienced in late March and the first half of April.  When he initially asked the Utilities Department spokesperson for the cause of the first power outage, he was told it was due to a "failed preventative maintenance project." When asked to provide details about this project, the spokesperson delayed answering — and Gennady had to keep reminding her that he hadn't received the information and that the public was waiting to know what had happened. It wasn't until mid-April that the director of Utilities posted an explanation on the city's blog about the three outages and nearly a week later before Gennady had gotten sufficiently detailed explanations of their causes, including the replacement of circuit breakers that tripped when they were brought online — the so-called "failed preventative maintenance."   Unfortunately, these communication failures and the lack of prompt and clear information from public officials has been growing exponentially over the past year or longer. We have cut city officials slack because we know they are juggling a lot due to the pandemic and remote working, but it has reached the point where the public is being routinely denied information it is entitled to know. And we know that if the city isn't responding to our phone calls and emails, it’s highly unlikely that the individual members of the public are getting treated any differently. 43 You can help advocate for greater city transparency by emailing the City Council and City Manager at city.council@cityofpaloalto.org and expressing your concern about the inaccessibility of key city officials to the news media and the danger this poses to an informed citizenry. 44 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Wednesday, May 12, 2021 4:24 PM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: New photo book traces history of Hakone Gardens in Saratoga CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    From: Allan Seid <allanseid734@gmail.com>  Date: Tue, May 11, 2021 at 7:10 PM  Subject: New photo book traces history of Hakone Gardens in Saratoga        https://www.mercurynews.com/2021/05/11/new‐photo‐book‐traces‐history‐of‐hakone‐gardens‐in‐ saratoga/?utm_email=5471747C047CF4F134FEE503FE&g2i_eui=sqnKQBf51kRyOuCrHJAwNHEFBT0TrrO E&g2i_source=newsletter&utm_source=listrak&utm_medium=Email&utm_term=https%3a%2f%2fwww. mercurynews.com%2f2021%2f05%2f11%2fnew‐photo‐book‐traces‐history‐of‐hakone‐gardens‐in‐ saratoga%2f&utm_campaign=%23Listrak%5cContentURL%3d+%22http%3a%2f%2fapps.mercurynews.c om%2fnewsletters%2fsan‐jose%2findex.php%3fextract%3dsubject%26ser  New photo book traces history of Hakone Gardens in Saratoga The traditional Japanese garden, a Bay Area treasure, has survived more than a century, Sal PizarroMay 11, 2021 at 12:13 p.m. To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.Spring brings blossoms and new foliage at Hakone Gardens in Saratoga, Calif. on Monday, March 10, 2014. (Jim Gensheimer/Bay Area News Group) Jim Gensheimer/Bay Area News Group file Spring brings blossoms and new foliage at Hakone Gardens in Saratoga, Calif. on Monday, March 10, 2014. (Jim Gensheimer/Bay Area News Group) For decades, Hakone Estate and Gardens has been one of Santa Clara County’s treasures, a traditional Japanese garden nestled away in the hills of Saratoga. Countless people visit every year to see the cherry blossoms in bloom or to just bask 45 in the quiet beauty. It’s one of those places where people say they can’t believe it exists just miles away from jammed freeways and bustling downtowns. But it’s a safe bet that most people don’t know much about its fascinating history. That’s changing as its story is being told through hundreds of photographs, along with text, in “Hakone Estates and Gardens,” a new volume in the Images of America series published last week. It’s written by two women who know Hakone better than just about anyone: Ann Waltonsmith, chairwoman of the Hakone Foundation and a former Saratoga mayor, and Connie Young Yu, a historian and Hakone Foundation trustee whose family was a part owner of the property in the 1960s. It begins with Isabel Longdon Stine, whose impressions of the Japan pavilion at the 1915 Panama-Pacific International Exhibition inspired her to turn 15 acres in Saratoga into Hakone. The history continues with Maj. Charles Lee Tilden, who purchased the property from Stine during the Great Depression, when she could no longer afford it, and the six couples — including Connie Young Yu’s family — who purchased it together in 1961 and held it until the city of Saratoga bought the property in 1966. Along the way, the book celebrates other people important to Hakone’s survival, like James Sasaki, who was Hakone’s lead gardener for 30 years, except for the 3½ years he was interned during World War II. “Throughout a century, the garden survived a national depression, racist policies, and threats of land redevelopment,” Waltonsmith and Yu write in the introduction, noting that the Japanese garden was saved for posterity for 50 years by three sets of owners who were all non-Japanese. “These were extraordinary individuals who pushed back against the prejudice, xenophobia and nativism of their respective times. They possessed a moral compass and gave Hakone its soul.” 46 Baumb, Nelly From:Patricia Becker <patricia@yourhealthandjoy.com> Sent:Wednesday, May 12, 2021 4:08 PM To:Council, City Subject:greater city transparency CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  We need and expect greater city transparency from our City Council and City Manager at city.council@cityofpaloalto.org We are all better when educated. I am concerned that you grant the news media information they request so we may be informed. Patricia Becker | Yoga and Diet Coach  Live Yoga and YouTube Yoga  To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.  Multipure Water Filters  47 Baumb, Nelly From:Annie Bedichek <annie@bedichek.org> Sent:Wednesday, May 12, 2021 4:01 PM To:Council, City Subject:Solar panels and planning CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________    Hi everyone,    Thank you for all you do.  I would like to put in a plug for improving both the speed and efficacy of our city planning  department.  They are very expensive, but not fast or effective compared to other local communities (Mountain View,  Redwood City, Menlo Park, Los Gatos).  It is almost impossible to get a solar system installed (we had to go through 14  vendors to get 1 who would work with the City, it is such a drain on a solar company).  That should not be true, no value  was added by their comments, and they had us provide ridiculous amounts of documentation for standard installation  items like nuts and bolts that cost us a LOT in time and effort to get.  If we are moving towards being a more green city,  it shouldn’t be so difficult and expensive to get green things through the City processes.  It’s been this way for 20 years.   We tried 3 times to get solar installed and gave up the first 2, after spending thousands on plans and consulting.  We  finally got a system installed, but not what would have maximized out electricity, only what the City would approve.  We  have 3 electric cars and spend a fortune on City electricity because of that, despite having solar on our roof.  Please  replace that team, they have had time to work a good system and have chosen not to.    Second, the planning department is just not functioning any more.  We have friends who are mid way through a  demolition in midtown.  Their plans were approved more than nine months ago and they have been waiting seven  months for the demolition permit, ostensibly because they need an unprotected tree cut down (a 10 year old magnolia)  in their back yard.  They have spent upwards of $50,000 on rent in a place in Santa Clara and will have to commute for  their kids school come fall.  There is simply no excuse for that.  If the planning department can’t function remotely, make  them come back and work far apart from each other in empty offices other functioning remote employees are not using.  I am not a complainer.  The rest of the city and companies here are functioning.  Other cities have functioning planning  departments (slower, but not like ours) due to the pandemic.  There needs to be a shake up.  Cutting staff might work, if  we could change the mentality of those there from blocking building, to supporting it.  It has a direct effect on the lack of housing in our city.    Thanks,    Annie Bedichek  3rd generation Palo Altan  48 Baumb, Nelly From:VW Martin <martin108vw@gmail.com> Sent:Wednesday, May 12, 2021 3:54 PM To:Council, City Subject:the public's right to know CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council & City Manager,    As a citizen of Palo Alto, I am concerned about the inaccessibility of key city officials to the news media and the danger  this poses to our community.       Please prioritize our access to the truth in a timely manner.     Thank you!  Vickie Martin  49 Baumb, Nelly From:Yahoo Mail.® <honkystar@yahoo.com> Sent:Wednesday, May 12, 2021 3:14 PM To:Honky Subject:You don’t want to miss this‼ PLEASE DO NOT VACCINATE or your FUTURE immune system will NOT function properly against all other virus? CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  It’s already too late ! Those who opted out and didn’t get the shot are being shed upon by those who swallowed the cool aid. https://rumble.com/vg4t4h-you-dont-want-to-miss-this.html Best Regards, & Stay Healthy, Wealthy & Wise. 50 Baumb, Nelly From:Mark Meyers <ommmgm@gmail.com> Sent:Wednesday, May 12, 2021 2:36 PM To:Council, City CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear City Council: I would like to advocate for maintaining the community gardens in Palo Alto during this next wave of budget cuts. The community gardens provide wonderful benefits to the gardeners and to visitors, especially during the pandemic. The gardens provide important mental health refuges for families and seniors throughout our community. The food is great for all of us, and really needed by low income gardeners. The gardens provide habitat and a pleasant peaceful place to relax and enjoy. Parks generally have trees and lawns only, no flowers. Every week, I see people who come to photograph and paint. People walk there while on business calls, they walk, jog, walk their dogs, and sit on the benches watching the birds and butterflies. Total elimination would be a tragedy. Certainly, some (or all) of the functions could be taken up by volunteers if needed. Some minimal help from the city to handle more difficult issues like terminations of gardener's contracts when they are not weeding or tending to their plots would be helpful. It would be sad to see such a wonderful resource vanish. Please find a way to keep this important city program alive. Thank you for your time and support, Mark Meyers  (Cell) 650‐771‐1358  FCC Ham Radio KJ6YFZ  51 Baumb, Nelly From:Sierra Club Loma Prieta Chapter <reply@emails.sierraclub.org> Sent:Wednesday, May 12, 2021 12:31 PM To:Council, City Subject:Sea Level Rise Webinar Starts Thursday at 9am! CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. Dear Supporter To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. Day 1 of the Webinar Starts Thursday (May 13th) at 9am! If you haven't registered already, please do so below. For those who have registered, we have sent you an email with the zoom link to join. Interested but unable to attend? All registrants will be given access to the recording of the webinars. Sea Level Rise: Why We Need Nature Based Adaptation 3-Part Webinar: Thursdays 9 am - Noon, May 13, 20, 27 Click here to register for free Decision makers need information and understanding of why nature-based adaptation to sea level rise is critical for cities around the Bay. This webinar provides an introduction to nature based adaptation strategies, how to plan for them and how to fund them. This is an opportunity to learn from leading experts in the field about how to make your community resilient to the impacts of sea level rise. You will join decision-makers and community stakeholders who are working to protect their communities while improving the quality of life for residents and leaving a living legacy. San Francisco Bay is a complex living ecosystem, essential to the ecology of California. As sea levels rise, urgent action is needed as rising levels seriously endanger the Bay's ecology in addition to threatening economic harm to housing, industry and critical infrastructure. Recent studies are confirming what scientists have believed, that traditional “armored” shorelines such as levees and concrete bulkheads offer less long-term protection than people might think. Now more scientists, policy makers and funding agencies have come to understand that “living shorelines” are valuable in protecting coastlines. Webinar Agenda 52 Speaker Bios “Sea level rise will have a profound impact on the San Francisco Bay and the communities that surround it. The challenge is to protect housing, businesses and critical infrastructure in an environmentally sensitive way. Learning from experts and local leaders involved in nature based solutions, this webinar series will inform key stakeholders about options for addressing sea level rise while restoring and protecting the Bay.” - Dave Pine, Chair of the San Francisco Bay Restoration Authority; San Mateo County Board of Supervisors, District 1; Member of the Bay Conservation and Development Commission Jointly presented by the Loma Prieta Chapter, the Redwood Chapter and the San Francisco Bay Chapter of the Sierra Club To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet. To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. Supporting Organizations: To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. Sponsored by the Bay2030 Campaign of the Sierra Club Loma Prieta Chapter To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. To help protect your privacy, Microsoft Office prevented automati To help protect your privacy, Microsoft Office prevented automati To help protect your privacy, Microsoft Office prevented automati Sierra Club Loma Prieta Chapter This email was sent to: city.council@cityofpaloalto.org This email was sent by the Sierra Club 2101 Webster St., Suite 1300, Oakland, CA 94612 Manage Preferences/Unsubscribe | View as Web Page GI I GI GI 701-32 DOCUMENTS IN THIS PACKET INCLUDE: LETTERS FROM CITIZENS TO THE MAYOR OR CITY COUNCIL RESPONSES FROM STAFF TO LETTERS FROM CITIZENS ITEMS FROM MAYOR AND COUNCIL MEMBERS ITEMS FROM OTHER COMMITTEES AND AGENCIES ITEMS FROM CITY, COUNTY, STATE, AND REGIONAL AGENCIES Prepared for: 06/01/2021 Document dates: 05/12/2021 – 05/19/2021 Set 6 Note: Documents for every category may not have been received for packet reproduction in a given week. 1 Baumb, Nelly From:Joe Hirsch <jihirschpa@earthlink.net> Sent:Tuesday, May 18, 2021 3:34 PM To:Council, City Cc:Greg Schmid (external); Holzemer Terry Subject:RHNA Numbers Action Item Attachments:PASZ Letter to Council dated 5-16-21 re RHNA numbers.docx; Cal Government Code 65890.pdf; Cal Government Code 65584.pdf; Cal Government Code 65584.01 to 65584.04.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  Dear Council Members: Attached is a letter that was recently sent to you by Greg Schmid on behalf of Palo Altans for Sensible Zoning (PASZ). Also attached are the Cal Government Code Sections referred to by Greg in his letter. Note one CORRECTION; Greg listed Cal Gov Code Section 65980 in the last paragraph on page 2 of his letter as the source for the Guidebook requirement/mandate. That should have been Cal Gov Code Sections 65890.3 and 65890.5 (copies attached). Joe Hirsch 65584.01. For the fourth and subsequent revision of the housing element pursuant to Section 65588, the department, in consultation with each council of governments, where applicable, shall determine the existing and projected need for housing for each region in the following manner: (a) The department's determination shall be based upon population projections produced by the Department of Finance and regional population forecasts used in preparing regional transportation plans, in consultation with each council of governments. If the total regional population forecast for the projection year, developed by the council of governments and used for the preparation of the regional transportation plan, is within a range of 1.5 percent of the total regional population forecast for the projection year by the Department of Finance, then the population forecast developed by the council of governments shall be the basis from which the department determines the existing and projected need for housing in the region. If the difference between the total population projected by the council of governments and the total population projected for the region by the Department of Finance is greater than 1.5 percent, then the department and the council of governments shall meet to discuss variances in methodology used for population projections and seek agreement on a population projection for the region to be used as a basis for determining the existing and projected housing need for the region. If agreement is not reached, then the population projection for the region shall be the population projection for the region prepared by the Department of Finance as may be modified by the department as a result of discussions with the council of governments. (b) (I) At least 26 months prior to the scheduled revision pursuant to Section 65588 and prior to developing the existing and projected housing need for a region, the department shall meet and consult with the council of governments regarding the assumptions and methodology to be used by the department to determine the region's housing needs. The council of governments shall provide data assumptions from the council's projections, including, if available, the following data for the region: (A) Anticipated household growth associated with projected population increases. (8) Household size data and trends in household size. (C) The percentage of households that are overcrowded and the overcrowding rate for a comparable housing market. For purposes of this subparagraph: (i) The term "overcrowded" means more than one resident per room in each room in a dwelling. (ii) The term "overcrowded rate for a comparable housing market" means that the overcrowding rate is no more than the average overcrowding rate in comparable regions throughout the nation, as determined by the council of governments. (D) The rate of household formation, or headship rates, based on age, gender, ethnicity, or other established demographic measures. (E) The vacancy rates in existing housing stock, and the vacancy rates for healthy housing market functioning and regional mobility, as well as housing replacement needs. For purposes of this subparagraph, the vacancy rate for a healthy rental housing market shall be considered no less than 5 percent. (F) Other characteristics of the composition of the projected population. 1 (G) The relationship between jobs and housing, including any imbalance between jobs and housing. (H) The percentage of households that are cost burdened and the rate of housing cost burden for a healthy housing market. For the purposes of this subparagraph: (i) The term "cost burdened" means the share of very low, low-, moderate-, and above moderate- income households that are paying more than 30 percent of household income on housing costs. (ii) The term "rate of housing cost burden for a healthy housing market" means that the rate of households that are cost burdened is no more than the average rate of households that are cost burdened in comparable regions throughout the nation, as determined by the council of governments. (I) The loss of units during a state of emergency that was declared by the Governor pursuant to the California Emergency Services Act (Chapter 7 ( commencing with Section 8550) of Division 1 of Title 2), during the planning period immediately preceding the relevant revision pursuant to Section 65588 that have yet to be rebuilt or replaced at the time of the data request. (2) The department may accept or reject the information provided by the council of governments or modify its own assumptions or methodology based on this information. After consultation with the council of governments, the department shall make determinations in writing on the assumptions for each of the factors listed in subparagraphs (A) to (I), inclusive, of paragraph ( 1) and the methodology it shall use and shall provide these determinations to the council of governments. The methodology submitted by the department may make adjustments based on the region's total projected households, which includes existing households as well as projected households. ( c) (1) After consultation with the council of governments, the department shall make a determination of the region's existing and projected housing need based upon the assumptions and methodology determined pursuant to subdivision (b ). The region's existing and projected housing need shall reflect the achievement of a feasible balance between jobs and housing within the region using the regional employment projections in the applicable regional transportation plan. Within 30 days following notice of the determination from the department, the council of governments may file an objection to the department's determination of the region's existing and projected housing need with the department. (2) The objection shall be based on and substantiate either of the following: (A) The department failed to base its determination on the population projection for the region established pursuant to subdivision (a), and shall identify the population projection which the council of governments believes should instead be used for the determination and explain the basis for its rationale. (B) The regional housing need determined by the department is not a reasonable application of the methodology and assumptions determined pursuant to subdivision (b ). The objection shall include a proposed alternative determination of its regional housing need based upon the · determinations made in subdivision (b ), including analysis of why the proposed alternative would be a more reasonable application of the methodology and assumptions determined pursuant to subdivision (b ). (3) If a council of governments files an objection pursuant to this subdivision and includes with the objection a proposed alternative determination of its regional housing need, it shall also include documentation of its basis for the alternative determination. Within 45 days of receiving an objection filed pursuant to this section, the department shall consider the objection and make a 2 May 10, 2021 KELLY GORDQN·COMPANY 12241 SARA TOGA--SUNNYV ALE ROAD SARA TOGA, CA 95070 N :J: > -< (.,.) " ::i: ('")~ ~-i -<-< c,O ,-n rrl-0 :::::,> ~r via al> -,, .. ,,-i .. N _c c,· r.,-n City Clerk 250 Hamilton Ave. Palo Alto, Ca. 94301 Re: Proposed Waste Water Rate Change ~tJv//)7' .3 "1> I $" ~ 7 t!) City Council Members : -' We are the owners of two office buildings located at 3240 & 3260 Hillview Ave. and do hereby submit this protest of the rate change for the following reason. Under the S-2 classification the rate would be determined by the amount of water used per month. At our locations we have only one water meter per building. The bulk of our water is utilized to water our landscaping. Landscape water does not enter the sewer system for processing. We request that some formula is established to take this condition into consideration . P/l~J Brian J. Kelly > final written determination of the region's existing and projected housing need that includes an explanation of the information upon which the determination was made. ( d) Statutory changes enacted after the date the department issued a final determination pursuant to this section shall not be a basis for a revision of the final determination. (Amended by Stats. 2019, Ch. 497, Sec. 146. (AB 991) Effective January 1, 2020.) 65584.02. (a) For the fourth and subsequent revisions of the housing element pursuant to Section 65588, the existing and projected need for housing may be determined for each region by the department as follows, as an alternative to the process pursuant to Section 65584.0 I: (I) In a region in which at least one subregion has accepted delegated authority pursuant to Section 65584.03, the region's housing need shall be determined at least 26 months prior to the housing element update deadline pursuant to Section 65588. In a region in which no subregion has accepted delegation pursuant to Section 65584.03, the region's housing need shall be determined at least 24 months prior to the housing element deadline. (2) At least six months prior to the department's determination of regional housing need pursuant to paragraph (1), a council·of governments may request the use of population and household forecast assumptions used in the regional transportation plan. This request shall include all of the following: (A) Proposed data and assumptions for factors contributing to housing need beyond household growth identified in the forecast. These factors shall include allowance for vacant or replacement units, and may include other adjustment factors. (B) A proposed planning period that is not longer than the period of time covered by the regional transportation improvement plan or plans of the region pursuant to Section 14527, but a period not less than five years, and not longer than six years. (C) A comparison between the population and household assumptions used for the Regional Transportation Plan with population and household estimates and projections of the Department of Finance. (b) The department shall consult with the council of governments regarding requests submitted pursuant to paragraph (2) of subdivision (a). The department may seek advice and consult with the Demographic Research Unit of the Department of Finance, the State Department of Transportation, a representative of a contiguous council of governments, and any other party as deemed necessary. The department may request that the council of governments revise data, assumptions, or methodology to be used for the determination of regional housing need, or may reject the request submitted pursuant to paragraph (2) of subdivision (a). Subsequent to consultation with the council of governments, the department will respond in writing to requests submitted pursuant to paragraph (I) of subdivision (a). 3 (c) If the council of governments does not submit a request pursuant to subdivision (a), or if the department rejects the request of the council of governments, the determination for the region shall be made pursuant to Sections 65584 and 65584.01. (Amended by Stats. 2008, Ch. 728, Sec. 9. Effective January 1, 2009.) 65584.03. (a) At least 28 months prior to the scheduled housing element update required by Section 65588, at least two or more cities and a county, or counties, may form a subregional entity for the purpose of allocation of the subregion's existing and projected need for housing among its members in accordance with the allocation methodology established pursuant to Section 65584.04. The purpose of establishing a subregion shall be to recognize the community of interest and mutual challenges and opportunities for providing housing within a subregion. A subregion formed pursuant to this section may include a single county and each of the cities in that county or any other combination of geographically contiguous local governments and shall be approved by the adoption of a resolution by each of the local governments in the subregion as well as by the council of governments. All decisions of the subregion shall be approved by vote as provided for in rules adopted by the local governments comprising the subregion or shall be approved by vote of the county or counties, if any, and the majority of the cities with the majority of population within a county or counties. (b) Upon formation of the subregional entity, the entity shall notify the council of governments of this formation. If the council of governments has not received notification from an eligible subregional entity at least 28 months prior to the scheduled housing element update required by Section 65588, the council of governments shall implement the provisions of Sections 65584 and 65584.04. The delegate subregion and the council of governments shall enter into an agreement that sets forth the process, timing, and other terms and conditions of the delegation of responsibility by the council of governments to the subregion. ( c) At least 25 months prior to the scheduled revision, the council of governments shall determine the share of regional housing need assigned to each delegate subregion. The share or shares allocated to the delegate subregion or subregions by a council of governments shall be in a proportion consistent with the distribution of households assumed for the comparable time period of the applicable regional transportation plan. Prior to allocating the regional housing needs to any delegate subregion or subregions, the council of governments shall hold at least one public hearing, and may consider requests for revision of the proposed allocation to a subregion. If a proposed revision is rejected, the council of governments shall respond with a written explanation of why the proposed revised share has not been accepted. ( d) Each delegate subregion shall fully allocate its share of the regional housing need to local governments within its subregion. If a delegate subregion fails to complete the regional housing need allocation process among its member jurisdictions in a manner consistent with this article 4 and with the delegation agreement between the subregion and the council of governments, the allocations to member jurisdictions shall be made by the council of governments. (Added by Stats. 2004, Ch. 696, Sec. 6. Effective January 1, 2005.) 65584.04. (a) At least two years before a scheduled revision required by Section 65588, each council of governments, or delegate subregion as applicable, shall develop, in consultation with the department, a proposed methodology for distributing the existing and projected regional housing need to cities, counties, and cities and counties within the region or within the subregion, where applicable pursuant to this section. The methodology shall further the objectives listed in subdivision (d) of Section 65584. (b) (1) No more than six months before the development of a proposed methodology for distributing the existing and projected housing need, each council of governments shall survey each of its member jurisdictions to request, at a minimum, information regarding the factors listed in subdivision ( e) that will allow the development of a methodology based upon the factors established in subdivision ( e ). (2) With respect to the objective in paragraph (5) of subdivision ( d) of Section 65584, the survey shall review and compile information that will allow the development of a methodology based upon the issues, strategies, and actions that are included, as available, in an Analysis of Impediments to Fair Housing Choice or an Assessment of Fair Housing completed by any city or county or the department that covers communities within the area served by the council of governments, and in housing elements adopted pursuant to this article by cities and counties within the area served by the council of governments. (3) The council of governments shall seek to obtain the information in a manner and format that is comparable throughout the region and utilize readily available data to the extent possible. ( 4) The information provided by a local government pursuant to this section shall be used, to the extent possible, by the council of governments, or delegate subregion as applicable, as source information for the methodology developed pursuant to this section. The survey shall state that none of the information received may be used as a basis for reducing the total housing need established for the region pursuant to Section 65584.01. (5) If the council of governments fails to conduct a survey pursuant to this subdivision, a city, county, or city and county may submit information related to the items listed in subdivision ( e) before the public comment period provided for in subdivision ( d). ( c) The council of governments shall electronically report the results of the survey of fair housing issues, strategies, and actions compiled pursuant to paragraph (2) of subdivision (b ). The report shall describe common themes and effective strategies employed by cities and counties within the area served by the council of governments, including common themes and effective strategies around avoiding the displacement of lower income households. The council of governments shall also identify significant barriers to affirmatively furthering fair housing at the 5 regional level and may recommend strategies or actions to overcome those barriers. A council of governments or metropolitan planning organization, as appropriate, may use this information for any other purpose, including publication within a regional transportation plan adopted pursuant to Section 65080 or to inform the land use assumptions that are applied in the development of a regional transportation plan. ( d) Public participation and access shall be required in the development of the methodology and in the process of drafting and adoption of the allocation of the regional housing needs. Participation by organizations other than local jurisdictions and councils of governments shall be solicited in a diligent effort to achieve public participation of all economic segments of the community as well as members of protected classes under Section 12955. The proposed methodology, along with any relevant underlying data and assumptions, an explanation of how information about local government conditions gathered pursuant to subdivision (b) has been used to develop the proposed methodology, how each of the factors listed in subdivision ( e) is incorporated into the methodology, and how the proposed methodology furthers the objectives listed in subdivision (e) of Section 65584, shall be distributed to all cities, counties, any subregions, and members of the public who have made a written or electronic request for the proposed methodology and published on the council of governments', or delegate subregion's, internet website. The council of governments, or delegate subregion, as applicable, shall conduct at least one public hearing to receive oral and written comments on the proposed methodology. (e) To the extent that sufficient data is available from local governments pursuant to subdivision (b) or other sources, each council of governments, or delegate subregion as applicable, shall include the following factors to develop the methodology that allocates regional housing needs: (I) Each member jurisdiction's existing and projected jobs and housing relationship. This shall include an estimate based on readily available data on the number of low-wage jobs within the jurisdiction and how many housing units within the jurisdiction are affordable to low-wage workers as well as an estimate based on readily available data, of projected job growth and projected household growth by income level within each member jurisdiction during the planning period. (2) The opportunities and constraints to development of additional housing in each member jurisdiction, including all of the following: (A) Lack of capacity for sewer or water service due to federal or state laws, regulations or regulatory actions, or supply and distribution decisions made by a sewer or water service provider other than the local jurisdiction that preclude the jurisdiction from providing necessary infrastructure for additional development during the planning period. (B) The availability of land suitable for urban development or for conversion to residential use, the availability of underutilized land, and opportunities for infill development and increased residential densities. The council of governments may not limit its consideration of suitable housing sites or land suitable for urban development to existing zoning ordinances and land use restrictions of a locality, but shall consider the potential for increased residential development under alternative zoning ordinances and land use restrictions. The determination of available land suitable for urban development may exclude lands where the Federal Emergency Management Agency (FEMA) or the Department of Water Resources has determined that the flood management infrastructure designed to protect that land is not adequate to avoid the risk of flooding. 6 (C) Lands preserved or protected from urban development under existing federal or state programs, or both, designed to protect open space, farmland, environmental habitats, and natural resources on a long-term basis, including land zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of that jurisdiction that prohibits or restricts conversion to nonagricultural uses. (D) County policies to preserve prime agricultural land, as defined pursuant to Section 56064, within an unincorporated area and land within an unincorporated area zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of that jurisdiction that prohibits or restricts its conversion to nonagricultural uses. (3) The distribution of household growth assumed for purposes of a comparable period of regional transportation plans and opportunities to maximize the use of public transportation and existing transportation infrastructure. ( 4) Agreements between a county and cities in a county to direct growth toward incorporated areas of the county and land within an unincorporated area zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of the jurisdiction that prohibits or restricts conversion to nonagricultural uses. (5) The loss of units contained in assisted housing developments, as defined in paragraph (9) of subdivision (a) of Section 65583, that changed to non-low-income use through mortgage prepayment, subsidy contract expirations, or termination of use restrictions. (6) The percentage of existing households at each of the income levels listed in subdivision (e) of Section 65584 that are paying more than 30 percent and more than 50 percent of their income in rent. (7) The rate of overcrowding. (8) The housing needs of farmworkers. (9) The housing needs generated by the presence of a private university or a campus of the California State University or the University of California within any member jurisdiction. (10) The housing needs of individuals and families experiencing homelessness. If a council of governments has surveyed each of its member jurisdictions pursuant to subdivision (b) on or before January 1, 2020, this paragraph shall apply only to the development of methodologies for the seventh and subsequent revisions of the housing element. ( 11) The loss of units during a state of emergency that was declared by the Governor pursuant to the California Emergency Services Act (Chapter 7 (commencing with Section 8550) of Division 1 of Title 2), during the planning period immediately preceding the relevant revision pursuant to Section 65588 that have yet to be rebuilt or replaced at the time of the analysis. (12) The region's greenhouse gas emissions targets provided by the State Air Resources Board pursuant to Section 65080. (13) Any other factors adopted by the council of governments, that further the objectives listed in subdivision (d) of Section 65584, provided that the council of governments specifies which of the objectives each additional factor is necessary to further. The council of governments may include additional factors unrelated to furthering the objectives listed in subdivision ( d) of Section 65584 so long as the additional factors do not undermine the objectives listed in subdivision ( d) of Section 65584 and are applied equally across all household income levels as described in subdivision (f) of Section 65584 and the council of governments makes a finding that the factor is necessary to address significant health and safety conditions. 7 (t) The council of governments, or delegate subregion, as applicable, shall explain in writing how each of the factors described in subdivision ( e) was incorporated into the methodology and how the methodology furthers the objectives listed in subdivision ( d) of Section 65584. The methodology may include numerical weighting. This information, and any other supporting materials used in determining the methodology, shall be posted on the council of governments', or delegate subregion's, internet website. (g) The following criteria shall not be a justification for a determination or a reduction in a jurisdiction's share of the regional housing need: (1) Any ordinance, policy, voter-approved measure, or standard of a city or county that directly or indirectly limits the number of residential building permits issued by a city or county. (2) Prior underproduction of housing in a city or county from the previous regional housing need allocation, as determined by each jurisdiction's annual production report submitted pursuant to subparagraph (H) of paragraph (2) of subdivision (a) of Section 65400. (3) Stable population numbers in a city or county from the previous regional housing needs cycle. (h) Following the conclusion of the public comment period described in subdivision (d) on the proposed allocation methodology, and after making any revisions deemed appropriate by the council of governments, or delegate subregion, as applicable, as a result of comments received during the public comment period, and as a result of consultation with the department, each council of governments, or delegate subregion, as applicable, shall publish a draft allocation methodology on its internet website and submit the draft allocation methodology, along with the information required pursuant to subdivision ( e ), to the department. (i) Within 60 days, the department shall review the draft allocation methodology and report its written findings to the council of governments, or delegate subregion, as applicable. In its written findings the department shall determine whether the methodology furthers the objectives listed in subdivision (d) of Section 65584. If the department determines that the methodology is not consistent with subdivision ( d) of Section 65 5 84, the council of governments, or delegate subregion, as applicable, shall take one of the following actions: (I) Revise the methodology to further the objectives listed in subdivision (d) of Section 65584 and adopt a final regional, or subregional, housing need allocation methodology. (2) Adopt the regional, or subregional, housing need allocation methodology without revisions and include within its resolution of adoption findings, supported by substantial evidence, as to why the council of governments, or delegate subregion, believes that the methodology furthers the objectives listed in subdivision (d) of Section 65584 despite the findings of the department. G) If the department's findings are not available within the time limits set by subdivision (i), the council of governments, or delegate subregion, may act without them. (k) Upon either action pursuant to subdivision (i), the council of governments, or delegate subregion, shall provide notice of the adoption of the methodology to the jurisdictions within the region, or delegate subregion, as applicable, and to the department, and shall publish the adopted allocation methodology, along with its resolution and any adopted written findings, on its internet website. 8 (I) The department may, within 90 days, review the adopted methodology and report its findings to the council of governments, or delegate subregion. (m) ( 1) It is the intent of the Legislature that housing planning be coordinated and integrated with the regional transportation plan. To achieve this goal, the allocation plan shall allocate housing units within the region consistent with the development pattern included in the sustainable communities strategy. (2) The final allocation plan shall ensure that the total regional housing need, by income category, as determined under Section 65 5 84, is maintained, and that each jurisdiction in the region receive an allocation of units for low-and very low income households. (3) The resolution approving the final housing need allocation plan shall demonstrate that the plan is consistent with the sustainable communities strategy in the regional transportation plan and furthers the objectives listed in subdivision ( d) of Section 65584. (Amended (as amended by Stats. 2018, Ch. 990, Sec. 3. 7) by Stats. 2019, Ch. 335, Sec. 4. (AB 139) Effective January 1, 2020.) 9 Law section https://leginfo. legislature.ca.gov/faces/codes_ displaySection.xh ... Home Bill Information California Law Publications Other Resources My Subscriptions My Favorites I of2 Code: Select Code Section: i '-" 2 ,_,. i OJ Search 0 up"<< Previous ~ GOVERNMENT CODE-GOV cross-reference cha P.tered bills POF I AddToMy F;ivorites Search Phrase: TITLE 7. PLANNING AND LAND USE [65000 • 66499.58) ( Heading of Title 7 amended by Stats. 1974, Ch. 1536.) DIVISION 1. PLANNING AND ZONING [65000 -66301) ( Heading of Division 1 added by Stats. 1974, Ch. 1536.) CHAPTER 3. Local Planning [65100 -65763) ( Chapter 3 repealed and added by Stats. 1965, Ch. 1880. ) ARTICLE 10.6. Housing Elements [65580 • 65589.11) ( Article 10.6 added by Stats. 1980, Ch. 1143. ) Highlight ✓,5584. (a) (1) For the fourth and subsequent revisions of the housing element pursuant to Section 65588, the department shall determine the existing and projected need for housing for each region pursuant to this article. For purposes of subdivision (a) of Section 65583, the share of a city or county of the regional housing need shall include that share of the housing need of persons at all income levels within the area significantly affected by the general plan of the city or county. (2) It is the intent of the Legislature that cities, counties, and cities and counties should undertake all necessary actions to encourage, promote, and facilitate the development of housing to accommodate the entire regional housing need, and reasonable actions should be taken by local and regional governments to ensure that future housing production meets, at a minimum, the regional housing need established for planning purposes. These actions shall include applicable reforms and incentives in Section 65582.1. (3) The Legislature finds and declares that insufficient housing in job centers hinders the state's environmental quality and runs counter to the state's environmental goals. In particular, when Californians seeking affordable housing are forced to drive longer distances to work, an increased amount of greenhouse gases and other pollutants is released and puts in jeopardy the achievement of the state's climate goals, as established pursuant to Section 38566 of the Health and Safety Code, and clean air goals. (b) The department, in consultation with each council of governme,ts, shall determine each region's existing and projected housing need pursuant to Section 65584.01 at 16:lst two years prior to the scheduled revision required pursuant to Section 65588. The appropriate council of governments, or for cities and counties without a council of governments, the department, shall adopt a final regional housing need plan that allocates a share of the regional housing need to each city, county, or city and county at least one year prior to the scheduled revision for the region required by Section 65588. The allocation plan prepared by a council of governments shall be prepared pursuant to Sections 65584.04 and 65584.05. (c) Notwithstanding any other provision of law, the due dates for the determinations of the department or for the council of governments, respectively, regarding the regional housing need may be extended by the department by not more than 60 days if the extension will enable access to more recent critical population or housing data from a pending or recent release of the United States Census Bureau or the Department of Finance. If the due date for the determination of the department or the council of governments is extended for this reason, the department shall extend the corresponding housing element revision deadline pursuant to Section 65588 by not more than 60 days. JCd) The regional housing needs allocation plan shall further all of the following objectives: (1) Increasing the housing supply and the mix of housing types, tenure, and affordability In all cities and counties within the region in an equitable manner, which shall result in each jurisdiction receiving an allocation of units for low-and very low income households. (2) Promoting Infill development and socioeconomic equity, the protection of environmental and agricultural resources, the encouragement of efficient development patterns, and the achievement of the region's greenhouse gas reductions targets provided by the State Air Resources Board pursuant to Section 65080. (3) Promoting an improved intraregional relationship between jobs and housing, including an improved balance between the number of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction. 5/1712021. 6:50 PM Law section 2 of2 https:/ /leg info. legislature.ca.gov/faces/codes_ displaySection.xh ... (4) Allocating a lower proportion of housing need to an income category when a jurisdiction already has a disproportionately high share of households in that income category, as compared to the countywide distribution of households in that category from the most recent American Community Survey. (5) Affirmatively furthering fair housing. (e) For purposes of this section, "affirmatively furthering fair housing" means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. (f) For purposes of this section, "household income levels" are as determined by the department as of the most recent American Community Survey pursuant to the following code sections: (1) Very low incomes as defined by Section 50105 of the Health and Safety Code. (2) Lower incomes, as defined by Section 50079.5 of the Health and Safety Code. (3) Moderate incomes, as defined by Section 50093 of the Health and Safety Code. (4) Above moderate incomes are those exceeding the moderate-income level of Section 50093 of the Health and Safety Code. (g) Notwithstanding any other provision of law, determinations made by the department, a council of governma,ts, or a city or county pursuant to this section or Section 65584.01, 655B4.02, 65584.03, 65584.04,65584.0S, 65584.06, 65584.07, or65584.08 are exempt from the california Environmental Quality Act (Division 13 (commencing with Section 21000) of the Public Resources Code). (Amended by Stats. 2018, Ch. 989, Soc. 1.5. (AB 1771) Effoctive January 1, 2019.) 5/17/2021, 6:50 PM Codes Display Text https://leginfo.legislature.ca.gov/faces/codes _ displayText.xhtml ... Home I of2 ./} ·-y")t(, #., . . C £1'f~j oJ<Jltrt, _/ 1.ECISLATIVE lNFORf\lATIO~ Bill Information California Law Publications Other Resources My Subscriptions My Favorites Code: Select Code Section: 1 o• 2 or l :JO Search (D GOVERNMENT CODE-GOV TITLE 7. PLANNING AND LAND USE [65000 -66499.58] ( Heading of Title 7 amended by Stats. 1974, Ch. 1536.) DIVISION 1. PLANNING AND ZONING [65000 -66301] ( Heading of Division 1 added by Stats. 1974, Ch. 1536.) CHAPTER 4. Zoning Regulations [65800 -65912] ( Chapter4 repealed and added by Stats. 1965, Ch. 1880.) ARTICLE 2.9. Guidebook for Jobs-Housing Balance [65890.1 -65890.5) ( Article 2.9 added by Stats. 1990, Ch. 843, Sec. 1.) 65890.1, The Legislature finds and declares that: (a) State land use patterns should be encouraged that balance the location of employment-generating uses with residential uses so that employment-related commuting is minimized. (b) Balance in employment and residential land use patterns reduces traffic congestion and may contribute to Improvement of air quality in urban areas. (c) Balancing of employment-generating land uses and residential land uses improves economic and housing opportunities and reduces loss of economic productivity caused by transportation delay. (d) The attainment of a more balanced land use pattern requires the cooperation of government agencies with the private sector to assure that public and private decisions affecting land use take into consideration the need to seek balance in the location of employment-generating land uses and residential land uses. (e) Local agencies and state agencies should cooperate to facilitate the balancing of employment-generating land uses and residential land uses and provisions of transportation to serve these uses. (f) Local governments have the primary responsibility to plan for local land use patterns, within the parameters established by state law to achieve statewide needs. (g) Housing must be provided for the estimated 3 million new workers and their families expected to be added to the California eoonomy in the 1990's. (h) It is the intent of the Legislature to move toward the goal that every California worker have available the opportunity to reside close to his or her jobsite. (Added by Stats. 1990, Ch. 843, Sec. 1,) ~5890.3. The Department of Housing and Community Development shall prepare a guidebook for use by cities, counties, councils of government, state agencies, and the private sector in the planning and development of a housing supply to meet the need created by employment growth. The guidebook shall be prepared in time for use following the availability of the 1990 Census of Population and Housing. (Added by Stats. 1990, Ch. 843, Sec. 1.) (~ (a) The guidebook shall include the following: (1) Methodologies for measuring the balance of jobs and housing. (2) Methodologies for analysis of the projected needed housing supply to serve projected employment growth. (3) Methodologies to encourage the balance of jobs and housing. (4) Incentives which local, regional, and state agencies may offer to the private sector to encourage developments and design which will facilitate an improved l:alance between employment generating land use and residential land use. (5) Methodologies cities and counties may use to analyze trip generation and vehicle miles traveled to and from employment centers. 5117/202 I, 6:57 PM Codes Display Text https:/ /legin fo. legislature.ca.gov /faces/codes_ displayText.xhtml... 2 of2 (6) Methodologies cities and counties may use to achieve more efficient use of transportation facilities serving major employment centers. (7) Descriptions of successful and unsuccessful efforts by cities or counties to move toward improved jobs-housing balance. (b) The guidebook shall seek to describe and evaluate the various tools available to local, regional, and state governments to measure, evaluate, and improve the balance of jobs and housing and to mitigate the undesirable effects of any imbalance between jobs and housing. The guidebook shall describe efforts by cities, counties, and regional agencies to improve the balance of jobs and housing. (c) The department shall consult with interested parties and organizations such as academic institutions, environmental groups, businesses, labor unions, real estate groups, housing advocacy groups, cities, counties, and regional agencies. The final guidebook shall be completed no later than December 31, 1993. (d) Within two years of final publication of the guidebook, the Assembly Office of Research shall complete a study of the effectiveness of the guidebook as a decisionmaking tool by public agencies and the private sector to facilitate improved jots-housing balance. The study shall include the office's recommendations for legislation needed to improve the effectiveness of decisionmaking as it relates to achieving jobs-housing balance, if any. (Added by Stats. 1990, Ch. 843, Sec. 1.) 5/171202 l, 6:57 PM Palo Altans for Sensible Zoning PO Box 305, Palo Alto, CA 94302 http://sensiblezoning.org May 16, 2021 Palo Alto City Council Agenda Item # 5 May 18, 2021 “RHNA Appeal Discussion” Honorable Council Members: The Palo Alto City Council should reject the Regional Housing Needs Allocation numbers assigned to Palo Alto. ABAG and RHNA have not followed the California Government Codes in formulating these numbers and they will bring unprecedented damage to our City. Plan Bay Area 2050 proposes that jobs should grow in “already jobs-rich areas”. This means that a very small section of Silicon Valley will get twice the number of new jobs of any of the other 32 equally sized geographical units that make up the Bay Area and build twice the level of new housing units. This concentration of job growth in a single area has already caused significantly negative consequences for residents: --Some of the highest land prices in the country; --Very expensive housing costs that are continuing to grow rapidly; --Income inequality that is one of the highest in the county and growing the fastest; --Transit usage that is declining over time; --Dispersion of families away from job centers; --Increasing tax burden on residents to pay for expensive infrastructure; --End of the mobility of workers and ideas through Silicon Valley; --Challenge to our sustainability goals; --Basic questions about the future of local democracy. THE CODES At the heart of the matter is the fact that the Plan Bay Area 2050/RHNA process has not followed the relevant California Government Codes regulating the actions of both ABAG and HCD. Section 65890.5 of the Code on Planning requires HCD to prepare and publicly distribute a Guidebook that would present “methodologies for measuring the balance of jobs and housing” and identifying “incentives which local, regional and state agencies may offer the private sector to encourage developments which will facilitate an improved balance between employment generating land use and residential land use”. HCD has not produced this Guidebook either before or during the Plan Bay Area 2050 process. Without the Guidebook, we need to take a more detailed look at why the RHNA allocation process described in Section 65584 is relevant. The most relevant parts include: Section 65584 (d) states that the regional government body should look for incentives that will “promote an improved intraregional relationship between jobs and housing”. Section 65584.04 (d) states that the data used shall include “each jurisdiction’s existing and projected jobs and housing relationship” and that “public participation and access shall be required in the development of the methodology of the allocation of regional housing needs”. To date there has been no effective public participation or access in the development of this methodology. 65584.01 (a) mandates that HCD’s housing projection “shall be based upon the Department of Finance and regional forecasts in consultation with each council of governments”. Further 65584.01 (c) states that HCD consult with the council of governments…who shall provide assumptions on the relationship between jobs and housing, including any imbalances between jobs and housing”. To date there has been no effective consultation outside of ABAG’s Technical Committee. Section 65584.04 (i) states that HCD should have a written report on whether the methodology is “promoting an improved intraregional relationship between jobs and housing”. To date there has been no such written analytic report. Section 65584.04 (a) states that “each council of government shall develop in consultation with HCD a proposed methodology for distributing the existing and projected regional housing needs to the cities”, while 65584.04 (d) states that “public participation and access shall be required in the development of the methodology of the allocation of regional housing needs”. Again—no effective public participation in exploring alternate means of dealing with imbalances. DISCUSSION The Codes explicitly mention again and again the need for “cooperation” and “public participation”. This clearly means that each of the parties—HCD, DOF, and MTC/ABAG—must engage directly with each other and with the public. But all the key decisions on the allocation methodology of both jobs and housing have been made by ABAG’s self-appointed technical committee that has representatives of both HCD and DOF but no public participation. Code 65980 clearly states that a Guidebook be prepared by HCD for use by cities and local government agencies to help explore other means of creating better balances between jobs and housing. But HCD has no records of the existence of a Guidebook and there is no record of MTC/ABAG requesting the Guidebook from HCD despite their close cooperation in working on population and housing projections together. MTC/ABAG have worked together with HCD and DOF on their jobs and housing forecast projections but all the work has been done in meetings of their self-appointed technical committee with no public participation. They have used their own in-house modeling programs based on aggressive job growth assumptions and have disregarded data that questions these assumptions. MTC/ABAG are moving ahead on their current model. Their approved methodology retains the ‘jobs driven model’ in priority development areas. This seems hard to reconcile with the Codes calling for public participation “promoting an improved intraregional relationship between jobs and housing”. For example: The Horizon project public outreach in 2019 did acknowledge that one strategy that might be looked at included placing office caps in eleven cities with more jobs than residents (Strategy V-7). But without any real or meaningful public participation or examination of “improving intraregional job- housing balances”, MTC/ABAG announced in October 2019 that Strategy V-7 was “Not recommended to move forward”. This leaves the Horizon strategies discussion involving “intraregional jobs-housing relationship” solely in the hands of an in-house staff process. The final decision on the RHNA options before you have been made in a closed Technical Committee despite the California Code calling for “public participation. CONCLUSION MTC/ABAG’s Plan Bay Area 2040 (2013) and their current update Plan Bay Area 2050 have failed to identify the emerging huge intraregional imbalances in jobs and housing that have negatively affected the West Bay and the whole of the nine county Bay Area during the last decade. MTC/ABAG failed to respond in detail to formal complaints raised in detail by West Bay citizen groups about the impacts of those imbalances. Further, they have not followed the Government Codes that have stressed the need for public discussion of alternative means of dealing with intraregional balances and have not acknowledged their joint commitment to cooperate in such activities with full public participation. We ask that the Palo Alto City Council halt the process of updating the jobs and housing projections in the plan Bay Area 2050. To date this process has not followed the California Government Codes that require the participation of local citizens groups in developing an effective course of action. Please act tonight on the steps that need to be taken in order to “promote an improved intraregional relationship between jobs and housing”. Direct the City Attorney to tell HCD and ABAG that the City of Palo Alto refuses to go along illegal misuse. We demand the opportunity to participate in the making of these decisions, as mandated by law. Sincerely, PASZ (Palo Altans for Sensible Zoning) Contact: Greg Schmid Palo Alto gregschmid@sbcgobal.net 2 Baumb, Nelly From:Rice, Danille Sent:Friday, May 14, 2021 7:40 PM To:Council, City Cc:Stump, Molly; Shikada, Ed; Minor, Beth; Gaines, Chantal; Guagliardo, Steven; Nose, Kiely Subject:City of Palo Alto Legislative Letters: Assembly Bill 703 and Senate Bill 591 Attachments:Support for SB 591-final.pdf; AB 703 (Rubio) Palo Alto Support (final).pdf Good afternoon Mayor and Council Members,   On behalf of City Manager Ed Shikada, I would like to inform you that the attached letters of support were sent to the  Honorable Josh Becker (Senate Bill 591) and the Honorable Blanca Rubio (Senate Bill 703).      Assembly Bill 703: Enhancing public access through teleconferencing in a public meeting setting   Senate Bill 591: Provides affordable housing builders an opportunity to construct more affordable units for  seniors and transition age youth    Respectfully,   Danille       Danille Rice  Executive Assistant to the City Manager  (650) 329‐2105 | danille.rice@cityofpaloalto.org   www.cityofpaloalto.org                      • . CITY OF :~~g 11 LJ • m nn Office of the Mayor and City Council 1 City of Palo Alto May 14, 2021 The Honorable Blanca Rubio California State Assembly State Capitol, Room 5175 Sacramento, CA 95814 Re: Assembly Bill 703 (Rubio) Support from the City of Palo Alto Dear Assemblymember Rubio, On behalf of the City of Palo Alto, I am pleased to support your Assembly Bill 703, related to enhancing public access through teleconferencing in a public meeting setting. As part of his response to the COVID-19 pandemic, Governor Newsom issued Executive Order N-29-20 in March 2020 to expand public access to meetings of local agencies by suspending some of the restrictions on teleconferencing. This allowed local agencies to utilize teleconferencing for legislative body meetings and boards and commissions meetings and it has enhanced public access and increased public participation. Unfortunately, once the Governor’s Executive Order expires, local agencies will again be required to comply with antiquated provisions of existing law which make it much more difficult to hold meetings of the legislative body by teleconference. Current law refers to “teleconference locations” and requires various actions to be taken at “teleconference locations” by local governments wishing to utilize teleconference meetings. Current law does not recognize that a “teleconference location” is now wherever there is a person with a computer, a tablet, or even a mobile phone. Existing law also does not allow for an entire meeting to be conducted via teleconference though many local agencies and the public have grown accustomed to that as an option. Assembly Bill 703 will eliminate the previously existing concept of teleconference locations and will revise notice requirements to allow for greater public participation in teleconference meetings of local agencies. The bill does not require teleconferencing, rather it modernizes existing law to ensure greater public participation in meetings of the legislative bodies of local agencies who choose to utilize teleconferencing. This bill also expresses legislative intent to improve and enhance public access to local agency meetings, consistent with the digital age, by allowing broader access through teleconferencing options consistent with the Governor’s Executive Order. Palo Alto has seen an increase in public participation in public meetings during this past year and the City would like to maintain that opportunity for additional participation and transparency in the future. DocuSign Envelope ID: C35E9B34-D450-48C1-A0EE-E4AFD1C1BD76 P.O. Box 10250 Palo Alto, CA 94303 650.329.2477 650.328.3631 fax 2 Thank you for introducing this important piece of legislation, and we are pleased to support Assembly Bill 703 and increase our flexibility with transparently conducting public meetings. Sincerely, Tom DuBois, Mayor City of Palo Alto cc: Josh Becker, Senator, California’s 13th Senate District Marc Berman, Assemblymember, California’s 24th Assembly District Seth Miller, Regional Public Affairs Manager, Peninsula Division, League of California Cities Palo Alto City Council DocuSign Envelope ID: C35E9B34-D450-48C1-A0EE-E4AFD1C1BD76 [ OocuSigned by: ~~9 Office of the Mayor and City Council City of Palo Alto May 14, 2021 The Honorable Josh Becker California State Senate State Capitol, Room 3076 Sacramento, CA 95814 RE: Senate Bill 591 (Becker) Senior citizens: intergenerational housing developments Support from the City of Palo Alto Dear Senator Becker: On behalf of the City of Palo Alto, I want to express support for Senate Bill 591 (SB 591) which will provide affordable housing builders an opportunity to construct more affordable units for seniors and transition age youth. As it relates to financing affordable housing, the options to pay for and build these projects are limited. Previously, tax credits were used to help finance senior affordable housing for people age 55 and older, though it came with a restriction that prohibited the financing of other types of affordable units in the same building. An affordable housing project aimed at serving seniors could not include some units for transition-aged youth (TAY), despite the well documented studies showing the social and health benefits to seniors associated with interactions with TAY. Without a change in legislation, seniors are missing opportunities to access social and health benefits and services. Our support for this legislation is oriented toward adjusting known ambient financing restrictions in a manner that could lead to housing developments that do more than just put a roof over people’s head. Youth in foster care often have lived through traumatic experiences, before and after placement into a foster home. Once they “age” out of the system, many do not have the skills or support needed to meet the challenges of life and some enter homelessness. In the 2019 Homeless Point in Time Count for Santa Clara County, 19% of the homeless individuals surveyed indicated that they had been in the foster system. Senate Bill 591 will allow seniors and youth to live in the same affordable housing complex, provide affordable housing developers greater access to financing, and help reduce our homeless population by providing housing opportunities for transition age youth and support for seniors. DocuSign Envelope ID: 810DC86D-8D83-48AE-A404-05EBC37D8036 P.O. Box 10250 Palo Alto, CA 94303 650.329.2477 650.328.3631 fax Thank you for your leadership, especially on SB 591. We are glad to see such swift approval of the bill. We greatly appreciate your support. Sincerely, Tom DuBois, Mayor City of Palo Alto cc: Marc Berman, Assemblymember, California’s 24th Assembly District Palo Alto City Council DocuSign Envelope ID: 810DC86D-8D83-48AE-A404-05EBC37D8036 [ DocuSigned by: ~~9 3 Baumb, Nelly From:Susan Kemp <skemp650@gmail.com> Sent:Friday, May 14, 2021 3:44 PM To:Tim Sheeper Cc:Wong, Lindsay; Eva, Sharon; Council, City; ParkRec.commission@cityofpalo.org; supervisor.simitian@bos.sccgov.org; michele.seaton@phd.sccgov.org; Friends of Steering Committee Subject:Commendation of PASS from Friends of Rinconada Pool Attachments:PASS Commendation from FoRP May 2021.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  May 14, 2021   Tim Sheeper, Founder and CEO Palo Alto Swim and Sport 777 Embarcadero Road Palo Alto, CA 94303   Dear Tim Sheeper and Team,   This letter is written on behalf of the Friends of Rinconada Pool to commend Palo Alto Swim and Sport for  your excellent service throughout the challenging events of the 2020 pandemic. Lap swimmers recognize that  not only residents of Palo Alto, but also those of neighboring cities have benefited from the rapid effort you  gave to safely reopen our public community pool as soon as the CDC, State of California, Santa Clara County  and City of Palo Alto guidelines were issued.   Further, you maintained maximum hours of safe access for swimmers during the course of the 2020 California  wildfires. Thank you also for your openness to feedback from swimmers and for expanding communication  through these many events.   It is with gratitude and appreciation that hundreds of swimmers from infants and teens to seniors are both  healthier and happier given the dedication of all your staff. We recognize that you will have a continuing  impact on the health and wellness of the community.   The Friends of Rinconada Pool, through its Steering Committee, express our appreciation to Palo Alto Swim  and Sport for your programs and your value to the swimming community.   Thank you,   Bruce Anderson    Marilyn Bauriedel     Gwen Fisher    Linda Fletcher   Anne Harrington    Susanne Jul      Susan Kemp    Barbara Rieder    cc:  Palo Alto City Council        Lindsay Wong and Sharon Eva, Palo Alto Community Services 4        City of Palo Alto Parks and Recreation Commission        Supervisor Joe Simitian        Dr. Sara Cody, Director, SCCPHD May 14, 2021 Tim Sheeper, Founder and CEO Palo Alto Swim and Sport 777 Embarcadero Road Palo Alto, CA 94303 Dear Tim Sheeper and Team, This letter is written on behalf of the Friends of Rinconada Pool to commend Palo Alto Swim and Sport for your excellent service throughout the challenging events of the 2020 pandemic. Lap swimmers recognize that not only residents of Palo Alto, but also those of neighboring cities have benefited from the rapid effort you gave to safely reopen our public community pool as soon as the CDC, State of California, Santa Clara County and City of Palo Alto guidelines were issued. Further, you maintained maximum hours of safe access for swimmers during the course of the 2020 California wildfires. Thank you also for your openness to feedback from swimmers and for expanding communication through these many events. It is with gratitude and appreciation that hundreds of swimmers from infants and teens to seniors are both healthier and happier given the dedication of all your staff. We recognize that you will have a continuing impact on the health and wellness of the community. The Friends of Rinconada Pool, through its Steering Committee, express our appreciation to Palo Alto Swim and Sport for your programs and your value to the swimming community. Thank you, Bruce Anderson Marilyn Bauriedel Gwen Fisher Linda Fletcher Anne Harrington Susanne Jul Susan Kemp Barbara Rieder cc: Palo Alto City Council Lindsay Wong and Sharon Eva, Palo Alto Community Services City of Palo Alto Parks and Recreation Commission Supervisor Joe Simitian Dr. Sara Cody, Director, SCCPHD 7 't 5 Baumb, Nelly From:Barbara Rieder <barieder@yahoo.com> Sent:Friday, May 14, 2021 1:54 PM To:Tim Sheeper Cc:Council, City; Wong, Lindsay; Eva, Sharon; ParkRec Commission; "supervisor.simitian@bos.sccgov.org Michele.Seaton@phd.sccgov.org friendsofrpsteering"@googlegroups.com Subject:Letter of appreciation Attachments:PASS Commendation from FoRP May 2021.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  May 14, 2021 Tim Sheeper, Founder and CEO Palo Alto Swim and Sport 777 Embarcadero Road Palo Alto, CA 94303 Dear Tim Sheeper and Team, This letter is written on behalf of the Friends of Rinconada Pool to commend Palo Alto Swim and Sport for your excellent service throughout the challenging events of the 2020 pandemic. Lap swimmers recognize that not only residents of Palo Alto, but also those of neighboring cities have benefited from the rapid effort you gave to safely reopen our public community pool as soon as the CDC, State of California, Santa Clara County and City of Palo Alto guidelines were issued. Further, you maintained maximum hours of safe access for swimmers during the course of the 2020 California wildfires. Thank you also for your openness to feedback from swimmers and for expanding communication through these many events. It is with gratitude and appreciation that hundreds of swimmers from infants and teens to seniors are both healthier and happier given the dedication of all your staff. We recognize that you will have a continuing impact on the health and wellness of the community. The Friends of Rinconada Pool, through its Steering Committee, express our appreciation to Palo Alto Swim and Sport for your programs and your value to the swimming community. Thank you, Bruce Anderson Marilyn Bauriedel Gwen Fisher Linda Fletcher Anne Harrington Susanne Jul Susan Kemp Barbara Rieder cc: Palo Alto City Council 6 Lindsay Wong and Sharon Eva, Palo Alto Community Services City of Palo Alto Parks and Recreation Commission Supervisor Joe Simitian Dr. Sara Cody, Director, SCCPHD   To help protect your privacy, Microsoft Office preautomatic download of this picture from the Intern   Virus-free. www.avast.com   [§] 7 Baumb, Nelly From:edie gilbertson <ideasbyeg@gmail.com> Sent:Thursday, May 13, 2021 5:26 PM To:Council, City Subject:Fwd: Forward to your city council Attachments:Final version of letter opposing SB 556 et al as faxed to 37 of the 40 CA State Senators.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    To:   City Council of Palo Alto     Please see the important letter attached here.    Thank you for your fine work,    Edie Gilbertson  Alma Street  Palo Alto  ‐‐‐‐‐‐‐‐‐‐ Forwarded message ‐‐‐‐‐‐‐‐‐  From: Cheryl Hogan <clhogan3@gmail.com>  Date: Wed, May 12, 2021 at 1:00 PM  Subject: Forward to your city council  To: <ideasbyeg@gmail.com>      This is a very important letter. Your city council is in agreement with this letter as I sent you in my previous email the  announcement that PA city council opposes the legislation that telecommunications industry is trying to push through in  Sacramento. Your city council finally got smart! How nice . Please forward this letter to your city council.    Cheryl Lea Hogan.   Harry .re Lehmann Pnn 1pal . ttom· , Law O,ffice ,of Barry . Lehma n PC 4 Vineyard ourt 0 _· lifi •. I 94947 _ ·ay 10 , 2021 Area Code 415 _ ,:1, phon :: 7-2121 ac imile: 898-69 59 Senator B,en Hueso tat p" ,I R m 4035 Sacram _nto CA 95814 Via ax .. , -16) 6 · -40 ear nat rHu - RE: ,(I) 1-cal ri k inherent in · B 5 56 b li s th-rationale fo dire __ transfe t the en it Floor p r Rul 2, , 8. (II) In additi n o fiscal rtSk _he mann r in whi h the Bill has been pushed through th 1Comrmtt e proce --, ·•~ , :~n prior _ o the 28.. , 1 actic h , , v1 la I d , ·tatut and Constitution. (Ill) It 1s scientificaH , u tainabl to vote against SB 556 , nth _ ,aj of 1n ral obJecti n to rad '" ~ n c qu nc . ... 1i , docum i ubm1tted to each Cali omia Sta ' , nat , --urc _ , at -ach four · nator h · -recei d Actual otice of th _ ad r -fi ca and health consequ n . whi,ch cl,ear and convincing vid nc, -how ould result from th B 556. ti note -in passing that if B 5 6, 1n · t1 nan nam d aft:1 _ r th armor ... pi rcing I A O bull t to illu trate h calculated abandonment of public acce . to Comrmttee m , tings can assure that the most _ rful c rpora -11 n can p, _ h the · -c n i , nt aro nd a a , -, n ,titu n -_ bj _ ct. B -ause Ia · er letters are alwa ··s man1pu ative, the only wa to make a traight etter 1 _ to chall -n _· · r -ad r · to u , , h Jr b _ ·~. analyti a ill t aluat · hat is. --aid. I invi · that approach towards thi letter. i lett r d fend three core points i . , 'Upporting annotation: • SB 5S6 was through inad 1_rt nc . · -an ferr•ed to th __ . oor ofth ,· nate without its plann d 1-1 aring on Monday-Ma 10th b -ll take stated as put u 1 -o 7 at -Ru1 _ 2 .. 8 b cau of no I' cal impa t SB -6, cann _. lawfully have b n so r :fi rred by sembl Appropriations because evidence in th_ , 5.5 -pr parat '. peck _ t -r .ach 1n -mb -r ,0· --ppropria ~. n . h that ; .B 556 will predictably assum risks of fiscal consequenc s of potentially ove -· h lmtn · t ht. h tat alif omi -, · . c s ma -ive li bility e po ure from the implementation o Sena1 · · 'ill 556. . enate B,ill 649 pr nted th , 1 a1ne r ks in 2017 ~ Tb r 11· r,. _. · 56 -hould be returned to A , mbly Appropriation-for a Hearing with o preJudi,ce to the BiU. Or-if the parliam ntary and Con tit _ tt nal fa ·t _r _ ar r _ogniz _d _ inh -r --ntly 'fi c · (incl, ding as to income) then the fi ,cal deadline has been missed this year The indu _t _ · m -t la:wy·-. --and a 1 _ th r ... in ur kn · tha -i com a __ vast uninsurable liability ,exposure and legal defense fees costs due to multip;Ie act r -includ1n ~ ae _ th·~ i _ health ncer . · h T 1 · mmunica i -n R ~ -rm Act nowhere u e the word health please ,_. _ the holding of the Califorma Supr -m _ court ·» _:_Mob ·l Lii_e ~ _ 1 C v. ·· Cal -th 1107 (2019). • , h =-_ -ha •e b _ ::-n corr _ ct -proc -_ dura -mnbi _ _itie _ in th mann .-r 1n whi -h 1B 556 has proceeded through the ·Committe tructurer: There are SB 556 ( uch as la t -nut,_ dra ing · ·nator , upporti.-1 f th ·iJ a tand-1n Committ,e ~ memb -. rs. without fonnali -when a quorum --as oth -rw1se absent . Other l gal and Con ·ti _utional i -u with. , · 556 --tated ., my re _, t ul l I f April 14 . 2021 _o the enat,e Standing Co1nmittee on -nergy, Utilities, and Communication hich 1 ,-r i r _p _ctfully i ·corpora 1 d h _r 1n b thi- refer .. ce as though mor fully s. -t ti ,rth her -in4 · hese procedural anomaU ~ ho bat , 556 must be 11etum d · o A s,emb 1y Appropriation , ·or , -valuation. Th po -·th ~ anno a _ d po ition in o lowing _ rk not ju t th bull t point 1 to a ur that each of our •enator ha Not"'eie and thereby actual know.le'dge 'th a c rtainable hi _ b ri ks inh nt.1.n 556. • .i:11/'1"1'-.. -of --,ri J 14th 1 d th m d _rnl unu ual g 3th-any Senator or As . mblymember has th -nght d cline a vo ,e for a particular B 11 or to oppos,e that ill in high r profile ' h re th lik _ ly ir u]t , a B,ill · ould nd uch -gislator , , moral , tandard including non-re]ati · 1c m ral tandar derived from traditional _chool oft ought , ·ome ma frown in tb · nam f all _g d cien ifi objecti i but --.· ~ all _ n cient put d ---nt _ p, __ , the same data . is letter provide · cientifi1c sources sho · ing that as the· mo t ulti _ t que ti n in ci _ 1 di pu ~ d in th _ _ urr nt . ri 1 1n , molo no Legislator need conclud _ that her or his moral judgment are inher _ ntly any . l .-, ·--, i "nttfi , than p -. , ha k -d mo 1 . I qu ntl b tho · _ h ha , _ th 1nos o gain emembe·r tobacco .. 2 S1 ATE BILL 556 P1 O 1 --_ 1 ABL RISKS O _ -I CIALHARM TO THE GO UTILITY LE . ORS OF PRO, SU I - ....,,..,,.., .. _.. _ B 64 in 201 7-· 1 current _ nat Bill 5 56 unpl _ m .n d will re -u'lt in transfer 10/the industry's miassiv'e uninsurable liability exposure to, the government of California and to th'e oth ,er Le -ors ofp.oles a.nd tr,uctu.re upon whi h antenna are built resulting th straight-forward non-no ,el application of well establish d jurisprudentia atut a· d c _ e Ia:-· ground -d · n Coot cts L dlord .... T _ ant {D trine· o( E1xt.ur_ .) J1oint Vent-re .Agency,, and liability from the c :ncuning results of independ nt ~ortfeasor ( umme · v. Tice ·t al). Botl _ d do n the companies and · ,o,vernm t entitie h1ch o-~ pot -and tructur · for th int nd d ma , of ant cc nna -ar:-Jo,nt Venturers with Telecom. In Contract wi.th elecom to provide the Dan erous Condttion Qf Public P~op,erty involved., and tl,e Landlord of Telecom. B 5 -6 -ould an, fer th o.ir -1 c, _ m uninsurabI,e Iiabiliti _ to the taxpayer ba ed on those and other theori sand combinations •, .:_ r f. Th , indu 1 -ant , tin uran _· ~, or th -, po ur o d , ''n _ the lia · ility on _ the taxpa r makes sense from the1r po"'nt of vie· ··. very ote for .B 556 is a ote to risk th practi ·al in sol _ ncy for th -tate f I ali orni . · hich ri ·. -hou d b full .• · , -· ,_ luat d Th _ risk · to the sol .ency of alif omia , hould , .5 5 6 be . 1gned into law includ · the ollowin --h ted con __ m . th · hich brought th .... _. .. _._.1ble e • d to SB 649 in 2017 .. 1. 2. The State can11 be su d for 'negligence' or other bas':c common-law theone ofr , !' f' and I lai1na · · , can onl · . ue as all din I ovemm _nt _ od, ,. he main CA Government Code hich is virtually always pled by all ._ ,· .:ri nc= 1 p · blic .. 11 _ lawy r i , __ an .. _ r u . ond! i 11 ublic · rty Go rnment Code 835. If forcing o -ity and 1county and 1city prop rties int 11 _ a in ontract -i _ · How d b · S1 , 556, as ouid ha been th ase with B 649 m 2017 at next foUo · s h n th n tow r i . affi , · d to th · u · ity pole or tructur due to the I octrin _ of Fixture· a·dotherl-galrea • n,, th _ m -rg -rofant ·nnaandpole -·nt batP bit Prope ·· er ating a Dangerous, ,condition,. f "~ 5 56 -,ootains th ' ·_ ir fl btl r . xemp, 1l n• a_ did ,64 ·· . 2017 hich Exemptio prohibit cellular broadcasat antenna 1CO struction near h r ftr• figh e-· I p b _d · h -I h ,-round pu h ~ b th ir ~ ti, St-ate i' acknowle·,tging that the radiation from .the e antenna are dan'gerous, as show·n by man, tudi . includ111; ~ th ,e1 $25 million s,tudy und«rlak'en b, , tl,e National 3 Toxtcology Program of our natio,n 's NIH, whl'cli found that cellular rmliatio.n ca e .the formation of glioma cells, tlie m'o··t deatlly of the· b1rain cancer cells. 5 .. A r _ult 1 th ·ab _B556L __ eS 49b ·£·r itmak th re _ultmgpubU prop _rty a Dangerou· , ·ondition of Pubic roperty m the ligh1 of Government ode· 83 _ which in urn mak . law · uit again · tat mu,ch mo· onn1dabl ., 6. There is no ,· overwhelming evid nee of D 1 A and cellular damage from radio- nc · . a -_m1tt _d by · ·· llular ph .n and t t . 7 It i · a matte o well-e tabUshed public r cord that th international re-in urance n 1 , try ha I , g refil' ed to in ur -any a p -c ofth _ -J-com 1ndu try · r injune, · cau d by cellular de ·ces or installations ... 8 , The· only avenue left to the cellular industry, other tli an ju .t honestly facing up to t/11 mess and help'tng u , solve ,t, I ' to liift the legal' respon ib1lity to gove·rnment 10 8e · oned and comp t . nt counsel where injuries. oc r of a · ort onsi te t with ~ inju •· . to -... , includin ._, gliobl, -to1na a -, .indicat, d b glioma ; 1nding r m th _ study will file suit against responsible corporate entities broad] and also sue th _ tat: • Cah , nia .a ,_ b v -. n .ddit1on t _· h _ fa 1hat th 996 ctn . b r - mentions health., and that ther-1 no prote,ction for industry · the Act language or ui 1 bas -c d on direct · · -ical the· pra tical im,munlty' offetl!'d to te,ie'com under the act is conditional upon compliance w1t/1 FCC ,standard , and the:re arie material means available to h·ow that c.urrently marketed sma'rl phone · do not meet FCC .tandards wi en mea · ,ured as actually' u _ ed tn the .field, .namely up aga,n~ t· .the /ace. 11. In he instanc of un uccessful bar to civil .rosecu ion from -aid indus -_ -inspir d 1996 Act and in a ta · h r '~I int and _.•-~ ral liability' m a, · that a 5% liabih· · contributor ha 100% of financial responsibility from a Joss , the' result .of the .combination of the/a tors stated abov·e .i ,that in the ,n tan -of uit,,. ludi11. ; 'friendly,' all financ,a'I burdens from ce'/lular iniurv are shifted to the Sta1e of ' -¥ ~ u.w iU-.,_ &' Cali .o.rn'ia under th,e~r__e_ ults_ ,tom SB 649 a here--· :ro ·e~c _ · d th·r;o_u. · h ·. 1ci e_a· the ~ ' - federal' regulator_v bar to such pro ecutrion of case a.g_ain -t th.e telecom'_Jr,dustry,~ 12. During the 901 ratepa_ ,er mon as us.ed t:o build _h · Int -. , t . uperhigh ay .. At . 1 a -more than thirt -·. million dollars. Probl m a from indu try tandpoin particularly in the regu ated ,context th fiber optic stems comprising the massi ,ely o __ ._ ct d In · rn -t u _ r Hi h wa j t too damn good. . -fi _ i _ nt. Bri liant companies w·-·t bankrupt because the systems were o fast and o reliable and could c . u.ch AAA_,.,...,1ve b d idth-· · cb ap h· ·. it ._r 1nor _ d ant g u tot C IA et a to move into far le r gulat d . ireless meaning initially, cellular Tbe Sup ·rhigh · · a ·. , till i t -now id ly call d dark fiber linki all majo cities and m suburban areas -_ urround'' g cities. here are man xampl , fiberoptic use in 4 · · outh Korea 1 often ited sho · ·ng the in,cr, dibly b tter deal the con umer gets -1th fib r optic In emet Plu no rad1at1on.. ··.any ten--fthousands of go d California J · · · making 1 cal ,conn ctions or higher · p1 d -far greater li _ liabHity mu h Je .-... co t, and no fire 1 • k . A aiding fiiie r1, ks, particularly m rural and emi-rural areas such a _ in -l D rado un -· · a cnti al con1 · -ration ·= b n con .. mplatin1 th advi ,-biUty of s :ationing thousand of ·automatic ... on power systems and power backup systems in th n · st--fire-dangerou -c unti 1 hav· -, , iven tb -fir ri k -· m th • diffu , _ high, subject-to-wind damage and maintenance requirmg SB 556 platforms. or each and all of th above re .-ons, SB 556 pres nt a high level of potential fi al ri :k for California uch that prudence requires mor tudy of these fi cal and ·, i ·tal impacts p,rior to th .· Bill reaching .tth _r loor .much le th Offi · o the . --· 1·.· or ... In addition r - ,e liability of our tate due o the busmess e~clu ions from coverage in HQ .... 3 policies. i b · p . ndmg legi lation is am n ed lat _ m .cour t ~ allo b ___ rad1 _ -~ n broadca .:hng antennas on private prop,erty homeowners who are sued · ill not even have co erage for gal de£_ : : wh th r· th ca. .-again ., that land n. r i • r , a .'em. nt · iolatio · , r a th tic ,concerns about health under the· decision of the 1Califom1a Supreme Court 1n ·~·1_ obile West : C ~ 1 • anc· ·CO 6 Cal 5th 1107 ( 119) o u ·der on1_ act - ,egligence. J 01nt . · nture, g ncy. ll.. ·,'--PARA 1-1 OM 'FIS .-ALMERI . · 556 T -B,ILLHA ·, PROCEEDED THRO . a I Tl ·_ · COMMITTEE PROCES I VIO·L · no,N OF I, D ' PRO ' I - -, pir _ tecti , f the g -rn1 . ntal wor pl c ha -ac " d hu I hall ng -tho -e o ' u ·ho hve o have business and family in . acramento wtll understand hat happ ned at Capitol I all better 1 -an the na ional nightly has tun o r _port ·. egisla -r .. and _ ta " face legitnnate .n«?ed to get the · ork of go ernment done in the mid t of an unprec,edented ,tate of fear from Covid 19 The profe , i.onals 1 ,ga,ged in the wor · o ,. ovemment have had t impro i ~ in con , · ts in · bich form ,_ t wa The egislature s long term adapti e reflex has been o unnecessarily · .· eep pow r a~ ay fro 1 con itu nt -.and , D1C -ntra it in th -p · fe sional h Ion . .. A t -oth ~r productive· realms, advancement in approval within the go · ,eming Party is no the most _ onduci · l e-ment t one' , b mg ano--d vocar 1tion . p · ition and cone rn . on legislatton.. For e-xampl,e up until Assembly Appropriations made th . rroneo , , no fiscal impact inadvert · nc; ---referr . I to th _ __ lo ,r of ~h -, · ,enat · . I a on of th . p ~ -ipI _ 5 ·appro e to speak I r two minutes against · 556 at Appropriation-.. Then it as r J~erred out under 28 -,8 . Th __ -, is no rational c · ., u _ _ const , _ . nt with · •. ahfi mta law and th -rule o de1no -ra in California for anything near this level of unn -cess.ary and utterly 1con trictive violation of :h _ fundam ntaJ ri ht o th _ public t ' ag , activ "th C mm1tt ar1ng hich ifby Zoo~ for example are till subject to nece.--ary limitations on time each allowed. 1:: 1 rybody m the pri ctor -• m bu 10 _ , s to a t corp, ,r ion t · r _-Ii ,-iou mst1tutions has b,een using Zoom or other · 1deo nteractJve . oftwar1e· uites for in eractiv,e gr up 1ne , :ing Covid ri k. Few· if any ec __ f 1 = -risk , nd ubj ct to w bma ter c ntr l ·. ince: 1850 ·aliforma· , constituents ha _ . had the ability and under the law no'1 · cl arly th _ right to att nd and offer vie . oint at I gi . lative· . ommitt ·. · m etin -" Whil 11 1s understandable due to th ~ Co id pand ·mic that 1n .. person attendanc• · could b -· '.·u pended but " . , tead of imp,lem · nting readil · availabl · ·Constituent engagement t . hnolog:ies in wid u e , 1 wher:. those in political ,control m Californ·ia liave implemented II comprehensive ~ ./,ut down of constituent comm,,enta·ry . .. · d -rtbe · ... l y Kan ·· .p,en . , ting and i,; C· mpan, ith 170 ·. ears of California history constituent . are ent t ed to attend and oice· therr · iews at th e 01nmi ·. -. meet ·ng -, which a -. • · uppo d to be O.P . · ·. w in · · -d p t ·on · mu t app,I a I did to b com an ·appro ed oppon n : ·· at an ·· hearing on a pending Bill, 10 which case ·_ · ,o such approv d personabtie -h·avin ._b_een_a~ roved in~atlJ!alJ'ce b ·the ,' ame Commitiee which will hear their test,mo·ny .. will b given .• m1nut,_ · . ach. Those wishing to otherwise communicat · are encouraged to go to the L,egislatur , · , b portal -A.t th. b por1 :al th ~. ,con, titu nt find~. th . opp rtunity _ , check th . box . ~ to · heth,er favoring or opposing the BHI and then tb.ere's at xt box whi.ch has a bu ■dred e r. l1m·t fo con t1 ·u . · t t _ fill 1n h r r · a · · n _. J __ voicin · .upport ppo · itl · n to a Bdl 1s not the binary reason for :ta ss testimony, mo people· want to .sa: why' the ·i favor or oppo · e a. Bill. That -art ha , _ ~ _ 1 effecti-Iy cut ut For f who ha-taken -_ hours nece sary to p,i, pare a formal le, ,er , ther, t an attacbm nt opportunity_ . hich apparentl sometime : work although one ad · o ate got ba. -k a 'limit . d to ] 00 . -· .aract,et- n.ote wh _n th , atta hm nt of a letter · . , r p .at _ di atte1np d.. -h ·' , nate has .made n attempt to comply . "th the la specifica ly the Bagley-Keane Op . ·n. ,eeting Act . which -uldha · · n.ac _·omtnod ·,d-like -· rybod I wdh .. 1nb in :t _ada ar hambr approach bas so far been found indelibl. convenient. ,u · .· 'ir t -, · · dm nt r1 -·hts bou tat ultimate e p -n e ar 11-· trrunp _ d h re~ the operatio al reality that citi en input o the legis.Iative process has been curtailed to such mm · sive ,_ t nt thst th -· Cotnmi · , . wh1 _ h are tr turally i · place t · . · . igh t 1 • :alue of I oiU · 6 before them are no -deciding · hich two · appro · , d oppon nts -are allowed to have two mmute · p· os,~dl, n b hal , th --a y. Rerpectfull . this ·appr d oppon nt,· and appro d proponent· appr ach i clearly un-Con ti 'ional b caus among other rea on there are· n,o tandard· for as e ing ho . to mak _ u b appro ._ aL Also w:l10 Jias tl,e right to make ucb· deci' io, _ appro . ing whom W'ill l)eak, fo·r example , ifa majority .of the involved ,Committee a/read likes the in·volved Biln wa idl .· · --~~ut a 1 , · for mo of a month. 1 _ ~n a , ad a , informed due to tlie pending deadline for matteri having fiscal consequence he B1U a , uddenl. n th _ cal _ndar. 1 . it has b -. n ta -, --~h ar n throu ~ · 2:8 , 8 by , mbl . pprop,riation as ha . ing no fiscal cons,equence. This ha · ,e utter and complete effect of cutting off on titu -· input. Thi wa d a g d t th d adline on th ba i . a i w · a fl -cal bill and then it was -ent out to th -Floor n the ba i that it a not a fiscal Bill . Wh were h r only tbr ~ day · ·tw en two ·ommittee h nngs in 2021? :e f .. ct of· his was to u off an· pracb,c. · any r ab, t1,c chan1c -or pubH participation. E though SB .. 556 as able to be heard as arly as March 20 it sat idl1e for nearl a m nth d a n t -h dul -: a 1 the ,-n lt tandm C rmn·· : . , n n rgy tilib -and Communications unt1l Apr 19 --nearl 30 days. la er. Then hen challenged on why the Bil -a · a i n · to th _ -r 22 ,1 · hear , g and n nth th r availabl -dat -, ·, ay 6. th reason gi _n was that it wa a Fiscal Bill and had to be heard by Apr 30 .. 'Th· al o d onstrate that · · 6 bein Cai~-n off th May 10 202 I -: at _ ppropriation Committee ag nda --citing 28 .. 8 a B 5. 6 having o, fiscal con .. equenc,e -"" · as not jiu, '1 ified. Th e completely c. t off con •,:, ·,_ nt input This Bill was dragg d to the d -adlin _-n the b·_ , i_ that it , . a ti -cal bdl, and then it , . , nt dii ,ctl to the · enat _ fl r on the ba i. that it ·as not a fi cal BilL · B .. 556 ha signifi1cant fiscal impact and needs · ob add .. dt ,t Mayl7 ,202l 1, a,. App -, priati '. · mmr nd _ .. ,ide -,_ mthe1n._nt of this BHI-in the . ay SB 556 has so far been hand]ed shows that the process n .. ed wor .. un·1 ik . th c mmodati,on whi _ as mad £ . -el ' ,,.,..,.._...,._magni ti n mti -- Californians wishing _o offer , B, 649 testimony in 2017 ·hich accommodations ere a compli ·h d for 649 i · , · oUo 1n _ 01nm·•. _· ,. A ·mbly .~ al ov mm nt A embl ommu cations d Con _ ~nee, A -embly Appropriation . With B 556 th re ha bee · · ·o legall r quired dialogue from the L gi lature de pite ADA application. ,_ 56 i agu due to th lac I an agr d d finiti n for ha consti t ·· a o ailed 'small wrreless facility.' Since the da of California by ta"ehood on Septemb r 9 1850 n titu _ _· hav h d th .abil · to 1n _ 1th th i, , 1 gi lat and , ~ .1. ,r · taf£ and 1n particular o attend and presen viewpoint at meeting~ of l gi -Jativ,e· Committee .. h . has no 1 b _nan l -1ctr ni r _plicati _ fth -t .l pho I a."""'""'-'..:1 , t, a whi1c - has been normally a _ ailab le to constituent for d ades. Often, constituents :i.,,', ... ""' ........ ·u. ... g to reach .., .pecific staffers are met with non-specific voice mails about how tough it is to make things . ork pro erly.. _ on _ a y to thi ailure to apply readily available te· hno]ogy -if taffe·r a . orking · om ho1n1c then the phones u ed to r = ach those ta -er for I gislati should be government issued phone s. 1 · ems which ork reliably and consist · nt · and in a patt, m . n · more no I · ·-· r _p,b a.ting .· ·· ·. t wa in place pr. -,pand -mi Instead caller are routinely told that a •. ought staffer cannot be r,eached becau _-. that staffer's pet onal phone' 1 , u : ed or bu, ine . and w-7 an t gi , _ t per _o_ al phon = nwnber · _ taff h· . Id hav _ . e=n provided ith governmentaU ponsor,ed working phones th working voice mail. Instead h _r _ ha ' . n at b -p1 c -m al cell ph n man g _·ment. Th. coul , hav _ b __ n handl db OIP 1nto e erybod ·s ho1ne. 1 here no technical or medical reaso · for this shut do n of · , _ abilii f the go emed to r, ach tho , ho o rn becau __ this p , blem se·t has all al n b . n read I· capable of technical solution., Th -r · are now nonsensical rule ubject to unpr .dictable enforoe:ment -such about p _rsonal computers a Hearing ·· .. · · i --the · nate pro ·· 1btt _ bringing co1np ,.ter in.to th · ··. hamb r ven pli hibit -tablet ,computers the· Ass1embly, as ha · alway · been the ,case, has allowed laptops and till does. In th _ A s _mbiy _ al o itnes ar: abl ~ o work a ciii nj um li t 1·-ut on th _ · _nat · 1d there is no such ace .. Even a portfolio as used for a legal pad is not allowed in the Senate nly th bar _ l gal pad and a p : n. Thi , i arbitra -and cap, i, -iou b _ au -e at o -, _, ins tan _ -th ame citiz,en was allowed in · ith his portfolio not . book, and the ne· .. ·nne it -a not allowed. W _ know that Zoom c uld b: u _ d b . au· e one m mber '. most committe,e, - typ1ically J . · I on , ill appear at a hearing via Zoom. In many of th abov· individual instance Constitut1 nal entitlem1ents in luding as protect · d b_. Cahfiomia statut have b · -n abroga , d in vi I, on o 'th .· Due Pro . · righ mcluding deprivation of conSitituent right to r e Speech and Assembly., As these Stat .· .ction , a 1n th -1 I' tance _ · _ndividu. J violati • n ar th _ 1 • ·-at -r ind lible pL 1 • r ts a confusing montage of uncoordinated failures to us · modem technologies and :a decis.ion to d .ploy h · : · top d · · con tratnt in, t ad which r, c . uld b ~ 1,_ pp d a-d updat d , ,•nd in particular aside· from th _ m, _ rits SB 5 5 6 should fail for 1t , many ue Proc . ·' violations~ III A ................. , APPROACH _HOWS ~ .. AT ACHL G ATOR AI RE SONABL '. RIGHT TO VO I ' ON I . BA ,o co CIENC .. =-I-M ! ·y A ·,p: . · RO ..'. TRADI ·c_10 1 Thi __ ction d fl nd , th · unu _ual p . _1tion .· pag 3 ,_ fth r fi .-need p -il 141 that: ''It is respectfully noted ,that any Senator or member of the Ass,embly has the unencumbered and free speecl, right to decline to --uppo.rt any bill because of tlrat Legis.lator's moral concern , with no lawful obl,"tfation to thereafter exp.lain:- If a enator r · · s 1nblymemb r has determined tha it i m, raUy inapp!ropriat to allow th · idespread densified deployment of indu trial 1nacbiner for the purp , of di -,tribut1 _ known _· -cinog -ic nicr a radiation i i . ntir -J . th rtght f uch Legislator to reject this vast dense micr ave deployment. Therei no seriou · cientific , . u -ti , , -_ to wh th -r the -~ llular radia:i . n 1 _.--inog ni · the $2 · million ·-. 1: -_ tud 1 H has ettled that question ith a ,, •es (NTP r,eport as initially announced on 5/27 /l6 as the pan I ___ .,,.._ alm · ,t two y a1;-f pe -r -1_ w at th ~ .ar, . · rian l pe, r r vi . conference on 3/28/18, wi h addition of the cl -ar evidence,,· language, and a -.hown in the final 1. • Prep _ rt on about 11/ / 8. ,e t t e_ and ..:..::....:.~:.::;.:..::===· t.:..:•o=r .. g . rences 1mbue each r ader · itb actual -owled,ge· of these hazard t , · ach reader s constituency. ha enat r ha · a du to tak a tual -i nc into · ,ccount i b · 1t If pn1n , reason for this letter. Yet re iance sole[ upon on p _rson favorite conclusion based on th ·ma i _ I , -, -r-bri ad t rm ' ci nc ·. a h _ ro t natur , 1 ,~xi t n i -incon:_. ". · nt 1th th1~ documented massi oids in the o-far-failed attempts of our finest osmology scientists to bj _cti ·~t dmo it f◄rp •,inent --ampl ·th _mchni --11 of .·h1 B,igBan. hi -h ·m between osmologi ts, is due to the extreme dispu _ -1n Cosmology as to the r liability of ·:hati alldlnflaf in iBangTh ry. To --n ab --01 :·erul ,utlook ·-m,etim , ,ound 1n th · modem intellig n 1a i m th Cosmology of modern ph 1c is utte ly dep•endent on a sci n "fie id a called Inflation i a capital I.'' In aioni 1curr -nty id -lyac · pedin ·.mology · ess -nttaltoth _m th -ma -i al urvival of Big Bang Theory. Inflation · as remained the c m rstone for the· survival of ·. -1 ntifi all ustainabl Bi -ang th: ,-· inc i __ nnoun · ,m nt b _he fa:h r of -flation · ' physicis _ Alan Gu, b in 1981,. P hair 1n rinc r ma1:n _ d a tr - advocate of 'nflation for more than two decades. When Dr. Steinhardt was a inner o the .irec Pri in 2003 h is n · o the o Id top ~ -perts on Inflation in o .... ____ _ , ars lat r m a co ·· r articl m ,cientifi · . nerican with al -ulations demons, ·a _ d, Dr t "nhardt offered proof for hl , position that Infla _" on i n t mathematically p · .ible. nt -ci tific Am r an arb -I cone -ming wha w · o k Times sci 1 nee journalist Denni Overb · e calls -a crisis in Cosmolo ~· 'The ,core point IS not who 1· r·ig'ht or· ron: i· -· he I fl tion ar· um nt, but tltat th .argume _ __J_ ts . ,al : on of us : ould be· bullied e · · time somebod arts pontificating on what om .supposed unitary , -ion of ience_ a It~ o. ay tor cognize ·hat science i -.. elfb-i nature i -, . tud of it own imp rfi ti n . D p,·t what may be r ad in th p11 _· ~ Big ang one stilt pon whic I moral relativity re ides is at I ast as to th -· 'ho also currently a faith- ba ::d b -li _-~(for an 1h re __ m l th a -__ nc _ 1 • , piric l proo fi ·. ev r p ·pu]ar . t ing Theory -· e Not E , en Wrong by Dr. Gr -ene's Columbia ,colleague in P'hysics Peter Woit)., ith hum , 1~ -· d . alth a tak "Hi n -.-peopl . 1 1 not u -,, 1cie.nti 1c to r ·J upon moral guidance viewpoints as factors in deci ion tnaking abou hether to · ote or a major B 11 Th lariz, d di put in 1 'ig I an _ • ory du _ to Inflat1i . i pr -. · -d me -· . · t · illu trat that ther -are 1nultipl,e co1npeting faitb-based vie _ including wid l publicaU , erceived ,cience . · n one hand and an alt _ mat1v _ way o living . bich tud cience i · u · v • C riou " 1 · , t _ till r tain the intlu nc o~ · Id r t a bing . Many legit" ate tributa ,·es of c1entific thought lead u to recognize an underly· g t ndenc t c ard ' t _m _or _nz Man lbrot I ' hm s ha -volutl, n V ", 'I ttrn to complex and ultimately conscious system asse:mbl be likel .. Alwa ith thanks to James 1 ·c · r Chao-, Tire Birtli of a New . C'tenice I b oks. I o on mor 1 rJati L ~. odern Times, b th late Paul Johnso . Also arguably rele ant her Seth Lloyd''s Program'm.ing the . niverse"• 1Quantum Comput r Scienti' ,t Take on the· Co mos. A thought xp • riment i uggested: If it i assu1ned as is so · id ·1y searched-for . that th _ r _ exi ts an ultimately indi . i ible con · it .• nt to the univer · e u uan pokJ n fas a article and ther_ :xi_._ · in th univ -r -ven locally, an un rlymg and no · --· .n- documenti d tendenc ,es towards system not enttop as seen through Chaos Th ory, such ,c mbinat .on could I r billi •. of . ; t nd t ~· ards or -an·zed -tructur,e. i_h a gi n tendency to system, indivisible ultimate uh-atomic particl1e could pr1edictably o er bil ions fyear ·1 " in , mputa ional co ---;"l, u n .. . one· of this .ms sought to be stated from an religiou perspecti e, the matt r stated here are -, portiv an Agn ,-,tic vie -int. Y1 for all of the man · fault in r Ugiou - institution , the tracht1ons of,.• eeking goodne and fair treatment permeate th · attempt . of developed all cultur, to deal with wha -ha b n hi toricall percei · d a a p·"'·"··~·rful :fi rce V CO CLUSIO . SB 556 pr,esents se ere hazard ofn gativ,e fis cal con _,equenc,e to governmental and tility n 1t wh'" b c · m : ll _dint ___ ntract -ovemm -nt , , _ ,_ andlord , of Teleco1n When the antennas are affix d to the poles or tructure merger· takes plac under the D10 trin. of ixtures. and ·th ~ r sultin . D· n erou -o diti n of Pubh -Prop rt · i , -o-owned by the nti _ in 1 d. 10 all seek l gislato , ho ·will take enginee.ring mto account and fairl balance and tb oft n competiti testnnonies fro1n · .cientist·· -·ince we o infrequently encounter e _. ,ct · ci-ntifi -agree-ment · hen va ,t ums ar , at stak •· Voter . are not trying to elect a -pock or a Kirk, .but .reasonable h.uman l,,eings _wlio will aJs,o take b,ein· human into account'. Being human 1n I , _d a ar, ne moral rin 1pl i 1 th ab , -of th m ra'l hm1t _ · hi _b ,clinicians properly label as psychotic. Voters want honora~ble people., So say we alL ObJ ctlv 1 ,gal risk · · 1th fi ,cal -a ard il u trat d be-th fir fighter · mption justify opposition to B 556 b -cause th reby the known ,effi cts on D .A are tak.en into account _ _ a -ain --=~~.:...;;..;;.;=._, Y t li o -childr n and adult ar at -t -.• .-en we continue to treat our population as .• perim ntal guin a pigs by constant multi-axial microwa. e r.adiati n., Thi' -· b uld not be allowed-, -'lther th _ phy ical r1 k or th · health concerns under 'T Mobile W,e · _ ity and · -ounty _p ___ ~~n Fran -·. _c_co, sup,ra .. Wh ·n making the ,cientifically correct choice about the known effects of mi,crowav _ radiation and _or evalua _: on of fl _ al ri k b r _ fi rral t A s _ 1nbl Appr p,riation -ii , al o cieniiflca'll permissible to resort to ,thoughif ully rely on traditional mor,al outlo,ok to oppose this Bill .. Inth ·930•·, thegreatbarr1ster 1 ·1arenc _ -arrow an gnotic was one a -k _dto be,come th , leading spokesperson for a prominent national Atheist organization. Darro _ ponded, -I don t know i -th -r is a Ii -after hi and y u don t -if th ~r ~ i, _ but u pretend you do, and . · ou ve er ated a religion all I own out of it, and I want nothing to do, ith it · Th _ bott m hn i that we mortal humans -don t know ' th JI hito -of thi universe , e grasp · 1th r asoning 1nmd . Let u . together as ume that Mr .. Darrow has a _ oint th1e possibility of some form of :sup~ ·rvening consciou -,ness is no typicaU · knowable to wh I 1bor herie in our tran~1 ory mortal forms · 1 ven that di pa " ionate Agn tic appr aich does not support the outright rej,ection of the standards about right and wrong ·, hich r sult omth thousands , fy_at thr u h --hichour p -c.i _,aru1iculat _d t ,ndard --donth belief that ultimate responsibility resides with the indi viduaI choo mg the right thing . . atyagrah 1 .. aJtfC) · 'arry V. -'-,eh1mann , 1 H Color Laser Jet Fax Co May -11 202 4:30P Job 327 Date 5/1 1 /2'02 , Time 4:21:51P M283fdw • a Jo Type Send Identification 19 66514940 Durat1on 8~57 Pages 11 Harry V~~ ~DmiD PriDCipal Attorney La , om: : · o1 Har,cy . t.ehm■ 1:1 ,c 4 Vin:eyarid CGWI. ,..·~o Cali Olmll'4 ·47 AJeaCode 'JS· Te opbone, m .. 2u1 t·~simk · -, St , ·a Ul 2.021, Senator Bm Hueso State Cap Room 4,03S Sacram C 9.-SI l4 Via F · ; (91.161)1 6! 1-4940 RE: (1) is:cal .risk inbere1u m SB 556 belies tltc: ·1ra:nsfe:r to the· ffla.te Flo ·pc:11' blo 28.8. (I]) Jn i1ion 10 fl · · al risk, Ike maM -in hj' h tl . BUI -Meil: ptr cd l,hrnna:h, die C mmiJUH -imor to, the .28.1 i., ha$ viol ltd: · tc and "oo.. (DJ) lt is:sei DWical ly sustain ble: o, vote ag.amst SB 5 6 • of moral objewMt I radiation consequences. lbh, domlment is submitted to ea.ch Ctdifomia State Senator tc,1 asmre that ,e :h of,·. SCnaton rooeived Actual • ce of the ad. and heatllh . u.enoo whidi clear . _ i.ncing :u)d res-u ' me SB 555. 1 noced n p · if SB, S:56 • k'.nL _ fler tb AffllOt-pi,;n;in,1 NA'l'01'1m1Ja ·ro muatratc omnem: oocss. to Committee mecdogs am ~ that the most :powemd ,calil(Qtioos ~ · . your com11itu -aroun.d. -· airuent. 1· o1b,jcct. 18 lnwycr lc,nm are man.i, -011ly o -· . a, mlgnt - i , &o chtdlcn _ md ts to, I, l}'ll. ,'-. id, I hu'iit , ' approach tOWll'ds tms I . le:ittr def ends cme po bits wHh , ppon:ing aooota • • ,SB, SS .·· . ma.d enea · _ d to the fl, . · Seri-te, i '. · . Hearin 011 M<rsmy M y 10'\ : uuh P!!lr$ .. ~. Rule: 28.8 b.: •no fbc J in,: ·, · 56 cannei: Iaw£utly hav been so refemed by AsselJl&ly .J\ppropriatiom beca:us.e ev.idm.ce in the S:S . 56 ~im:i p eke.ts mem : · 011ss:huw wt SB S 6 . . f fis~ · · of potcn: o · ' o . ~ . I fQQ . :lit, ~ ·, · -: ;e BiH SS , . Se settted the IResullt OK 8 Baumb, Nelly From:Nancy Alfaro <alfaro.nancy@gmail.com> Sent:Thursday, May 13, 2021 2:01 PM To:auditorgen@paauditor.gov; budget@pa.gov; RA-ethicsRTKL@pa.gov; achristman@nelp.org; bchen@nelp.org; dberkowitz@nelp.org; gwentworth@nelp.org; krole@nelp.org; inspectorgeneral@cpsoig.org; cmoreno@aft.org; BlackwellJ@ctpf.org; ReillyM@ctpf.org; RedfeairnG@ctpf.org; CavalleroJ@ctpf.org; WardJ@ctpf.org; jwaddell@aft1521.org; lmarzillier@aft1521.org; sharonaft1521@gmail.com; lahc1521@gmail.com; parkcj@lacitycollege.edu; robbdm@piercecollege.edu; mindy@post.harvard.edu; shewfeo@wlac.edu; russeltm@wlac.edu; coloche@lahc.edu; fenyesm@laccd.edu; lees@lasc.edu; guerrij@lattc.edu; theodore@uic.edu; gcities@uic.edu; AGREDAFE@elac.edu; JesseSharkey@ctulocal1.org; ChristelWilliams@ctulocal1.org; MariaMoreno@ctulocal1.org; StacyDavisGates@ctulocal1.org; nmonteiro@mac.com; drmarcelm@gmail.com; cofercw@gmail.com; jamesmckeever101@gmail.com; joseph.guerrieri@gmail.com; phoenixmountain2@gmail.com; Zknorr@gmail.com; Olgashewfelt@gmail.com; mcdowelljr@gmail.com; Pkallen3717@yahoo.com; Kyasuda62 @hotmail.com; rubybrou@hotmail.com; mmoon13956@aol.com; Sandraleephd@aol.com; sufiserf@aol.com; sanpsych@aol.com; wder@social.rr.com; wdelarton@socal.rr.com Cc:Mayor.Garcetti@lacity.org; mayor@fresno.gov; Daniel.Zack@fresno.gov; Mark.Standriff@fresno.gov; Esmeralda.Soria@fresno.gov; Paul.Caprioglio@fresno.gov; Robert.Andersen@fresno.gov; Leager@fresnoedc.com; Council, City; Office of the CIO; TomforCouncil@gmail.com; Ng, Judy; LydiaKou@cityofpaloalto.org; Kane@cityofpaloalto.org; Carnahan, David; Stephanie.Douglas@cityofpaloalto.org; Yang, Albert; Patel, Raj; Auzenne, Tom Subject:Fwd: Illicit Financial Flows, Trade Misinvoicing, and Multinational Tax Avoidance: The Same or Different? - EY-Wal-Mart as an model - V2 Attachments:illicit-financial-flows-trade-misinvoicing-and-multinational-tax-avoidance.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.     Begin forwarded message:  From: Nancy Alfaro <alfaro.nancy@gmail.com>  Date: May 13, 2021 at 1:31:32 PM PDT  To: sbarragan@aristeguinoticias.com, redaccion@aristeguinoticias.com, careyshenkman@riseup.net,  courage.contact@couragefound.org, transportandoamichoacan@live.com,  periodicooficial@michoacan.gob.mx, buzon@poderjudicialmichoacan.gob.mx,  Comercializacion@telesurtv.net, Albinocm6502@gmail.com, JuanJosedelCastillo@gmail.com,  Borderlinebeat@gmail.com, Charropoliticoenvivo@gmail.com, Conexiononline1@hotmail.com,  wells@wsws.org, autoworkers@wsws.org, sep@socialistequality.com, Norissa@socialism2020.org,  joe@socialism2020.org, Christine.s.Richard@gmail.com, Aaron.Greenspan@plainsite.org,  realitycheck@plainsite.org, VeritasTIPS@protonmail.com, richard.clayton@ctwinvestmentgroup.com,  noe.cruz@eluniversal.com.mx, denuncia@eluniversal.com.mx, contacto@eluniversal.com.mx,  atiempomx@gmail.com, indicepolitico@gmail.com, Investigacion@elpais.es, jlsc.ua@gmail.com,  WorldsApart@rttv.ru, charles@russia‐insider.com, moderator@russia‐insider.com,  radio@sputniknews.com, mediapartners@sputniknews.com, advertising@sputniknews.com,  media@sputniknews.com, marketing@sputniknews.com  Cc: urgent‐action@ohchr.org, ethicsoffice@who.int, ethicsoffice@un.org, cdhdf@cdhcm.org.mx,  quejas@cdhcm.org.mx, cdhm@tlachinollan.org, aclupreferences@aclu.org,  communications@aclusocal.org, press@ccrjustice.org, info@insyde.org.mx, info@amnistia.org.mx,  9 carlos.mendoza@amnesty.org, duncan.tucker@amnesty.org, daniella.gac@ulagos.cl,  tribunalpazecuador@yahoo.com, Victor.cabezas@estud.usfq.edu.ec, asuntoscorporativos@clarochile.cl,  marcel.theza@ulagos.cl, thelmstetter@americansfortaxfairness.org,  dbailey@americansfortaxfairness.org, aorozco@utla.net, albert.lowe@utla.net, acaputopearl@utla.net,  alau@utla.net, Management@usfca.edu  Subject: Fwd: Illicit Financial Flows, Trade Misinvoicing, and Multinational Tax Avoidance: The Same  or Different? ‐ EY‐Wal‐Mart as an model ‐ V2  Thomas Flannery (EY, Sr. Audit Partner)   Co‐leader, Americas Wealth and Asset Management, EY Boston    Cyberattack:    On May 12, 2021, an updated version of this email disappeared into a black whole in space after I  pressed the sent button. The email "appeared" to go out as usual, except  it didn't registered on my sent  inbox nor did I received any receipt confirmations from the intended recipients (i.e. United Nations).  Refer to email distribution list below at the end of this email trail. (Second cyberattack incident)    The above incident occurred early in the morning hours [ ~5am] after I numerous attempts at  forwarding a separate email were blocked. The subject of the outgoing email blocked is:  "Cyberattack  Forces Shutdown Of Largest Gasoline Pipeline In United States | ZeroHedge". This was the first email out  of four emails I sent on May 8, 2021 to a small group of recipients below. (First cyberattack incident)    Most importantly, I spent several hours starting on March 11, 2021 updating and adding context and  information to the email below, including cleaning up the writing and grammar. Apparently, I can only  write at kinder garden level. Consider the implications of this on you (email recipients) and to others  since I don't really have "shitty"  grammar or writing skills.     Reminder: everything I write, read, re‐review or click on the internet is being read an analyzed in real  time. Translation:  The updated email below, which was sabotaged was read prior to being sent by  opportunistic fraudsters and then it was confiscated and stolen. I don't even have a record myself.     This is the exact same thing as the incident involving the confiscation of my entire email and Goggle  account on November 18, 2020 and with the email and information being sent to Veritas. I aren't the  ignorant winy snowflake who missed the gravity of the crimes involved in attempting to confiscate my  entire Google Account. It's like the Italia Mafia walking into the DOJ's prosecutor office during a mayor  criminal investigation, and stealing all the evidence from their offices while the criminal prosecutors are  present. And Italian Mafia's offense would still look like a petty crime next attempting to confiscate my  Google Account and Gmail. The crimes involved are jurisdiction of the US Foreign military and National  Defense.     The methods and tactics  being used to disrupt and sabotage this emails (electronic communications)  just keep evolving. Nothing has changed since July 2019.      I am the Public Auditor.  Risk Manage Accordingly.     Below is the May 8, 2021 email intact except for adding the email distribution list  at the end. Since you  those included on the email below had several days advance notice. Risk Manage accordingly as four  emails from Saturday May 8, 2021 will be forwarded to the expanded distribution list.     Dumb People stuck with their head in the ground got caught with their pants down in the Market  Meltdown,  Elon Musk and Crypto‐currencies, Colonial and others.     10 In case you are oblivious, there are Foreign embassies in Mexico (including Russia's). The United Nations  Security Council is at the UN as well. Caritas is a network of religious organizations around the world.  There are embassies and politicians in those countries as well. Hint:The Vatican. Remember it was a  Boston newspaper who broke the Catholic's church pedophile scandal and knocked down the Roman  Catholic Pope?     Wait, wasn't EY also involved in crippling the Vatican Bank?  Catholic Cardinals were found hanging from  bridges remember that.  Remember who was the private security psychopath giving his expert opinion  on whether a catholic cardinal found hanging from a bridge in London (check the city) had committed  suicide or was murdered? Hint: Its related to Wal‐Mart and KPMG's Security Background check  in 2016.    Meanwhile read:       Cryptos Slide After Report Binance (World's biggest crypto currency) Under Investigation By IRS, DOJ |  May 13, 2021  https://www.zerohedge.com/markets/cryptos‐slide‐after‐report‐binance‐under‐investigation‐irs‐doj  It's not a good day for cryptos which after being hammered earlier on the Elon Musk reversal, just  legged lower after a Bloomberg report that the world's biggest cryptoexchange Binance is under  investigation by the Justice Department and Internal Revenue Service.  The report notes that "officials who probe money laundering and tax offenses have sought  information from individuals with insight into Binance’s business."  Binance ‐ which is led by Changpeng Zhao, "a charismatic tech executive who relishes promoting  tokens on Twitter and in media interviews" ‐ is incorporated in the Cayman Islands and has an  office in Singapore but says it lacks a single corporate headquarters.   Chainalysis Inc., a blockchain forensics firm whose clients include U.S. federal agencies, concluded  last year that among transactions that it examined, more funds tied to criminal activity flowed  through Binance than any other crypto exchange.  To be sure, in the aftermath of the Colonial Pipeline ransomware hack ‐ where we learned that the  hackers were immediately paid $5 million in crypto ‐ it was virtually inevitable that there would be  some blowback.  “We take our legal obligations very seriously and engage with regulators and law enforcement in a  collaborative fashion,” Binance spokeswoman Jessica Jung said in an emailed statement, while  adding that the company doesn’t comment on specific matters or inquiries. “We have worked  hard to build a robust compliance program that incorporates anti‐money laundering principles and  tools used by financial institutions to detect and address suspicious activity.”  11 Meanwhile, Zhao has said Binance closely follows U.S. rules, blocks Americans from its website, and  uses advanced technology to analyze transactions for signs of money laundering and other illicit  activity. Last year, the firm warned that U.S. residents would have their accounts frozen if they were  found to be trading, crypto trade publications have reported.  Bloomberg notes that along with the CFTC, the Justice Department is likely to examine steps that  Binance has taken to keep U.S. residents off its exchange. One person familiar with Binance’s  operations said that prior to the establishment of Binance.  Americans were advised to use a virtual  proxy network, or VPN, to disguise their locations when seeking to access the exchange.  Jung, the Binance spokeswoman, said the exchange has never encouraged US residents to use VPNs  to get around its rules, as doing so would be something “that has always been contrary to our  company’s principles.” In January, Zhao tweeted that Binance’s security systems block Americans  even if they try to connect through one of the networks.  "We have implemented strong access controls that have been tested via external audit and are  under continuous review and evaluation by Binance to ensure that the appropriate restrictions are  in place and are effective," Jung said.  While the subject of the DoJ and IRS investigation wasn't revealed, Bloomberg's sources said the  investigation is being led by the DoJ's bank integrity unit, which probes complex cases targeting  financial firms. The scrutiny from the IRS is a separate issue, and has reportedly been going back  months. Whatever has been happening, the revelation that a ransom payment was made in crypto  means authorities are bound to try and follow the digital trail (the blockchain is open to public  scrutiny, after all).  With investigators knocking, Binance clearly stepped up its presence in Washington and retained a  former Treasury Department official and top white‐collar defense lawyers to represent it in legal  cases and matters being reviewed by regulators. In March, the firm hired former Sen. Max Baucus, a  well‐connected Montana Democrat, to advise it on policy and government relations.  This isn't the first time US regulators have launched an investigation into Binance. Back in  March, Bloomberg reported that the CFTC was investigating whether Biannce, which isn't registered  in the US and thus doesn't allow Americans to trade, allowed US residents to buy and sell  derivatives that the CFTC regulates.  It was perhaps the first ripple of what many fear might be a bigger crackdown in the US, as  prosecutors come after one of the world's biggest exchanges that they effectively helped criminals  cripple the American energy infrastructure, an economic strike against American civilians.    12       Begin forwarded message:  From: "." <alfaro.nancy@gmail.com>  Date: May 8, 2021 at 11:37:21 PM PDT  To: thomas.flannery@ey.com, tfflannery@gmail.com, susan.cote@ey.com,  susan.rothfels@uk.ey.com, tracy.koh@my.ey.com, kelly.musmanno@ey.com,  Alexis.Lucas@ey.com, kathryn.tominovich@ey.com, carmine.disibio@ey.com,  Patrick.niemann@ey.com, thomas.flannery@ey.com, mark.weinberger@uk.ey.com,  michael.serota@ey.com, mark.gutierrez@ey.com, michael.odonnell@ey.com,  joost.hendriks@ey.com, david.cormack@ey.com, jim.mccaulley@ey.com,  marc.roberts@ey.com, gabriel.marquez@ey.com, roger.yang@ey.com,  sandra.burns@ey.com, gregory.feng@ey.com, greg.glater@ey.com,  david.statman@ey.com, troy.jones@ey.com, allen.freeman@ey.com,  keith.lupton@ey.com, michael.johnson4@ey.com, robert.moritz@us.pwc.com,  groa@deloittemx.com, sbarragan@aristeguinoticias.com, dchrencik@hotmail.com,  Benjamro@herbalife.com, Glozano@queretaro.gob.mx, Sedesu@queretaro.gob.mx  Cc: silvanoaureoles@michoacan.gob.mx, Marco.Lagunas@cocotra.michoacan.gob.mx,  manuel.valencia@cocotra.michoacan.gob.mx,  Transparecia@cocotra.michoacan.gob.mx, FOM.2@hotmail.com,  tribuno_alfa@hotmail.com, gobiernodemorelia@morelia.gob.mx,  GobiernoMichoacan2.0@gmail.com, transparenciamorelia@morelia.gob.mx,  Fiscal@morelia.fiscaliamichoacan.gob.mx, fiscalgeneral@fiscaliamichoacan.gob.mx,  pgjecomsoc@michoacan.gob.mx, sectec.despacho@michoacan.gob.mx,  sectec_segob@michoacan.gob.mx, denuncialosaqui@ssedomex.gob.mx,  denuncia.regulacionsanitaria@edomex.gob.mx, contacto@senadomorena.com,  SINDICATO@senado.gob.mx, SINDICATO969.transparencia@senado.gob.mx,  gobernacion@senado.gob.mx, Transparecia@senado.gob.mx,  puntosconstitucionales@senado.gob.mx, derechoshumanos@senado.gob.mx,  anticorrupcion@senado.gob.mx, hacienda@senado.gob.mx, justicia@senado.gob.mx,  marina@senado.gob.mx, webmaster@semar.gob.mx, cni@cni.gob.mx,  asuntosindigenas@senado.gob.mx, ninezyadolescencia@senado.gob.mx,  economia@senado.gob.mx, salud@senado.gob.mx, educacion@senado.gob.mx,  trabajoyprevision@senado.gob.mx, reformaagraria@senado.gob.mx,  agriculturayganaderia@senado.gob.mx, energia@senado.gob.mx,  comunicacionesytransportes@senado.gob.mx, asuntosfronterizos@senado.gob.mx,  comsegsocial@senado.gob.mx, crpp@senado.gob.mx,  seguridadpublica@senado.gob.mx, seguridad.nacional@diputados.gob.mx,  defensanacional@senado.gob.mx  Subject: Illicit Financial Flows, Trade Misinvoicing, and Multinational Tax Avoidance:  The Same or Different? ‐ EY‐Wal‐Mart as an model ‐  Illicit Financial Flows, Trade Misinvoicing, and Multinational Tax Avoidance: The Same or  Different? ‐     I am using EY and Wal‐Mart as an model example. Walt‐Mart is the largest employer in  the world ‐ Affects the Labor force and police violence and departments around the  world. Walmart ca't  just demand increased government budgets for the Police  Departments worldwide to protect its boxes while it decimates local economies then  turns around and snitches on Police when it suits them and points the finger elsewhere.     13   https://www.cgdev.org/sites/default/files/illicit‐financial‐flows‐trade‐misinvoicing‐and‐ multinational‐tax‐avoidance.pdf      EY and Wal‐Mart growth and tax evasion (NOT AVOIDANCE) and  business has grown in  parallel over the past two decades as did the violence in Latin America and around the  world. Read above. That's why there are companies call Factureros ‐ fake invoices in  Mexico. A billion dollars in fake expenses to deduct and represents  a lot of tax revenues  for tax authorities and local treasuries worldwide.     I am not going to tolerate Herbalife nor Walmart's crap attempting an orchestration  to  rat out a sitting president in Mexico in July 2018 (Enrique PenaNieto) nor threaten  newly elected Mexican president on July 1, 2018 Andres Manuel Lopez Obrador AMLO  with emails released in a bogus class action lawsuit in the USA and claims US Courts  made them do it. They need to look back to the US corrupt and failed US public  institutions and  criminals they associate with before  pointing the finger elsewhere.     Wal Mart Corporate Criminals and EY already removed their shit information from the  internet. Didn't both EY/Wal‐Mart said that US Courts in Arkansas made poor Walmart  do it?   FYI everything WalMart has been removing is public information and part of the  Arkansas and other courts transcripts and I have copies of it.      I was clear that Wal‐Mart did not spend  close to a billion dollars in training expenses in  a fake FCPA Investigation over bribery and corruption. This is what I read and refer to  not news papers.  It cannot just be pissed off and shoot Mexicans at its El Paso stores  and wine about Avocado Land (located in Michoacán Mexico) in public. I aren't an  American ignorant winy snowflake you tell fairy tales or needs a history lesson.    I doubt you missed  Wal‐Mart's bullshit to justify getting subsidized electricity at the  expense of Mexican Taxpayers and the prior Administration for giving them the  subsidies willingly. I was there in 2014 during the Energy Reforms remember? I almost  got killed.     Energy Security (i.e. Oil, Pemex, Electricity, CFE) is a serious National Security issue. It  triggers National Defense and the Military.    Wal‐Mart enlisting Bimbo to whine in Public is irrelevant. Bimbo can go out of business  worldwide before Wal‐Mart for all I and Mexico gives a shit. Did you missed that the CFE  (Mexico's electric utility)  was shipping electricity to Texas in 2011? Felipe Calderon  Calderon was the sitting President at that time.     The start of the violence in Mexico was 2006 when Felipe Calderon, stole the Presidency  from Andres Manuel Lopez Obrador  by sending the Military to invade Michoacan and  take over Mexico as he was hastily being sworn on December 1, 2006 and declared the  War on Cartels. Hillary and Calderon's shenanigans were outed in the US State Cables  leaked to Julian Assange, which he published in Wikileaks around 2010.     Wal‐Mart's emails and coordination with Hillary Clinton's camp were leaked in the  Stratford leaks.  I was never asking nor joking about the US DOJ dropping the Julian  Assange shitty espionage charges against Assange. Nobody is making the UK torture and  14 jail Assange but themselves.    Felipe Calderon communicating with was defending Walmart's  in April 2012 publicly as  Wal‐Mart's bribery and corruption was being made public. Calderon was touting Wal‐ Mart's  logistics/supply chain as a model to follow in Latin America. Read the fucking  news paper.     I was getting shit at EY on way too many fronts, including by new EY FSO Tax Partner  Mark Gutierrez, reporting to EY FSO Sr. Tax Partner Michael Serota, Co‐leader Americas  Wealth and Asset Management. The little fucker had  just joined EY Los Angeles after by  making out with Deloitte's entire Tax Practice in Los Angeles in collusion with by John  Plaga Canyon Johnson Urban Funds  ‐ Real Estate Funds. Mark was a Director at Deloitte  and made a new Partner at EY  in March 2012.  He hadn't been one month at EY before  he was already tag teaming with Audit and Real Estate Tax Partners and Jim McCaulley  to attack an EY FSO Audit Sr. Manager and his boss on Tax issues of EY Clients prior to  him joining EY.   Canyon Johnson was a smoke screen just the same as   Climate Change.      According EY Real Estate Partner Gabriel Marquez (Gabe), Scott Tornberg, PwC Real  Estate Partner had complained to John Plaga, Canyon's Chief Financial Officer that I  (Nancy) was trying to steal Canyon Johnson's real estate fund audits from him and take  them to EY's Real Estate Practice in Los Angeles. Apparently, John Plaga was as offended  as poor Scott Torberg  about my dirty business development manners that he instructed  Sheridan Masfeld, Canyon Jonson's Controller, equally pissed off to call EY and  complaint to Gabe about my shitty business tactics and attempting to harm poor PwC's  Real Estate Audit Partner Scott Tornberg. Scott was livid when PwC's Real Estate Sr.  Manager Kristen,  a former EY's Real Estate Sr. Manager working under Scott informed  him what I was up to. Outraged Kristen had found out from a PwC Senior that worked  on the Canyon account with me as a staff prior to 2008.     One just needed to ignore the fact that the winy snowflake  Kristen was naming as the  source was a PwC Senior informant  was a Gay Philipino male (South East Asia) who  reported to a Chinese Audit Senior who in turn reported to me on Canyon Johnson. Why  not use the Korean Senior on the account too.   The Chinese Audit Senior had joined Oaktree after I left PwC Los Angeles to PwC New  York.  I had recommended and lobbied for her at Oaktree to David Orkin. David Orkin,  Sr. Executive at Oaktree knew her work as well. She I was exclusive to PwC Asset  Management.  The Chinese Manager became a Vice‐President at Oaktree Capital.     I was on both ends of Kristen shenanigans between PwC and EY Real Estate. Kristen was  suspected of being at snitch and isolated from me by  Sr. Partners in Financial Services  and Asset Manager Sr. Partners.  She was in close contact with EY Real Estate Partners  while a Sr. Manager.  I din't even speak to PwC Asset Management or Real Estate  Partners, Sr. Managers nor Oaktree while at EY.     I wasn't a Sr. Manager in EY Real Estate since the fall of 2011. Canyon became "formally"  a client of EY FSO when Mark Gutierrez,  Deloitte Tax Director and "Tax Advisor" on  Canyon came over to EY FSO Tax along with Deloitte's Tax Practice in March 2012.    Had John Plaga and Sheriden Mansfeld had some common sense, I was at Canyon  before Sheriden Mansfeld, former Arthur Anderson Audit Senior joined Canyon.  Sheriden's predecessor was a Deloitte Tax Manager/Director who run out of Canyon  15 after a week on the job.  I needed a controller a canyon so I had to console Sheriden  when she was crying and complaining that the job was too hard and was overwhelmed.     I was on Canyon when a mayor tax change and reporting was made to the Canyon  Johnson Advisor entity and financial statements. The PwC Tax Sr. Partner from new York  didn't even want to deal with their constant whining. I had to negotiate even the fees  for them. I wasn't a shit head to go pass a low level controller complaints to a Sr. Tax  Partner. I did communicate with the Sr. Audit Partner on Asset Management  Canyon's  account what Canyon about when PwC was questioning their Tax Crap.    The SEC can deal with its own shit. All an Audit team has to do in a Private Equity its  General Partner and Advisors is to ask the criminals involved in tax evasion and offshore  structures is to swear to the Auditors they are saints and comply with all tax laws in a  management representation letter.     What idiots report Financial Statements on a Tax Basis that don't tie with their own tax  tax returns and still expects that the PwC Asset Management Practice Leader and PwC  Los Angeles Financial Services is going to sign off the prior Auditor's  (Deloitte) garbage  going forward.    As if complaining  about a PwC Sr. Tax Partner asking too many questions on their tax  shenanigans to the Audit Manager right under Sr. Partners and Financial Services Senior  Leadership in the West Coast wasn't going to raise red flags about Canyon within PwC  Financial Services Audit Leaders.     Canyon wasn't let out of the control of the Auditors that would nail Canyon's ass to a  wall and dump them back on Deloitte, PwC New York  & Regulators over their Tax  shenanigans.     I was a PwC Public Auditor not a PwC Public Accounting Parrot walking around  promoting  the latest Lease Accounting implementation or Business development  Company Advisory schemes.  If I needed help with accounting for Derivatives question, I  asked the Derivatives Accounting Experts (a.k.a.  Julie Malouf now PwC Partner in  Financial Services) before I told garbage to Sr. Partner in Financial Services.     FYI ‐ July Malouff was my Senior in 2000. We both were in the PwC Financial Services  Managers Committee, which Tomoko (A New York Asset Management Partner) and Bill  Starn (PwC Real Estate Partner and Practice Leader in Northern CA  transferring to Los  Angeles) saw first hand what trying to ram a Manager promotion that financial services  managers hadn't approved nor  recommended to financial services Sr. Partners in Los  Angeles.  Just because a PwC Orange County Real Estate Manager was sitting on the  Financial Services committee or Bill was overseeing the Committee as an independent  partner,  it didn't give them a vote nor voice over Financial Services Managers in Los  Angeles.     Hell broke loose in Human Resources in Los Angeles and New York between Financial  Services and Real Estate.  That is what EY FSO couldn't understand. PwC Financial  Services Industry isn't the same thing as EY Financial Services Office nor where Financial  Services Managers the same people as PwC Real Estate Practice in Orange County  clueless about Private Equity Funds with underlying Real Estate Assets.  Auditing a property manager or developer isn't the same  thing as Auditing a Fund  Complex and its Registered Investment Advisors.   16   A REIT election and status is a Tax determination made by the respective Big Four Tax  Service Provider and Tax Departments where Auditors don't get involved nor the Tax  Partners sign any Audit Opinions to the IRS or the SEC.  In fact, Tax Partners explicitly  take no responsibility for the numbers they include in Tax Returns of the Funds or  shown to the "alternative investors" given go them by a Private Equity Accounting or Sr.  Management.     Translation: When a Tax Partner is attacking and ratting out their Tax crap to an Big Four  Auditor, specially in the same firm as EY did, Partners did, the shit heads are up to no  good.      Sheridan didn't get past kinder‐garden at a Big Four  and Arthur Andersen didn't  implode over a minor transgression nor were they innocent.  In the Big Four Cartel  hierarchy  Sheridan and plain common sense, Sheridan doesn't gun for a Audit Senior  Manager many times her superior for life and misses. Sheriden and John Plaga to meant  blame their shitty business tactics and collusion with EY against the other firms  (PwC/Deloitte) to harm me publicly, in the industry and market,  with stupid rumors for  their own benefit.     Remainder, I wasn't working for any unknown winy snowflake in the West Coast or a  new line partners new to Los Angeles and to CA PwC suits in New York get to push  around.     I wasn't sold fir pennies in a backroom dirty transaction behind anyones back to New  York by shitty LA partners. I was transfer to NYC under in elaborate Partnership Package  and signed Agreements between PwC‐Los Angeles Partners, PwC‐New York Partners and  myself.  I ceased to be an employee of CA overnight when Lehman imploded.   I was  working for PwC‐New York under a contract not   "At Will" employee.     I wasn't fired by PwC, nor left PwC in any bad terms for PwC or to me.     What stupid person thinks that imploding the Financial System and Housing Crisis in  2008 over a Lehman derivative was a walk in the park for the people working in the  middle if the mess in NYC.  Nobody was hugging or kissing each other.   New Yorkers and  Wall Street were watching their ass from each other and getting stuck with criminal  liability.     EY's Client Lehman Brothers Repo 105 (Derivative) and EY's Accounting, Valuation and  Tax Shenanigans in Financial Services took down Lehamnan Brothers  not EY.    Enron a Texas based Corporate Criminal went down and took Arthur Andersen  Accounting Firm  (There used to be a Big 5 Cartel 20 years ago) down with them along  with the Governor of California. Arthur Andersen disappear overnight. Ask Sheridan or  David Orkin how it went down for employees.  It was about Enron's and Arthur  Andersen shenanigans in the electricity markets and between California and the pretend  rolling black outs just to jack up electricity prices to CA Consumers.     I didn't drop a lowly EY‐Lehman Brothers (Repo 105) derivative (a.k.a Financial Weapon  of Mass Destruction) on the US Financial Markets. I dropped a Santander‐Deloitte  Mexico over ICA Enterprises (Critical Infrastructure i.e. Metro Linea 12, Mexico City  Airport) based in Mexico City  and ICA Flour based in Texas and its associations in Los  17 Angeles, CA and Latin America.     Nor have I said more.  I was clear it wasn't about Santander shenanigans just as TwC's  shenanigans tax evasion and money laundering shenanigans with EY aren't the main  concern.  TCW's Real Estate FundS were not just in Russia. I haven't even mention TwC  China Real Estate Funds just yet.      Email distribution list [added  May 13, 2021]   SBarragan@aristeguinoticias.com, redaccion@aristeguinoticias.com, careyshenkman@riseup.net,  courage.contact@couragefound.org, transportandoamichoacan@live.com,  periodicooficial@michoacan.gob.mx, buzon@poderjudicialmichoacan.gob.mx,  Comercializacion@telesurtv.net, Albinocm6502@gmail.com, JuanJosedelCastillo@gmail.com,  Borderlinebeat@gmail.com, Charropoliticoenvivo@gmail.com, Conexiononline1@hotmail.com,  Wells@wsws.org, autoworkers@wsws.org, sep@socialistequality.com, NORISSA@socialism2020.org,  JOE@socialism2020.org, Christine.s.Richard@gmail.com, Aaron.Greenspan@plainsite.org,  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cstepati@pfp.gob.mx, csatlaco@pfp.gob.mx, sumit2006@gmail.com, ed‐del‐rev@nic.in,  molegangwar@yahoo.com, secy‐labour@nic.in, farida.samsul@gov.in, igkonwar.acs@assam.gov.in,  bopb1.clb@nic.in, registrar‐mum@nclt.gov.in, secretary@nclt.gov.in, registrar.jpr@nclt.gov.in,  response‐nis@pib.gov.in    FRAUD@insurance.ca.gov, Ombudsman@insurance.ca.gov, CAB‐SF‐Intake@insurance.ca.gov,  ElectronicSubmissionFD‐1@insurance.ca.gov, pushpa.uttamchandani@insurance.ca.gov,  21 RECRUITMENT@insurance.ca.gov, RSBCovid19PR@insurance.ca.gov,  CustodianofRecords@insurance.ca.gov, StateFarmfireClaims@statefarm.com, Privacy@statefarm.com    Ethics.Officers@jll.com, Laura.Locks@lasalle.com, John.Carlson@lasalle.com, klynch@icsla.us,  S.Mercer@festivalcos.com, T.Killeen@festivalcos.com, D.Whitt@festivalcos.com,  S.Brown@festivalcos.com, F.Insurance@festivalcos.com, Celia.shibata.iyhc@statefarm.com,  Nicole.HillSmidt@roberthalf.com, Samantha.figueroa@roberthalf.com, sherri.agganis@rhmr.com,  anjali.chandel@rhmr.com, chelsea.jongewaard@rhmr.com, julia.person@roberthalf.com,  carmen.romero‐eberle@roberthalf.com, tony.uyehara@roberthalf.com,  zoya.naumchik@roberthalf.com, tala.moussouras@roberthalf.com, cawagenotice@roberthalf.com,  pay.timereporting@roberthalf.com, OnlineTimeReporting@roberthalf.com, quality.manager@rhi.com    SMangum@smwb.com, JRobb@smwb.com, jsweeney@smwb.com, rmason@smwb.com,  sschmidt@smwb.com, colson@smwb.com, kwilson@smwb.com, REB@smwb.com,  wkaufman@smwb.com, dlee@smwb.com, rthomson@smwb.com, LLGinn@smwb.com,  TJacobson@smwb.com, lbalke@smwb.com, WStanger@smwb.com, Parul@giulianiconstruction.com,  Vince@giulianiconstruction.com, Tiffany@giulianiconstruction.com,  Antoinette@giulianiconstruction.com, Ashley@giulianiconstruction.com, AR@giulianiconstruction.com,  Claudia@giulianiconstruction.com, Erik@giulianiconstruction.com, SLG@sghoalaw.com,  TMiller@constructionsdefects.com, Sara@constructiondefects.com, Sbrown@constructiondefects.com,  Linda@constructiondefects.com, Rachel@constructiondefects.com, Joseph@constructiondefects.com,  State@constructiondefects.com, Asha@constructiondefects.com, EHillier@washblaw.com,  THones@washblaw.com Jknight@berdingweil.com, Cthomas@berdingweil.com,  Lolona@berdingweil.com, Bhirsch@berdingweil.com, Tnocco@berdingweil.com, Kpolk@cahill‐sf.com,  JPalmer@cahill‐sf.com, Rmartini@cahill‐sf.com, Aelizabethcostello@gmail.com,  Donklingbeil@gmail.com, Arun.Bhatia@sfdwp.org, Ngueylay@gmail.com,     CynthiaC@partnerscm.com, CarmenH@partnerscm.com, Karolo@partnerscm.com,  RebCohen999@sbcglobal.net, Kathlineking@yahoo.com, Cbretzin@gmail.com,  Cristin.morneau@gmail.com, Rebelcapitaladvisors@gmail.com, Maddydominick@hotmail.com,  HHW7878@yahoo.com, KristyandAlvin@gmail.com, kyle.algeo@gmail.com, Balog@climbsf.com,  Kevans@gmail.com, renee@hrhrealestate.com, Steven.Sheh@gmail.com,  Steven.sheh.300ivy@gmail.com, Cathy.edwards@gmail.com, Cathy300ivy@gmail.com,  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Taylormarcus@gmail.com, Tony.h.liu@gmail.com, Tracyc863@gmail.com, Uma105@gmail.com,  Vmalhi@gmail.com, Vyomesh.joshi@gmail.com, Wccheng@gmail.com, Yadathi@gmail.com,  Justchar@outlook.com, Whstuart@googlemail.com, Llazar@google.com, Joykao2000@icloud.com,  Rilely@icloud.com, Alags10@hotmail.com, Carlos_cm86@hotmail.com, Erickjvn@hotmail.com,  lianayingsu@hotmail.com, Maria_chiossi@hotmail.com, numazer@hotmail.com,  smekhalfa@hotmail.com, Aplutino@yahoo.com, al_laxman@yahoo.com, ethankan@yahoo.com,  gauravbhasin@yahoo.com, souhil.zaim@yahoo.com, terichappell@yahoo.com,  UshaTumkur@yahoo.com, tzippi_zach@yahoo.com, Fred.Hsu@3rdstone.ws,  JMoran@parksconservancy.org, David@ellnerconsulting.com, Atidman@mac.com, Vellner@mac.com,  Dennischang@alumni.stanford.edu, Vinodhini.lakshman@ucsf.edu, Brennan.spellacy@sonder.com,  chikodi@moonshotpr.com, ckwan@chokwancpa.com, JSmith@test.com, lauren@edgertons.com,  manonpaquet@live.fr, hillpropmanager@sbcglobal.net, mponce@alse.com.mx, serfriaz@live.com.mx,  William.Livermore@fsresidential.com, Todd.Caniglia@fsresidential.com, Natalie.valdez‐ smith@fsresidential.com, Jeanette.Zamora@fsresidential.com, Marco.Pulido@yahoo.com,  irmavillalobos@hotmail.com, curlysue713@yahoo.com, ramartinez@gmail.com, rapransky@gmail.com,  ms.ra.martinez@gmail.com, Cordon.Lucky@gmail.com, Paoneill@asu.edu, shaoyun925@hotmail.com,  Atsuko_Nakamura@hotmail.com, Paul.Ryan.201@hotmail.com, Hvchowdhary@gmail.com,  Neng1983@gmail.com, Amacrine67@icloud.com, WexlerSecretary@2730wilshire.com,  info@ericwexlermd.com, pialigeti@gmail.com, Geotff@outlook.com, Marcos.f.carrillo@gmail.com,  Victoriav561@gmail.com, Joe.Cicalo@wholefoods.com, Andyperez23@yahoo.com,  Bebelovesbo76@hotmail.com, Tribuno_alfa@hotmail.com, Jessicaflores05@gmail.com,  ymo73@hotmail.com    RecordsAccessOfficer@trs.nyc.ny.us, Investments@ocers.org, CalSTRSCIO@calstrs.com,  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jgiordano@treasurer.ca.gov, kjohantgen@treasurer.ca.gov, mpaxson@treasurer.ca.gov,  rwebster@treasurer.ca.gov, tconnelly@treasurer.ca.gov, tpaine@treasurer.ca.gov, vau‐ yeung@treasurer.ca.gov, Kselenski@sto.ca.gov, InvestorRelations@treasurer.ca.gov,  Audrey.Noda@treasurer.ca.gov, Christina.SARRON@treasurer.ca.gov, Frank.Ruffino@treasurer.ca.gov,  Frank.Moore@treasurer.ca.gov, Gloria.Li@treasurer.ca.gov, Gloria.Pulido@treasurer.ca.gov,  Genevieve.Jopanda@treasurer.ca.gov, Judith.Blackwell@treasurer.ca.gov,  Jovan.Agee@treasurer.ca.gov, Kristin.Szakaly@treasurer.ca.gov, Kathryn.Asprey@treasurer.ca.gov,  Kasey.O'Connor@treasurer.ca.gov, Mark.Desio@treasurer.ca.gov, Noah.Starr@treasurer.ca.gov,  Robert.Berry@treasurer.ca.gov, Seth.Doulton@treasurer.ca.gov, Tracey.Paine@treasurer.ca.gov,  Tim.Schaefer@treasurer.ca.gov    AuditorGen@paauditor.gov, Budget@pa.gov, RA‐ethicsRTKL@pa.gov, achristman@nelp.org,  bchen@nelp.org, dberkowitz@nelp.org, gwentworth@nelp.org, krole@nelp.org,  Inspectorgeneral@cpsoig.org, Cmoreno@aft.org, BlackwellJ@ctpf.org, ReillyM@ctpf.org,  23 RedfeairnG@ctpf.org, CavalleroJ@ctpf.org, WardJ@ctpf.org, Jwaddell@aft1521.org,  lmarzillier@aft1521.org, sharonaft1521@gmail.com, lahc1521@gmail.com, parkcj@lacitycollege.edu,  robbdm@piercecollege.edu, mindy@post.harvard.edu, shewfeo@wlac.edu, russeltm@wlac.edu,  coloche@lahc.edu, fenyesm@laccd.edu, lees@lasc.edu, guerrij@lattc.edu, theodore@uic.edu,  gcities@uic.edu, AGREDAFE@elac.edu, JesseSharkey@ctulocal1.org, ChristelWilliams@ctulocal1.org,  MariaMoreno@ctulocal1.org, StacyDavisGates@ctulocal1.org, nmonteiro@mac.com,  drmarcelm@gmail.com, cofercw@gmail.com, jamesmckeever101@gmail.com,  joseph.guerrieri@gmail.com, phoenixmountain2@gmail.com, Zknorr@gmail.com,  Olgashewfelt@gmail.com, mcdowelljr@gmail.com, Pkallen3717@yahoo.com, Kyasuda62@hotmail.com,  rubybrou@hotmail.com, mmoon13956@aol.com, Sandraleephd@aol.com, sufiserf@aol.com,  sanpsych@aol.com, wder@social.rr.com, wdelarton@socal.rr.com    Investor@gruposantander.com  dorkin@oaktreecapital.com, Westcoastorkin@gmail.com, Shaoyun925@hotmail.com,  dkirchheiner@oaktreecap.com, jarnold@oaktreecapital.com, arnoldmd@aol.com,  Lsilva@canyonpartners.com, MCulp@oaktreecapital.com, Losorio@oaktreecapital.com,  NRedington@colonyinc.com, Jplaga@canyonpartners.com, Smansfeld@canyonpartners.com,  Pprak@canyonpartners.com, Lsilva@canyonpartners.com, Mpage@canyonpartners.com,  Dmillman@canyonpartners.com, Purrutia@clearlakecapital.com, Peter.Viles@tcw.com,  Lynn.kalbach@tcw.com, Fiona.huang@twc.com, Lindsey.Lennon@carlyle.com,  Elizabeth.gill@carlyle.com, Irina.Rudnitsky@tcw.com, PRivera@shamrockcap.com,  CPark@shamrockcap.com, AHoward@shamrockcap.com, SRoyer@shamrockcap.com,  LHeld@shamrockcap.com, MDiLorenzo@shamrockcap.com, Rohit.Subramaniam@duffandphelps.com,  Rohit.venkatasubban@gmail.com, investorrelations@marriott.com, IR@invesco.com,  Company.Secretary@invesco.com, Contactus@invescomortgagecapital.com, Patty.Dow@cbre.com,  Bonnie.m.wong@jpmorgan.com, edwin.k‐w.chin@jpmorgan.com, REA_Finance_‐ _Central@jpmorgan.com, Investor@gruposantander.com, Fidelity.Investments@mail.fidelity.com,  reportphish@wellsfargo.com, ofsrep.rumbbgw@wellsfargo.com, contacto@gmxt.mx, ri@telmex.com,  info@grupobmv.com.mx, vfueyo@homex.com.mx, ir@gruma.com,  daniela.lecuona@americamovil.com, investor.relations@americamovil.com,  anticorrupcion@americamovil.com, asuntoscorporativos@clarochile.cl,  codigoetica@americamovil.com, derechoshumanos@americamovil.com,  conflictointeres@americamovil.com, valores@americamovil.com,  seguridadinformatica@americamovil.com, infoconfidencial@americamovil.com,  privacidad@americamovil.com, clientes@americamovil.com, investor@uber.com,  Angela.Padilla@uber.com, raymond.galaviz@uber.com, tracey.merwise@uber.com,  nbartow@uber.com, press@uber.com, social@uber.com, tradingcompliance@uber.com,  ipteam@uber.com, competition@uber.com, Abengoa@abengoa.com.mx,  cam.espanola@camescom.com.mx, Jgange@dkpartners.com, Rebelcapitaladvisors@gmail.com,  Johnson@barkerpacific.com, Wsueiro@statestreet.com, Nathan@standishmanagement.com,  G.hill@standardinvestment.com, Jwurtz@pathfinderfunds.com, George.rupp@carioncapital.com,  anna.marie.lopez@hwcm.com, t.duanne@pefco.com, Ethics.Helpline@wal‐mart.com,  Luis.kolster@walmart.com, Alberto.mora@walmartlegal.com, Rainlay@walmart.com,  inversionistas@walmart.com, mjafern@outlook.com, Jessicaamassey@gmail.com,  claudia.delavega@walmart.com, Gabriela.buenrostro@walmart.com, Mario.Gonzalez@walmart.com,  Jimena.Rodriguez@walmart.com, Adriana.Garza@walmart.com, Mario.González@walmart.com,  miopinion@wal‐mart.com, donativosenespecie@walmart.com, Juanf.torreslanda@hoganlovells.com,  Michael.Mctiernan@hoganlovells.com, bill.flanagan@hoganlovells.com,  richard.climan@hoganlovells.com, Jaime.espinosa@hoganlovells.com, james.banks@hoganlovells.com,  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rdiogo@playaresorts.com, PSaif@playaresorts.com, ir@playaresorts.com, press@playaresorts.com    Michael.Mctiernan@hoganlovells.com, Cbode@tpg.com, Doug.warner@weil.com,  Chris.machera@weil.com, Kyle.Krpata@weil.com, Nelsonj@gtlaw.com, Saylea@gtlaw.com,  brunoespindola@paulhastings.com, gonzalogutierrez@paulhastings.com,  emilywinston@paulhastings.com, elenapoleganova@paulhastings.com, joygallup@paulhastings.com,  leopoldogomezgrassi@paulhastings.com, pvelasco@s‐s.mx, theather@ritch.com.mx,  ldanton@ritch.com.mx, cobregon@ritch.com.mx, gdelvalle@ritch.com.mx, jpfarah@ritch.com.mx,  jberrueta@ritch.com.mx, lnicolau@ritch.com.mx, pperezalonso@ritch.com.mx, efreedman@cgsh.com,  ggaleotti@cgsh.com, fgaray@cgsh.com, ngrabar@cgsh.com, jcardona@cgsh.com,  apaul@whitecase.com, andrew.choe@balm.com, filo.fiorani@balm.com,     Joseph.Mazza@mcgladrey.com, Ron.kent@mcgladrey.com, Craig.Wickwire@mcgladrey.com,  Christine.Jung@mcgladrey.com, Tom.leyden@mcgladrey.com, Tracy.whetstone@mcgladrey.com,  Steven.Johnson@mcgladrey.com, Paige.Kuroyama@mcgladrey.com, Scott.Mackey@rsmus.com,  karen.jong@mcgladrey.com, Ericka.Foster@mcgladrey.com, Ellen.Burns@mcgladrey.com,  Michelle.McKenzie@mcgladrey.com, Leroy.Dennis@mcgladrey.com, allison.hovey@mcgladrey.com,  Byron.Whittlinger@mcgladrey.com, jack.rominger@mcgladrey.com, Tselby@wc.com,  BRobb@shilepsky.com, CNeff@foxrothschild.com, BRodos@foxrothschild.com,  PConnolly@foleyhoag.com, JLQ@foleyhoag.com, Marc.maselli@morganpartners.com,  JRudd@solutionsiq.com, Gmorein@gmail.com, George.Schlitz@gmail.com, Jamesiracundiff@gmail.com,  Garson@soelaw.com, Darrin_Ladd@hotmail.com, Stalley333@gmail.com, Stalley@kcrlegal.com,  Kelvin.Tetz@mossadams.com, Dkouame@bdo.com    CGD Policy Paper 123 March 2018 Illicit Financial Flows, Trade Misinvoicing, and Multinational Tax Avoidance: The Same or Different? Illicit financial flows (IFFs) connected with corruption, crime, and tax evasion are an issue of increasing concern. A target to reduce IFFs is included in the Sustainable Development Goals (SDGs). However, there is not yet a clear consensus on how to define illicit financial flows, and even less on how to measure them. In particular, while tax fraud and evasion clearly fall within the definition “illicit,” several arguments have been put forward for widening the term to also include legal behaviour which reduces tax payments. Rationales for this include the dictionary definition of the word “illicit” and the existence of enforcement uncertainty. One of the most practically compelling arguments has been a belief that there is a large “grey zone” reflecting an absence of clear defining lines between legal tax planning and tax evasion. This is often linked to the idea that transfer pricing and trade misinvoicing are areas of overlapping practice where major multinational companies engage in illicit financial flows. This paper explores the definitional questions and the estimates of trade misinvoicing to shed light on whether these behaviours and issues are the same or different. This paper argues that conflating legal and illegal behaviour under a single definition involves a loss of clarity and a risk of confusion. www.cgdev.org Center for Global Development 2055 L Street NW Fifth Floor Washington DC 20036 202-416-4000 www.cgdev.org This work is made available under the terms of the Creative Commons Attribution-NonCommercial 4.0 license. Abstract An earlier version of this paper was presented at the Tax Justice Network Annual Conference in London in July 2017 and benefited from discussion with participants, particularly Sol Picciotto and John Christensen. It was also presented at the Tax and Good Governance conference on Countering Treaty and Transfer Pricing Abuse organized by the University of Vienna in Cooperation with UN Office on Drugs and Crime and the World Bank Group and hosted by the Ministry of Finance, Ghana Revenue Authority and Financial Intelligence Centre in Accra, Ghana in July 2017. Thanks also to Fredrik Erikkson and Michael Anderson for review comments. Maya Forstater. 2018. “Illicit Financial Flows, Trade Misinvoicing, and Multinational Tax Avoidance: The Same or Different?” CGD Policy Paper. Washington, DC: Center for Global Development. https://www.cgdev.org/publication/illicit-financial-flows-trade-misinvoicing-and-multinational-tax-avoidance CGD is grateful for contributions from the Ford Foundation in support of this work. Maya Forstater Contents 1. Introduction .................................................................................................................................. 1 1.1 Are tax avoidance and illicit financial flows the same or different? .............................. 2 2. Illicit financial flows: definition debates ................................................................................... 4 2.1 Is there already consensus? .................................................................................................. 7 2.2 Can the dictionary solve it? .................................................................................................. 8 2.3 Grey areas? ............................................................................................................................. 9 3. “Trade misinvoicing”: the meeting point between IFFs and avoidance? ......................... 10 3.1 Problem I: Gaps and mismatches in trade data don’t reliably reflect misinvoicing . 12 3.2 Problem II: “Misinvoicing” is not mispricing ................................................................ 18 3.3 Problem III: Findings from trade misinvoicing studies do not reflect corporate practice by major multinational companies ........................................................................... 23 3.4 Are there large hidden margins in commodity trading? ................................................ 25 4. “Tax-havens”: The meeting point between IFFs and tax avoidance? ............................... 27 5. Conclusion................................................................................................................................... 29 Bibliography .................................................................................................................................... 31 1 1. Introduction Illicit financial flows (IFFs) have become an issue of increasing concern over the past 20 years, reflecting the damage wrought by kleptocracy, corruption, state capture, and organised crime. Focusing on cross-border financial flows in particular highlights the role of international banks, real estate, and corporate legal structures as vehicles for enabling ill- gotten gains to be kept out of the reach of law enforcement. The need for international cooperation to assist countries in tracking, tracing, and retrieving assets across borders and to prevent impunity is increasingly well recognised. In 2000 the UN General Assembly adopted the Convention Against Transnational Organised Crime, including a commitment to criminalise the transfer, concealment, or disguise of assets of illicit origin. In 2001 the Economic and Social Council agreed a resolution (2001/13) to strengthen international cooperation in preventing and combating the transfer of funds of illicit origin derived from acts of corruption, and in 2005 the UN Convention Against Corruption (UNCAC) was adopted, including commitments on returning stolen assets. Since the 9/11 attack in 2001 there has also been increasing in focus on financial networks that support terrorism, as part of anti-money laundering controls. Cross-border flows of money (or other assets) associated with crime, corruption, and tax evasion are diverse, and by their nature hard to measure. However, large estimates of the scale of illicit financial flows have played a key role in attracting attention and encouraged political momentum. In 2004, Transparency International estimated that ten of the most notoriously corrupt heads of state such as Ferdinand Marcos of the Philippines, Sani Abacha of Nigeria, and Suharto of Indonesia had together embezzled as much as US$60 billion from their countries over the previous 20 years (Transparency International 2004). In the same year Peter Reuter and Edwin Truman’s book “Chasing Dirty Money: The Fight Against Money Laundering” reviewed emerging global estimates of the proceeds of crime and corruption hidden through money laundering, and concluded they were likely to amount to several hundreds of billions of dollars annually. In 2005 Raymond Baker published his seminal book Capitalism's Achilles Heel: Dirty Money and How to Renew the Free Market System in which he set out a global estimate of illicit financial flows in the hundreds of billions. He went on to found the NGO Global Financial Integrity “with the aim of quantifying and studying the flow of illegal money while promoting public policy solutions to curtail it,” which has popularised figures in the order of one trillion dollars in annual illicit financial flows from developing countries.1 In 2007 the government of Norway called on the World Bank to undertake a study of IFFs. However, finding the concept too poorly understood to support quantification, the Bank instead began by convening the first major international conference on the topic, commissioning analytic contributions from diverse experts. This culminated in the publication of Draining Development (World Bank, 2012). The book highlighted confusion and contestation at every level of the issue; What does “IFFs” include? What do we know about 1 www.gfintegrity.org/about 2 them? How can they be measured? What damage do they do? How should they best be addressed? Reuter, as editor, concluded that illicit financial flows are diverse and that we know too little to take the reductionist approach of assuming that each dollar (whether related to grand corruption, criminal enterprise, tax fraud and evasion, or evasion of capital controls) does equal damage, or that they can all be dealt with through a single set of actions. He argued that focusing on “black box” aggregate figures obscures the causes and consequences of different streams and that “it is not clear how much effort should go toward halting illicit flows, as opposed to dealing with the underlying phenomena.” In 2015 IFFs was included in the Sustainable Development Goals (SDGs) under target 16.4 to “significantly reduce illicit financial and arms flows, strengthen the recovery and return of stolen assets and combat all forms of organised crime.” It was agreed that this would be measured using the indicator “total value of inward and outward illicit financial flows.” The setting of this target and concrete indicator might perhaps suggest that in the ten years since the first conference on illicit financial flows there must have been significant progress in resolving the definitional questions, as well as breakthroughs in understanding and measurement. In fact the state of knowledge and consensus has hardly advanced, and debates are often confused.2 1.1 Are tax avoidance and illicit financial flows the same or different? One question which needs to be answered in clarifying, defining, measuring, and effectively tackling illicit financial flows is whether the concept should primarily concern financial flows that relate to illegal actions, or whether a broader conception should be used that takes in tax avoidance by multinational enterprises (so-called base erosion and profit shifting or BEPS). While these may seem like quite distinct areas of concern it is often that legal transactions and practices that result low tax bills should also be included under the umbrella of illicit financial flows. One argument is that not only should corporate tax avoidance be included as part of IFFs, but that it already is. In particular this view has been put forward by the NGOs the Tax Justice Network (TJN) and the Global Alliance for Tax Justice (GATJ) and the Independent Commission for Reform of International Corporate Taxation (ICRICT) in letters to the UN Secretary General. They argue that this is a settled matter and “no amount of reinterpretation or redefinition can raise any legitimate question over this point” (see Box 1). 2 See the review of the state of knowledge and understanding of illicit financial flows at the end of 2017 by Frederik Erikkson for the U4 Anti Corruption Resource Centre: https://medium.com/u4-anti-corruption- resource-centre/iff-definitions-3f3d0ba106c3 3 Box 1: Letters to the Secretary General Global Alliance for Tax Justice: “The global agreement reached in the Sustainable Development Goals to seek to reduce illicit financial flows is an agreement that clearly covers tax avoidance by multinational companies. No amount of reinterpretation or redefinition can raise any legitimate question over this point. But the effort now to exclude tax avoidance retrospectively is well underway.” Independent Commission for Reform of International Corporate Taxation: We understand that some actors within the UN system are lobbying for a redefinition of the term ‘illicit financial flows’ in order retrospectively to exclude tax avoidance by multinational companies from the definition. Such a course of action represents a clear threat to the SDG contribution of domestic resource mobilization, and will also undermine confidence in the UN’s ability to deliver honestly on what member states have previously agreed upon. https://www.taxjustice.net/2017/06/23/un-must-defend-target-curtail-multinational-companies- tax-abuse/ Sometimes this argument is made “by the numbers”; it is often stated that tax related illicit flows through trade misinvoicing attributed to multinational companies make up the largest proportion of illicit financial flows and therefore must be core to the IFFs agenda. This paper argues that combining legal and illegal activity into a vaguely defined composite category is not something to do lightly, if the overall goal is to strengthen the rule of law, democratic accountability, and the effectiveness of states. It sets out the arguments for and against including BEPS within the definition of illicit financial flows and examines the assumptions behind the methodologies used to calculate popular and influential measures of trade misinvoicing which give rise to the “by the numbers” argument. 4 2. Illicit financial flows: definition debates The most common working definitions of illicit financial flows converge around the core concept of financial transfers across borders that are in some way related to illegal activity (see Table 1). Table 1. Converging definitions of illicit financial flows Source Working definition African Tax Administrators Forum (2105) Illicit Financial Flows and Trade Misinvoicing “Illicit Financial Flows (IFF) is defined as any money that is illegally earned, transferred or utilised” Global Financial Integrity (2015) “Illicit Financial Flows from Developing Countries: 2004-2013” “Funds crossing borders [that] are illegally earned, transferred, and/or utilized.” High Level Panel on Illicit Financial Flows from Africa (2015) “Money illegally earned, transferred or used” Inter-Agency Task Force on Financing for Development (2017) “There are… some parameters that members of the Task Force agreed on, namely: i) illicit financial flows constitute money that is illegally earned, transferred or used and ii) that crosses borders.” OECD (2014) Illicit Financial Flows from Developing Countries “There are various definitions of illicit financial flows, but essentially they are generated by methods, practices and crimes aiming to transfer financial capital out of a country in contravention of national or international laws. United Nations (2016) Coherent Policies for Combatting Illicit Financial Flows IFFs are defined broadly as all cross-border financial transfers, which contravene national or international laws. United Nations (2016) World Economic Situation and Prospects 2016 “There is no agreed definition of the concept of illicit financial flows (IFFs), but it is generally used to convey three different sources of IFFs: the proceeds of commercial tax evasion, revenues from criminal activities, and public corruption.” World Bank (2016) The World Bank Group’s response to illicit financial flows: a stocktaking “Generally refers to cross-border movement of capital associated with illegal activity or more explicitly, money that is illegally earned, transferred or used that crosses borders.” This “narrow” definition of illicit financial flows covers a range of activities including hiding the proceeds of crime, drug trafficking, and embezzlement; channelling funds towards criminal destinations, such as bribery or terrorism; misreporting transactions in order to evade tariffs or taxes; and capital flight in disobedience with currency controls. 5 Figure 1. Conceptual map for core definition of illicit financial flows Source: Forstater, M (2016) Illicit Flows and Trade Misinvoicing: Are we looking under the wrong lamppost? While there is a fair degree of convergence between these definitions, there remains some fuzziness. For example, the definition suggested in the OECD publication seems to focus only on the illegality of the transfer, rather than the source or use of funds (although this may be assuming predicate offenses which underpin the crime of money laundering). The GFI definition refers to funds (i.e., money), while the OECD describes movement of financial capital which could cover loans, equity, financial instruments, or possibly even physical assets if used in the pursuit of future revenue. (In practice, however, GFI’s definition also includes transfer of goods in the case of trade based money laundering.)3 Beyond these detailed definitional questions, some actors propose a much wider “normative” definition, which is not limited to financial or capital flows with a connection to illegality, but includes activities which are deemed to be undesirable, immoral, or “unacceptable to the public,” in particular focused on tax avoidance. This of course begs the question who holds these morals or ethics, and whether they are universal and well defined. 3 Erikkson, Frederik. 2017. Illicit financial flows definitions — crucial questions. U4 Anti Corruption Research Centre https://medium.com/u4-anti-corruption-resource-centre/iff-definitions-3f3d0ba106c3 ILLEGAL Financial transfers which break the law Tax evasion Proceeds of crime Money laundering Proceeds of corruption Financing of terrorism and conflict Evading capital controls Sanctions busting Bribery ILLICIT FINANCIAL FLOWS INTERNATIONAL Financial transfers across borders Wire/bank-transfers Cash carried across borders Import/export of goods & services Transfers of financial assets, e.g. stocks Transfer of ownership of property Informal IOUs/ Halawa Cryptocurrencies 6 Table 2. Broader use of “illicit financial flows” Source Description High Level Panel on Illicit Financial Flows from Africa (2015) Also includes activities “that, while not strictly illegal in all cases, go against established rules and norms, including avoiding legal obligations to pay tax.” They include in their list of activities aggressively avoiding tax and “base erosion and profit shifting.” European Parliament (2015) Report on tax avoidance and tax evasion as challenges for governance, social protection and development in developing countries Includes in description of illicit financial flows: “typically originate from tax evasion and avoidance activities, such as abusive transfer pricing, against the principle that taxes should be paid where profits have been generated.” Cobham, A. (2015) Illicit Financial Flows Assessment Paper. “IFF is by its nature hidden, whether it is illegal or simply unacceptable to the public -- This makes clear that the source of funds may be perfectly legal, while the avoidance of tax, for example, may be technically legal but illicit according to societal norms.” UN Human Right Council (2016) Final study on illicit financial flows, human rights and the 2030 Agenda for Sustainable Development of the Independent Experts In their broader sense, illicit financial flows refer also to funds that, through legal loopholes and other artificial arrangements, circumvent the spirit of the law, including, for example, tax avoidance schemes used by transnational corporations. UNCTAD (2014) Trade and Development Report “In a broader sense, IFFs also encompass all kinds of artificial arrangements that have been put in place for the essential purpose of circumventing the law or its spirit. Thus, illicit might not necessarily mean contravening the letter of the law but going against its spirit. In this case, illicit can be understood as something hidden or disguised…In this report, the key criterion used is whether such tax-motivated IFFs are justified from an economic point of view. If a given international financial flow is part of a “tax-optimization” scheme without any concrete related economic activity, it could be considered “illicit.” Picciotto, Sol (2018) Illicit financial flows and the tax haven and offshore secrecy system. Tax Justice Network “Offshore is a murky world which facilitates a range of criminal, illegal, illegitimate and undesirable practices, all covered by the broad term illicit… They range from facilitating serious crime to behaviour which is unethical or undesirable, such as concealing assets from family members or business associates. It is sometimes said that many of these activities are ‘perfectly legal’, and hence legitimate.” Several justifications have put forward for the wider approach: 1. By etymology: One argument is that the dictionary definition of the word “illicit” is inherently wider than the word illegal; relating to action that is morally wrong or against societal norms and therefore, by definition, “illicit financial flows” must address areas beyond illegality (Cobham, 2015). 7 2. By enforcement uncertainty: Financial flows related to illegal activities may go unchallenged, such as when the revenue agency lacks capacity or there is no political will to address the theft of state funds. Chowla and Falcao (2016) therefore rehearse the argument that legal non-compliance cannot be a clear dividing line, because uncovering financial flows which would be prevented if they were detected and challenged depends on the investigative and legal resources to do so. 3. By legal grey area: A further argument is that there is a large grey zone in the area of tax avoidance reflecting an absence of clear legal defining lines between tax compliance and non-compliance, and therefore that the distinction between the two areas is arbitrary (Chowla and Falcao, 2016). The UN Human Right Council (2016) report refers to “legal loopholes” and other artificial arrangements, circumventing the “spirit of the law.” 4. By consensus: A final argument, as put forward by the Tax Justice Network and Global Alliance for Tax Justice is that there is already global political agreement that a broad normative definition of illicit financial flows underpins the SDGs, and that focusing on the narrower law related definition would therefore be a clear subversion the existing global consensus about the meaning of IFFs. Table 3. Summary of arguments for broad definition By etymology By enforcement certainty By legal grey area By consensus The meaning of Illicit inherently includes a sense of “against custom”/ frowned upon. Taxpayers can sometimes get away with tax evasion, but it is still illicit. There are large areas of practice where it is not clear what is legal and what is not. Governments are already in clear agreement that tax avoidance is included under illicit flows. 2.1 Is there already consensus? The meaning of novel policy terms, is of course, politically defined. It is entirely up to parties to any international agreement to establish what they mean. Therefore the fourth argument could trump all others. If the governments involved in developing the SDGs had reached consensus on the meaning of “illicit financial flows” (or indeed “red flag financial flows” or “harmful financial flows” or any other form of words they might have chosen to use) then that would be the established definition. Alex Cobham (2017) argues that when SDG 16.4 was agreed, “there was no question that avoidance was included” and that there is “no question that those signing up to the SDG agreement to include target 16.4, did so in the belief that avoidance was included.” 8 However there is no record of the architects of the SDGs in practice adopting such a definition. Those that have reviewed the field such as The Interagency Taskforce on Financing for Development state that there is “as yet no firm agreement on conceptual and definitional issues related to the term IFFs” (Chowla & Falcao, 2016). The Report of the High-Level Panel of Eminent Persons on the Post 2015 Agenda, which informed the development of the SDGs, highlights both illicit financial flows and tax avoidance, however, it does not elide the two; it describes illicit flows as money illegally taken out of developing countries through money-laundering of bribes and stolen funds and to evade taxes, while also covering tax avoidance in a separate paragraph. Civil society organisations argued in the run up to the UNCTAD summit in 2016 that the UN should adopt a normative definition of illicit financial flows (Declaration of Civil Society, 2016), suggesting that this was not already the common accepted definition. The Financial Transparency Coalition says that “different country and regional interpretations of the term have made achieving political consensus at the global level challenging.”4 If there is already a clear global consensus around the wider definition, it is a well-kept secret. 2.2 Can the dictionary solve it? Another argument is that the dictionary definition of the word “illicit” requires that a broad approach which goes beyond illegality. For example the Oxford English Dictionary gives a definition of “not authorized or allowed; improper, irregular; esp. not sanctioned by law, rule, or custom; unlawful, forbidden.” Certainly in everyday speech a married person can have an illicit affair. A person on a diet might eat an illicit candy bar. A Muslim can have an illicit drink. However this argument is trivial. The sense of the word “illicit” is that something is against the rules in its relevant domain (and is therefore carried out clandestinely). In the domain of determining whether the assets a person holds rightly belong to them, to someone else or to the government the relevant domain is the law. The fact that the term “illicit financial flows” in the SDGs is sandwiched between illicit arms trade, theft of public assets and organised crime (indeed the phrase used is “reduce illicit financial and arms flows”) suggests that the definition of “illicit” should be the same as in these closely related domains. Illicit manufacturing and trafficking of firearms in the UN Convention Against Organised Crime is defined in relation to being unauthorized by the relevant states. Illicit enrichment (UNCAC Article 20) is where the assets of a public official increase beyond what can be explained by their lawful income. Illicit origin of property (in UNCAC Article 23) is referred to under “laundering proceeds of crime.” The illicit cigarette trade is defined by the FATF as “the production, import, export, purchase, sale, or 4 https://financialtransparency.org/conferences/tipping-point/ 9 possession of tobacco goods which fail to comply with legislation.” All of these meanings suggest that illicit in this context should be defined in relation to illegality. A further clue in this direction come from the specific origin of the term. Raymond Baker, founder of Global Financial Integrity, an organisation that has played a key role in coining the term IFFs and promoting it onto the international agenda, describes its origins in “A Brief Biography of Illicit Financial Flows” (GFI, 2015) as being more sophisticated than “dirty money” but less legally demanding than “illegal”: “One of our early conversations surrounded the phrase dirty money.” We both felt that this was counterproductive. It made people cringe and shrink from the subject.…So what should we call these enormous sums of money shifting out of emerging market and developing countries? After considerable discussion we homed in on the wording “illicit financial flows.” This had a number of advantages. “Illicit” is a slightly less demanding word than illegal and would be a bit more palatable to lawyers. “Financial” makes it clear that we are talking about money more than about drugs or arms or contraband. And “flows” is perhaps the most important word, making it clear that what is being addressed has an origin and a path and a destination. The combination of the three words is obviously more sophisticated than “dirty money,” not nearly so off-putting, much more robust, appealing to economists, lawyers, and policymakers. So “illicit financial flows” it was and still is.” 2.3 Grey areas? Chowla and Falcao (2016) rehearse the second argument, that sticking with the narrow definition could mean that IFFs could only be counted if they had been discovered and ruled against by a court or competent authority. This seems an overly narrow interpretation. The fact that some individuals and businesses get away with hiding, misreporting, or obscuring transactions in order to successfully evade a legal liability does not invalidate the conceptual definition of illicit flows being linked to illegality. Indeed this same issue could be raised for money laundering, drug trafficking, theft of public assets, and other core areas of illicit flows. Thus we are left with argument three, that there are large areas where there is uncertainty about the interpretation of the law or where there are “loopholes” which allow taxpayers to get away with following the letter but not the spirit of the law, and that these should be considered illicit. This is what is commonly termed “avoidance” (or aggressive avoidance, or abuse). However, there are important distinctions. Avoidance is often formally defined as practices designed to gain a tax advantage by contravening the intention of the legislation. For example the UK government says abusive tax avoidance is when “the course of action taken by the taxpayer aims to achieve a favourable tax result that Parliament did not anticipate when it introduced the tax rules in question and, critically, where that course of action cannot reasonably be regarded as reasonable.” The US Internal Revenue Service (IRS) characterises abusive tax avoidance transactions as those that “take a tax position that is not 10 supported by tax law or manipulate the law in a way that is not consistent with the law’s intent.” (Hoddes, 2016). In these and many other jurisdictions courts already seek to close this down, giving effect to the “spirit of the law” through purposive interpretation and anti- abuse rules, and revenue authorities can challenge unreasonable transfer prices and other transactions through audit. Such avoidance can therefore be found to be unlawful (i.e., turned into “failed tax avoidance”), and as such might be included under a definition of illicit on this basis, although it is not clandestine. Other common conceptions of “avoidance” go beyond this. For example the European Commission say avoidance is “taking advantage of the technicalities of a tax system or of mismatches between two or more tax systems for the purpose of reducing tax liability.”5 Devereux, Freedman and Vella (2012) argue that it is inconsistent with the rule of law to try to invoke a further “spirit of the law” which is different from the interpretation of legislation by the courts, or mechanisms such as General Anti-Abuse Rules (GAARs). Where a defect (or “loophole”) in the legislation is found, or where there is a problem of misalignments between the tax rules of different countries allowing taxpayers to arbitrage between them, they argue the most efficient course of action is to revise the specific legislation or treaty to close the loophole. Many BEPS planning strategies such as strategic transfer pricing and use of debt, treaty shopping and “hybrid mismatches” (such as the famous “Double Irish-Dutch Sandwich”) fall into this category (although are called “tax avoidance” in everyday speech). They can remain legal tax planning, unless rules and treaties are updated to prevent them. Changes to laws and tax treaties can prevent certain actions which were previously allowed, but this does not make them by definition “illicit.” 3. “Trade misinvoicing”: the meeting point between IFFs and avoidance? Beyond these conceptual distinctions, a practical argument is often made that there is a major category of action which has been identified as both “illicit financial flows” and also as “legal avoidance,” and therefore that the two areas cannot be separated. This category of action is “trade misinvoicing.” Trade misinvoicing is a form of customs and/or tax fraud involving exporters and importers deliberately misreporting the value, quantity, or nature of goods or services in a commercial transaction. Estimates of trade misinvoicing are closely linked the term “IFFs,” as both were popularised by Global Financial Integrity (GFI). GFI famously estimates that trade misinvoicing is the largest portion of illicit financial flows. It uses a methodology based on adding up gaps and mismatches in trade data to estimate 5 European Commission Recommendation on aggressive tax planning, 6 December 2012: http://eur- lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32012H0772&from=EN 11 that misinvoicing drains $800 billion from developing countries annually (GFI, 2015). Their work also inspired the UN Economic Commission for Africa (UNECA) and the African Union to set up a High Level Panel on Illicit Financial Flows from Africa which estimated that this practice, concentrated on a few commodities, is responsible for $50 billion of illicit flows from Africa (HLP, 2015). These numbers played a key role in the arguments for IFFs to be included the SDGs. The same numbers are often used to represent both fraudulent trade misinvoicing (for the purposes of smuggling, tax and tariff evasion, paying bribes and kick-backs, and to evade capital controls) and strategic transfer pricing used for profit shifting by multinational corporations. For example early NGO reports on corporate tax avoidance, such as Christian Aid’s “Death and Taxes” (2008) and “False Profits” (2009), used measures based on these misinvoicing estimates to assess the scale of corporate tax avoidance through “transfer mispricing.” The High Level Panel on Illicit Financial Flows also explicitly conflates trade misinvoicing and corporate tax avoidance, while others such as The Africa Progress Panel in 2013 simply confused them—suggesting that the gross amount of trade misinvoicing estimated by GFI was a tax loss due to transfer pricing (Forstater, 2013). This conflation can lead to circular arguments: for example the Financial Transparency Coalition (2016), whose leading member is Global Financial Integrity, argues that “excluding tax avoidance [from the definition of IFFs] would have detrimental consequences on revenue mobilization,” citing the Human Rights Council on Illicit Financial Flows and Human Rights (2016) which says that “tax-related illicit financial flows has the potential to make the largest fiscal impact.” However the evidence that the Human Rights Council draws on for this is GFI’s estimate of trade misinvoicing. Figure 2. Terms that are often perceived to be equivalent In recent years it is becoming increasingly clear that the trade misinvoicing estimates are problematic both in terms of understanding the scale and nature of customs fraud and as indicators of the kinds of structures and practices that major corporation use for tax planning. Gaps and mismatches in trade data "ILLICIT FINANCIAL FLOWS" "TAX AVOIDANCE" "TRADE MISPRICING" "TRADE MISINVOICING" ~ "largest contributor" / 12 3.1 Problem I: Gaps and mismatches in trade data don’t reliably reflect misinvoicing Trade misinvoicing certainly is a real phenomenon. For example business people in China have used overpayments for imports as a means to get around the country’s currency controls, and build up an nest egg of savings outside China. Companies in South Africa smuggle in shipments of clothing from China evading import duties.6 Dealers in Tanzanite has been found to be smuggling the gemstone out of Tanzania including in private cars and carried by Maasai herdsmen.7 In Venezuela scammers used inflated import invoices to buy cheap dollars from the official currency control agency. In Nigeria oil is sold from the national oil company at advantageous prices to politically well-connected middlemen known as “briefcase companies” who sell it on at a significant margin without serving any commercial function, essentially privatising what should be public revenue. In 2015 Côte d’Ivoire Customs issued 2,420 fraud reports. The offences most commonly recorded by frontline services are false values, false goods, and false weight declarations (Victorien Gnogoue, 2017). However, while it is clear that customs fraud is real, it is not clear that the influential and widely quoted figures based on adding up gaps and mismatches in trade data can be directly interpreted as trade misinvoicing. The theory of assessing trade misinvoicing is simple. When a shipment of goods crosses a border the importer or exporter declares what is in the container: 12 dozen cuddly toys valued at $1 each say, or twenty tonnes of copper valued at $4,000 per tonne. If the unit value and the amount declared match with what is actually in the container then there is no illicit flow. The correct tariff and VAT are levied, any export credits are correctly awarded, and eventually the companies involved will pay the right amount of corporate income tax, given the profit or loss they made on the deal. However the exporter or importer may seek to evade tariffs or taxes or hide a payment to an associate by declaring a value that does not reflect the real value of the goods (in either direction—higher or lower). Thus if there is a difference between what is declared and the actual nature, quantity, or value of the goods then this may be customs fraud and diversion of funds. 6 www.dailymaverick.co.za/article/2017-03-09-sars-unravels-sa-clothing-industry-tax-leakages-job-losses-blamed- on-illegal-imports 7 http://allafrica.com/stories/201608170084.html 13 Figure 3. Trade misinvoicing: Volume, price, and value If for example the container really contained 22 tonnes of copper, or the cuddly toys were worth $10 each, the value of the additional two tonnes of copper or the additional nine dollars per toy would be an illicit flow and could indicate a side payment being made through collusion between the buyer and seller and not declared for tax purposes (this mechanism can also be used as a channel for paying bribes or making kickbacks, as well as for evading currency controls). Customs inspectors may be able verify the actual volume and nature of individual cargo shipments and assess whether the price and overall value declared are correct. Large scale estimates of trade misinvoicing, however, rely on comparing trade statistics: looking at the declared value of transactions at one end of the trade (when the cargo is exported) with the value declared at the other (when it is imported). This “mirror data” approach of comparing what country A reports as an export to B and what country B reports as an import from A (or vice versa) is the basis for the widely cited trade misinvoicing studies, such as those carried out regularly by Global Financial Integrity as well as others such as UNECA/ High Level Panel (2015), and Boyce and Ndikumana (2012). In each case the calculation assumes that, where there is a developed country on one side of the trade, and the developing country on the other, the price and volume declared to its authorities and compiled into trade statistics on the developed country side will be correct (due to greater capacity for customs enforcement), and that, allowing for insurance and freight costs, any further difference between the trades reported by bilateral pairs of countries indicates trade misinvoicing. REAL VALUE Volume •◄---Price per unit -----1►• 14 Most commonly studies use a rule of thumb of allowing a 10 percent margin for insurance and freight, but some seek to take a more sophisticated approach applying different margins for different types of good. Figure 4. Estimating trade misinvoicing using mirror data The estimation problem is that not all trade misinvoicing shows up as mismatches in the trade data, and not all mismatches in the trade data are evidence of misinvoicing. This was illustrated clearly in 2016 when The UN Conference on Trade and Development (UNCTAD) published a study on trade misinvoicing of commodities under the headline “some countries are losing 67% of the value of their exports.” It highlighted specific instances which it saw as evidence of this level of misinvoicing (Ndikumana, 2016). The report by Professor Léonce Ndikumana analysed mismatches in international trade data in the UN COMTRADE database for seven country-commodity pairs: gold, silver/platinum, and iron ore from South Africa; copper from Chile and Zambia; cocoa from Côte d’Ivoire; and oil from Nigeria. In all seven cases it came to a single conclusion: there were substantial levels of misinvoicing. However in most of the cases a simpler explanation could be readily found. • South African gold: The UNCTAD report calculated that “virtually all gold exported by South Africa leaves the country unreported,” accusing mining companies of smuggling billions of dollars’ worth of gold. This was promptly disputed by the South African Chamber of Mines and the South African Revenue Import/ Export volume (kg) IMPORTER (DEVELOPED COUNTRY) DECLARED VALUE +-Import/Export price (USD/kg) ➔ 10% for insurance and freight 15 Authority. The Chamber of Mines commissioned an independent report from economics consultancy Eunomix (2016) which found that the mining companies and public agencies do report gold exports, just not in the right format for COMTRADE. They found that three quarters of the observed discrepancy could be explained just by looking up the official statistics. • Zambian copper: Copper is one of Zambia main exports. Trade statistics show that more copper is exported from Zambia to Switzerland and the UK than arrives in these destinations, but more Zambian copper arrives in countries such as China, Korea, Italy, and Saudi Arabia than Zambia reports as exports to those them. This has often been interpreted as indicating massive tax evasion and capital flight associated with copper exports from Zambia.8 The UNCTAD report the trade statistics as showing underinvoicing and overinvoicing in the two directions. However it is more readily explainable by merchanting trade involving trading companies in Switzerland and the UK, and by the London Metals Exchange system of bonded warehouses. For example if copper is reported as an export from Zambia to Switzerland, but in practice sits in a bonded warehouse before being delivered to Germany, this would show up as “overinvoiced exports” to Switzerland and “underinvoiced exports” to Germany, even if at each stage of consignment the declaration matched exactly with the contents of the container. • South African silver and platinum: The analysis suggested overall high levels of misinvoicing, made up of a combination of years when the discrepancy in the trade data is relatively small, and a few years when there are substantial discrepancies. In other words, it describes a scenario where the industry swung from legal compliance, to massive undetected smuggling, and then back again on an annual basis (and that no one noticed). This seems unlikely. It is notable that the COMTRADE database contains no record of South Africa’s platinum exports in 2000 and 2002, but SARS statistics show normal levels of platinum exports. The UNCTAD study attributes several billions of dollars’ worth of underinvoicing by exporters to the gap in the COMTRADE data for these two years. • Chilean copper: The study found significant overinvoicing of copper from Chile (i.e., copper imports from Chile are reported to be worth less than copper exports, given a 10 percent allowance for insurance and freight). This is likely to reflect shipping costs being lower than 10 percent. Copper cathode sells at about $5,000 / tonne, while freight shipping rates are measured in tens of dollars. Relatively valuable but non-perishable goods such as this are likely to appear to be overinvoiced by exporters because of their relatively low actual freight costs. • South African iron ore: The study observed a “drastic” shift from apparent underinvoicing to overinvoicing—suggesting illicit outflows, followed by illicit inflows. However this may also be explainable through relative transport costs. Iron 8 https://www.cgdev.org/blog/stop-spreading-myth-zambia-not-losing-3-billion-tax-avoidance 16 ore prices were rising till 2009 then fell gradually, while shipping costs fell precipitously, thus the margin of difference would have changed without indicating alleged secret side deals inexplicably being renegotiated. By looking at individual commodities it is possible to see that price volatility, transit and merchanting trade, and the use of bonded warehouses can result in large trade data discrepancies arising from legitimate trade. In particular ordinary, legitimate trade can generate systematic discrepancies in trade data involving three countries. For example a single shipment of copper could lead to apparent underinvoicing from Zambia-Switzerland and equal apparent overinvoicing from Zambia-Germany. Global Financial Integrity’s “Gross Excluding Reversals” method is based on the same general principle as the UNCTAD study (but uses aggregate “Direction of Trade” statistics), while the UNECA High Level Panel report on Illicit Financial Flows (“Africa is losing $50 billion to misinvoicing”) uses a similar methodology. The same country-commodity pairs as those that feature in the UNCTAD study are strong contributors to the UNECA total, with 60 percent of apparent misinvoicing relating to oil, precious metals, ore, machinery, copper and iron, and steel. In fact, gold, silver, and platinum are the second largest source of alleged misinvoicing in the UNECA study, and almost all of this relates to Southern Africa, where it now seems likely that the explanation is far more pedestrian. Figure 5. The High Level Panel’s findings indicate concentrated misinvoicing in a few countries and sectors 60 50 Percent of total 40 misinvoicing 30 20 10 0 6 COMMODITIES account for 60% of misinvoicing Machinery Copper Precious metals and minerals Oil 4SOURCES account for 40% of misinvoicing (annual misinvoicing in USD) $5.1 bn $1.5 bn $2.6 bn + Zambia copper (2%) SACU gold, platinum, + diamonds, ore, and steel (22%) + Algeria oil (5%) + Nigeria oil (9%) BasedonHLP 17 Further clues that ordinary merchanting and transit trade may be responsible for a large part of what is picked up in trade misinvoicing estimates can be seen from the overall pattern of trade reported globally. Carriere and Grigoriou (2014) note that discrepancies (“missing exports and phantom imports”) are very common when looking at country-commodity pairs at a detailed level, but that they cancel out when looking at wider commodity categories and world trade. CEPII, the French research institute which manages the BACI trade database, analysed 5000 products over ten years in the UN COMTRADE database and find that the declared quantities of commodities traded between country pairs were only similar in 11 percent of cases (Gaulier et al, 2008). For example reported exports of cocoa from the Netherlands are consistently greater than reported imports of cocoa from the Netherlands by partners (mainly developed countries, particularly Germany). The widespread nature of quantity divergences in trade statistics even between developed countries with strong customs and statistical capacity means that the assumption that the trade statistics at the developed country side are a sound benchmark against which any divergence can be interpreted as “misinvoicing” should not be taken for granted. It is striking that globally, imports and exports track each other closely, falling within the 10 percent margin conventionally allowed for the cost of transport and insurance overall. Figure 6. Global reported imports and exports (USD trillion) Adapted from Kellenberg, D and Levinson, A (2016). Misreporting Trade: Tariff Evasion, Corruption, And Auditing Standards. NBER Working Paper Working Paper 22593 This pattern of widespread statistical discrepancies between country-commodity pairs cancelling out at a global level could either reflect massive real illicit financial flows in all directions (independent, but oddly coordinated and involving diverse and unrelated parties), 14 13 12 11 10 9 Global trade 8 (trillions USO) 7 6 5 4 3 2 1 0 2004 2005 2006 2007 2008 2009 2010 2011 2012 Adapted from Levinson and Ke/fenberg 2016, drawing on COMTRADE data Imports Exports CIF/FOB margin (10%) 18 or could be caused by the value of shipments being correctly recorded under mismatched country and/or commodity categories. These observations provide concrete illustrations of the general problem with these estimates. Volker Nitsch in his paper “Trillion Dollar Estimate: Illicit Financial Flows from Developing Countries” reviews GFI’s “gross excluding reversals” methodology. He concludes that the quantitative results have no substantive meaning and that therefore the estimate of $800 million of trade misinvoicing globally “lacks evidence and is uncorroborated.” The IMF and the UN, whose data these studies draw on, warn that the statistics cannot be reliably used in this way. The IMF says, “we caution against attempting to measure [illicit flows] by using discrepancies in macroeconomic datasets… official estimates of trade misinvoicing cannot be derived by transforming trade data from the IMF Trade Statistics and/or UN COMTRADE, either by individual country or in aggregate.” The World Customs Organisation says that mirror trade analysis can be used as a risk assessment tool to highlight potential cases of misinvoicing, but that before the findings of any mirror analysis lead to assumptions of fraud they must then be verified by investigations in the field or in-depth document reviews (Gnogoue, 2017). 3.2 Problem II: “Misinvoicing” is not mispricing When Raymond Baker first wrote about the practice of misinvoicing in his book Capitalism’s Achilles Heel (2005) he called it trade mispricing, and he drew from 550 with officials from trading companies which largely focused on pricing. He said, “mispricing in order to generate kickbacks into foreign bank accounts was treated as a well-understood and normal part of transactions.” However GFI’s core methodology which uses aggregate IMF “Direction of Trade” statistics cannot differentiate mispricing from misdeclaration of quantities. Thus the language that GFI uses was later changed from “mispricing” to “misinvoicing.” Direction of Trade statistics only provide details of the aggregate value of trades—they don’t give details of prices and quantities. Thus a mismatch in value might mean that the price was misdeclared ($1 teddy bears instead of $10 ones) or that the quantity was misdeclared (22 tonnes of copper instead of 20) or it could reflect “orphan imports” or “missing exports” where there is no record of the shipment at all on one side of the transaction. In each case there might be innocent (green) or illicit (red) explanations as shown below. 19 Figure 7. Different possible interpretations of mismatched values of exports & imports Because Direction of Trade statistics aggregate across all commodities and over time they cannot be used to tell the difference between a concentrated area of customs fraud hiding amongst other compliant shipments and widespread marginal discrepancies of declared price or quantity. Price difference Q Technical smuggling DIFFERENCE IN ? EXPORT AND . < IMPORT VALUE p Q BETWEEN TWO Quantity difference COUNTRIES ? < p Q Missing data p Q p 20 Figure 8. Concentrated fraud or widespread marginal differences? The differences matter in practice because different types of misdeclaration represent different types of behaviour by taxpayers, and could be closer or further away from the “grey area” between legal and illegal action, and relatively harder or easier for customs officials to detect in practice. For example (aside from genuine administrative errors such as recording the wrong commodity code or unit of measure by accident), misdeclaring the quantity or nature of a shipment could be outright customs fraud (for example shipping cars and declaring them as scrap metal, or shipping 20 kgs of gold but only declaring 5kg). Massively under- or over- reporting prices could also be customs fraud (such as exporting buckets for $973 each), or outright smuggling. However such cases are either technically easy to detect through visible inspection or (somewhat harder, but still straightforwardly) through systems for monitoring commodity exports, such as in the mining sector. If blatant huge misdeclarations of quantities and prices (including outright smuggling) are taking place this suggests massive tax evasion, with customs inspectors are looking the other way (whether through lack of capacity, or complicity). This though is not what is usually understood as “mispricing.” CONCENTRATED FRAUD Q Q p p Q Q p p Q Q WIDESPREAD MARGINAL DIFFERENCES Q p p Q p p 21 Table 4. Implications of different misinvoicing scenarios Misinvoicing scenario Behaviour by tax payer Ease of detection by customs Pricing difference Large/ concentrated  Tax evasion/ Customs fraud  Relatively easy (requires some price knowledge but easy to spot, particularly for commodities) Marginal/ widespread  BEPs/ transfer price abuse?  Could reflect ordinary costs/ variance?  Hard (requires detailed price knowledge) Quantity/ commodity difference Large/ concentrated  Tax evasion/ Customs fraud  Very easy (gross physical inspection) Marginal/ widespread  Tax evasion/ Customs fraud?  Medium (precise physical inspection, minerals monitoring) Destination difference Large / concentrated  Smuggling?  Ordinary transit/ merchanting trade?  Relatively straightforward to investigate large scale smuggling by major corporations—through tax audit, minerals monitoring Small/ widespread  Smuggling?  Ordinary transit/ merchanting trade?  Hard to detect small scale cross- border smuggling The only type of taxpayer behaviour which equates to BEPS type tax avoidance and which might show up as discrepancies in trade data is transfer price manipulation being used to shift profits to a third country. However these marginal price differences could also reflect legitimate use of a marketing hub. For example many mining companies use a subsidiary in marketing hub to sell commodities to end consumers. It could charge a margin of 2-4 percent of the value of the commodity, or even 6 percent if the hub takes physical and legal possession of the commodity or undertakes innovative marketing or risk exposure (Readhead, 2016). Tax authorities might challenge the level of the marketing charge on audit—as Australia has done recently with BHP Billiton, and it could result in more tax being payable in a particular jurisdiction (and perhaps less in another) but such disputes are not uncovering about clandestine transfers but challenging the valuation of the service provided by the hub. Often the term trade misinvoicing and trade mispricing are conflated suggesting that the behaviour being described by the data is largely about price manipulation by companies operating at the borders of legality by declaring barely acceptable transfer prices. However in practice it appears that what the misinvoicing studies pick up often is destination mismatches (which may well have ordinary explanations in transit and merchanting trade) and quantity differences (which could have either criminal or ordinary explanations). 22 Box 2: Exploring prices, quantities and destinations: The case of cocoa Côte d’Ivoire has often been highlighted as a country which suffers large illicit flows from the cocoa trade—which makes up over 40 percent of its exports (Côte d’Ivoire cocoa features in both the UNCTAD report and High Level Panel report). The High Level Panel report states that cocoa is a significant source of IFFs, and that Côte d’Ivoire accounts for 38 percent of this. A simple calculation comparing cocoa exports and imports on a bilateral basis confirms that there are significant mismatches.9 Figure 9. Calculating underinvoiced exports of cocoa from Côte d’Ivoire using the Gross Excluding Reversals methodology This reflects large bilateral mismatches—for example cocoa is reported as an export to Estonia, Belgium, and the Netherlands, but does not arrive there. Meanwhile more cocoa arrives in Germany, Russia, and France than is reported as exported to those destinations. Trade misinvoicing studies tend to interpret these mismatches as separate and unrelated smuggling reflecting illicit financial flows into and out of Côte d’Ivoire. However this seems less likely than the alternative scenario which is that cocoa bean wholesalers in countries such as Estonia, Belgium, and the Netherlands are buying cocoa beans which are then delivered (including via bonded warehouses) to chocolate manufacturers in countries such as Germany, Russia, and France. When we look at the price per kg of cocoa beans on export and import, there is in fact no sign of mispricing. 9 NB: the calculation done here is slightly simpler than GFI’s “Gross Excluding Reversals” methodology as it treats all partner countries—both developed and developing equally, whereas GFI applies a slightly different method when partner countries are also developing economies. 900 30 800 25 700 Exports 600 20 Percent of (millions USO) 500 partners' 15 imports 400 300 10 200 5 100 0 0 2010 2011 2012 2013 2014 2015 Author's calculations based on COMTRADE data 23 Figure 10. Export price and import price of cocoa from Côte d’Ivoire (USD/kg) If we look only at the quantity effect (how many kilogrammes of Ivorian cocoa beans are imported by the world compared to how many are exported from Côte d’Ivoire) there remains some discrepancy, which in most years is less than 10 percent (usually under, but sometimes over). This could reflect a degree of smuggling, cocoa beans going into or out of store, or cocoa beans from other countries being mislabelled. Similar analyses might be undertaken on other commodities to break down misinvoicing estimates into destination, price, and quantity effects. 3.3 Problem III: Findings from trade misinvoicing studies do not reflect corporate practice by major multinational companies Raymond Baker began to work on IFFs following his own experience as a business owner and manager in a number of African countries. The practices that Baker describes from his experience and interviews with other tightly-held companies suggest illicit behaviour. They include misinvoicing in order to pay a bribe, generate a kickback, or to evade taxes or currency controls, in each case to divert funds into hidden accounts. While multinational corporations have too often been involved in corruption, this is not the kind of thing that is generally being defended when companies face tax controversies and respond that “we pay tax according to the rules.” Shareholder owned companies in particular have procedures and controls in place to try to prevent bribery, kickbacks, and embezzlement, as it would mean shareholders being defrauded (Truman, 2010). Similarly where misinvoicing methodologies indicate large scale smuggling or misdeclaration of quantities, again this is not the kind of practice that would be defended as ordinary business. This is recognised by the African Tax Administration Forum (ATAF, 2014) which notes that misinvoicing is not significantly related to multinational corporations, and that while multinational corporations may undertake sophisticated tax 3.5 3.0 2.5 Average price (USD/kg) 2.0 1.5 1.0 0.5 0 2010 2011 2012 2013 2014 2015 Author's calculations based on COMTRADE data, with 10% allowance for freight and insurance Export price Import price 24 avoidance involving complex but well documented transfer pricing design, they do not tend to undertake fraudulent activity. They distinguish this from the risks emanating from owners and managers of closely held companies, noting that “there is evidence that business receipts due to individuals or smaller businesses may be diverted to privately owned companies in tax havens, with little or no justification or documentation.” Nevertheless misinvoicing estimates have been used to stand in for multinational corporate tax avoidance. The adoption of trade misinvoicing measures as indicators of the problem of corporate tax avoidance has leads to a misperception of the nature of transfer pricing issues—in particular assuming large hidden margins in commodity supply chains such as for bananas and copper. Examples such as the “$973 bucket” and “the 50 pence fridge” which derive from outliers in trade data have been widely used as popular explanations of transfer pricing issues but bear no relationship to actual transfer pricing practices by major corporations (Forstater, 2015). Box 3: The $973 bucket The $973 bucket (reportedly exported from the Czech Republic to the US) is a popular illustration that has been used as a demonstration of transfer pricing abuse, alongside others such as fenceposts from Canada at $1,853, a kilo of toilet paper from China for $4,122, and a pair of tweezers from Japan at $4,896. As Prem Sikka (2003) argued these “actual prices charged by some of the world’s biggest multinational corporations, all authorised by some of the best accountants, and by political friends in high places. Their game is to shift the tax burden onto somebody else. It is played through ‘transfer pricing’.” Similarly Eurodad (Ruiz and Romero, 2011) highlights the $973 bucket as a case of one US corporation using manipulated pricing schemes to avoid paying taxes. Forum Syd (Fröberg and Waris, 2013) also highlights the for $973 bucket as a case involving a profit shifting from a developing country to a tax haven. “A more realistic price paid on the open market would have been around one dollar. The rest of the price paid is just a way to shift profit to the subsidiary in the tax haven where less tax is paid.” If the famous $973 was a true reflection of corporate transfer pricing practice then it would it makes sense to view avoidance, misinvoicing, and illicit financial flows as so closely related that they cannot be differentiated. As Prem Sikka says "They are suggestive of a widespread, systematic setting of transfer prices in whatever direction helps to avoid taxes and boost profits" However evidence for the $973 bucket does not come from a particular business that was caught at mispricing, but from analysis of US published trade data by Pak and Zdanowitz (2002). A more parsimonious explanation of the $973 bucket and the other similar examples is that they reflect mistakes in recording the quantity of items (for example the price of a shipment of items rather than a single item) or mistakes in the commodity code recorded. Certainly no one would try to defend these as “arms length prices” and the US Internal Revenue Service would challenge them if they tried (Lunnan, 1996 and Weisman, 2002) 25 3.4 Are there large hidden margins in commodity trading? Cross border-criminals, money launderers, bribe payers, bribe takers, and tax evaders do hide transactions amongst legitimate trade flow. Products such as diamonds, other gemstones, and gold and jewellery are easy to smuggle, while other products such as oil may be stolen or misreported. The problem is real. However the idea that such illicit financial flows can be reliably identified through simple calculations using publicly available data appears overoptimistic. These calculations systematically transform records of ordinary trade flows into large misinvoicing estimates which in turn have been interpreted as reflecting systematic and egregious mispricing by multinational companies. They create perceptions that major companies doing international business in developing countries must be getting away with hiding vast illicit flows, while customs, revenue, and statistics agencies in developing countries must all be utterly incompetent or complicit. These calculations have supported a widely held perception of large hidden margins in commodity supply chains. One common reading of the illicit flows estimates is that they must reflect exploitation of primary producers through trading relationships which extract a high margin on commodities. However, as the cocoa bean example above highlights destination (i.e., volume) mismatches can have a much bigger effect on the numbers than price effects, without indicating any illicit flow or hidden price margin. Another reason to be sceptical of the idea that simple calculations on publicly available trade data reveal large hidden margins in the commodity trade is that commodity trading is a competitive business that is based on low margins and high volumes. If there was a better deal to be done, or if traders found out that their competitors were making large margins, this would be commercially valuable information, and would an opportunity for arbitrage. Large scale misinvoicing estimates are often reported as a development issue, but have been largely ignored by the financial and trade media, although if they had information about hidden margins this would be highly material for traders. The experience of Fairtrade also suggests that there is not a big margin in the supply chain of commodities such as cocoa, tea, and coffee which can simply be reallocated to producers. 26 Box 4: Acacia Mining: A case of massive illicit flows? Developing countries face real challenges in securing revenues from natural resources. However, inflated expectations of massive hidden margins can contribute to policy instability and undermine government accountability. One current example of this is the dispute between Acacia Mining and the Government of Tanzania (see Forstater and Readhead, 2017). There have long been concerns about whether Acacia Mining is paying enough tax in Tanzania. Between 2010 and 2015, Acacia paid $444 million in dividends to shareholders, despite not yet paying any income tax in Tanzania. There is a widespread belief expressed in the media and by politicians that underlying Acacia’s tax affairs are mechanisms which enable it to illicitly export much of the value of its products. However analysis of mining revenues by Open Oil (2016) highlight that the main reason for the lack of corporate tax is that there were generous fiscal terms in the original mining agreement, specifically an additional capital allowance, that meant Acacia could deduct 100 percent of its $4 billion investment, plus a 15 percent margin, before paying any income tax. In March 2017 an export ban was introduced on unprocessed minerals and ores. Exports of concentrate (an intermediary product between ore and metal) were halted due to the ban. In May 2017, President Magufuli appointed two special committees to investigate the contents of 277 of the containers stuck at the port. The first committee reported that the concentrate contained around twice as much copper and silver, and around eight times as much gold than was declared by the company. They also detected a range of other metals. If the committees’ findings are accurate, the extent of the undervaluation would be enormous, amounting to almost $4 billion annually (one tenth of Tanzania’s GDP). The second committee scaled these figures up to cover 61,320 containers exported between 1998 and 2017, suggesting the true value of concentrate exports was $83 billion and that the government had lost $31 billion of revenue trade due to misinvoicing and transfer price manipulation. The company maintains they have always declared all materials produced and paid all royalties and taxes that are due, while The Tanzania Mineral Audit Agency (TMAA) undertakes careful work to monitor minerals exports. The committee’s belief that they have uncovered a case of massive misinvoicing (i.e., misrepresentation of the value or quantity of exports) does not seem plausible for economic and geological reasons (Forstater and Readhead, 2017). The committee’s reports suggest that the mine was producing massive amounts of unreported gold, iridium, and ytterbium, but that this has been covered up. This would mean an extraordinary conspiracy, including defrauding shareholders. 27 4. “Tax-havens”: The meeting point between IFFs and tax avoidance? Another argument is made that illicit financial flows and corporate profit shifting are fundamentally the same phenomena because they both involve “tax havens” and/or “secrecy jurisdictions.” The three topics of IFFs, havens, and multinational profit shifting are often considered together (for example see Fjeldstad et al, 2017), particularly by civil society networks and the media. The linkage between tax havens, illicit financial flows, and multinational corporate taxation goes back to the early days of Norway’s advocacy engagement (Tilley, 2016) and can be seen in the original Draining Development book (World Bank, 2012). Sol Picciotto (2018) makes a strong form of the argument stating that any financial transaction or structure that takes place “offshore” (a term that he does not define) is by definition illicit: “Offshore is a murky world which facilitates a range of criminal, illegal, illegitimate and undesirable practices, all covered by the broad term illicit. …. It is sometimes said that many of these activities are ‘perfectly legal’, and hence legitimate. However, if they are legal, there is no need to carry them out offshore. Offshore devices or structures all involve using the laws or facilities of another country to obtain an advantage not possible under the law that should apply. Private persons’ bank accounts, financial information and other aspects of their personal affairs are generally protected in all countries by laws on confidentiality and privacy, which can only be overridden in specified circumstances, when there is a public interest. There is a network of tax treaties aimed at preventing double taxation, and in any case countries wishing to attract investments generally provide inducements, not excess taxation. Resorting to an offshore arrangement always involves trying to get around an inconvenient law – dodging the law.” This categorical equation between “offshore/ tax havens” and “illicit” seems overly sweeping. Everywhere is “offshore” to everywhere else. While it is certainly true that people and enterprises can access legal frameworks that more convenient and advantageous than if they were confined to their home jurisdiction, this does not necessarily mean that they are evading or breaking rules at home or that they are doing something illegitimate. Piciotto’s formulation seems to rely on the idea that there is a single set of laws which “should” apply to every person or enterprise. However a wealthy international family which owns properties in several countries, a multinational enterprise managing risk, assets, and inventories across borders, or a joint-venture involving investors from several different countries all face choice of jurisdictions to use for legal structures and financial assets in the ordinary course of their affairs—and whichever they choose will be “offshore” to some parties. Nor should it be assumed that people everywhere enjoy the confidence that information held by banks or public authorities is securely held and protected from political or criminal 28 interference. Zucman (2017) finds that countries whose residents have the largest stock of offshore assets compared to GDP include autocracies (such as Saudi Arabia or Russia) and countries with a recent history of autocratic rule (such as Argentina or Greece), suggesting that lack of confidence in legal protections at home could be a key motivation for offshore holdings. Similarly not every country has institutions that enable businesses to raise capital on foreign stock markets, access reliable courts, or use flexible and sophisticated financial products. Jason Sharman (2012) finds for example that it is these factors, rather than criminal money or tax arbitrage, that explain the popularity of the British Virgin Islands as a conduit for investment into China (including round-tripping by Chinese investors). Development finance institutions investing public money in private enterprises regularly route their investments through tax havens as a means to overcome shortcomings in the legal systems in the poor and capital-scarce countries in which they invest (Carter, 2017). Multinational corporations tend not to seek out jurisdictions with weak legal or financial governance or those with extreme secrecy. For example Oxfam (2017) found that the top 5 “tax havens” where European banks earn profits are Hong Kong, Luxembourg, Belgium, Ireland, and Singapore (only two of which score below 60 on the Tax Justice Network’s Financial Secrecy Index). Simply deeming that everything involving international finance that goes on in these places is murky and “illicit” requires stretching the definition far beyond boundaries which relate to the law. The use of international financial system to enable tax evasion, and hiding of stolen assets, is clearly a problem. Preventing financial institutions, and the financial centres that host them, from being used in this way by crime syndicates, kleptocrats, and opportunistic tax evaders is core to the illicit financial flows agenda. However the role that international financial centres play in mediating investment, enabling people to diversify their assets, and supporting global commerce are also critical benefits to society. Too little is known about the how much of what takes place offshore is beneficial, defensible, or objectionable, and bundling these categories together under the “illicit” umbrella will not support greater clarity and understanding. 29 5. Conclusion The distinction between doing something that is currently against the law (or that abets those seeking to get away with illegal acts) and doing something that is within the bounds of civil liberties is critical to protecting civil rights and freedoms. It is fundamental to the democratic political process and the rule of law that laws are set by the legislature and interpreted by the judiciary. Legislative changes can shift behaviours from one category to the other (as has been the case with the BEPS), and administrative improvements and information sharing can make it easier to determine which side of the line activities are on—but the distinction remains important. Using a conceptual definition of illicit financial flows which combines what is illegal with what uncertain, or what is judged to be undesirable by some unelected group, undermines and confuses accountability and understanding. A careful analysis of the trade misinvoicing estimates and cases, and of the role of international financial centres does do not support the view that illicit financial flows, legal tax avoidance and the use of “tax havens” are categorically the same. Nor, as it is sometimes stated, is it true that corruption is only a minor part of the IFFs agenda, dwarfed by massive outflows related to multinational investment. Figure 11. These terms are not equivalent Ultimately the question of how the term “IFF” is defined will only settled by those that define and use it, whether as international organisations, governments, researchers and academics, or activists. While different players have different perspectives, they have a common interest in strengthening administration of tax law so that it is neither weakly enforced, nor capricious and predatory. This is positive for citizens, businesses, and government, and ultimately critical for sustainable development. Concentrating on battling definitions may be seen as a distraction from this underlying common objective, but incompatible language can become a barrier to understanding and dialogue. Being clearer about the distinction between acts of tax fraud and evasion (alongside Gapsand ? mismatches • in trade data "ILLICIT FINANCIAL FLOWS" ~ 'TAX AVOIDANCE" ~ 'TRADE MISPRICING" ~ 'TRADE MISINVOICING" "largest contributor" ? / 30 bribery, corruption, money laundering, and theft of public assets) on one hand and tax avoidance and tax uncertainty on the other does not entail an absolute “parting of the ways” of tax and anti-corruption, but a clearer understanding of issues and potential solutions.10 Transparency and accountability of fiscal regimes (including in areas such as the extractive sector), ending abuse of anonymous companies, tackling customs fraud, and rationalising and regularising tax incentives are areas of common ground which necessitate collaboration. Certainly, globally integrated value chains combined with complex (and sometimes incomplete) tax rules mean that the tax affairs of major multinational companies will always be challenged or adjusted. There are wider questions about how the international tax system should be developed to address the digital economy and to better serve developing countries. However, bracketing questions of how to allocate international taxing rights along complex international value chains into the same category as prosecuting theft of public assets, or money laundering of criminal proceeds, implies guilt-by-association which is not be helpful for public-private dialogue, development of effective fiscal regimes and accountability, or cooperative compliance. 10 See also Transparency International’s deliberations about whether “tax abuse” and corruption should be equated. Barrington, R. 2016. When Is Tax Abuse Corruption? The New Official View of Transparency International http://www.transparency.org.uk/when-is-tax-abuse-corruption/#.Wp00KhPFLeQ 31 Bibliography African Tax Administrators Forum. 2105. Illicit Financial Flows and Trade Misinvoicing: the challenges for Africa. Allison Christians. 2014. Avoidance, Evasion, and Taxpayer Morality. Baker et al.,. 2014. Illicit Financial Flows from Developing Countries: 2003-2012. Baker, Raymond. 2005. Capitalism's Achilles Heel: Dirty Money and How to Renew the Free Market System. Carrere, Celene and Christopher Grigoriou. 2014. Can Mirror Data Help to Capture Informal International Trade? Policy Issues in International Trade And Commodities Research Study Series No. 65. UNCTAD. Carter, Paddy. 2017. Why do Development Finance Institutions use offshore financial centres? ODI Report. Chowla, Peter and Tatiana Falcao. 2016. Illicit Financial Flows: concepts and scope. Interagency Task Force. Christian Aid. 2008. Death and Taxes. Christian Aid. 2009. False Profits. Cobham, Alex and Petr Jansky. 2017. Global distribution of revenue loss from tax avoidance: Re-estimation and country results. WIDER Working Paper 55/2017- UNU- WIDER. Cobham, Alex. 2015. Illicit Financial Flows Assessment Paper. Copenhagen Consensus. Crivelli, Ernst, Ruud de Mooij and Michael Keen. 2015. Base Erosion, Profit Shifting and Developing Countries. IMF Working Paper. Declaration of Civil Society. 2016. Declaration of Civil Society to UNCTAD XIV Devereux, M., J. Freedman and J. Vella. 2012. Paper 1: Tax Avoidance. Oxford University Centre for Business Taxation. Eunomix. 2015. A review of the UNCTAD report on trade misinvoicing, with a focus on South Africa’s gold export Draft final 7 November 2016. European Parliament. 2015. Report on tax avoidance and tax evasion as challenges for governance, social protection and development in developing countries. Financial Transparency Coalition (2016). Financial Transparency Coalition. 2016. Recommendations to the United Nations Conference on Trade and Development (UNCTAD 14) on Illicit Financial Flows. Fjeldstad, Odd-Helge, Sigrid Klæboe Jacobsen, Peter Henriksen Ringstad, Honest Prosper Ngowi. 2017. Lifting the Veil of Secrecy: Perspectives on International Taxation and Capital Flight from Africa. Bergen: CMI. Forstater, Maya. 2015. Can Stopping 'Tax Dodging' by Multinational Enterprises Close the Gap in Development Finance? CGD Policy Paper 069. Washington, DC: Center for Global Development. Gaulier, Guillaume, Julien Martin, Isabelle Mejean and Soledad Zignago. 2008. International Trade Price Indices. CEPII Working Paper 2008-10. Global Financial Integrity. 2015. Illicit Financial Flows from Developing Countries: 2004- 2013. Gnogoue, Victorien Roger-Claver. 2017. Mirror analysis, a risk analysis support tool for Customs administrations in WCO News. February 2017. 32 Hearson, Martin. 2014. Tax-motivated illicit financial flows A guide for development practitioners. Anti-Corruption Resource Centre. Bergen: CMI. High Level Panel on Illicit Financial Flows from Africa. 2015. Track it! Stop It! Get It! Hoddes, Robin. 2016. Corruption and Tax Abuse: two sides of the same coin. Transparency International Policy Position. Inter-Agency Task Force on Financing for Development. 2017. Illicit Fianncial Flows. Background Note. http://www.un.org/esa/ffd/wp- content/uploads/2017/02/Background-note-on-illicit-financial-flows.pdf. Johannesen, N. & Pirttilä, J..2016. Capital flight and development: An overview of concepts, methods, and data sources. 2016/95. Helsinki: UNU-WIDER. Lunan, C.1996. Tax Cheating? Or Clerical Gaffes? Fiu Professors Say Import-export Data Point To Billions Of Laundered Dollars The IRS, Though, Isn't Buying It. Messick, Richard. 2018. Human Rights Law and Victim-Centered Remedies for Kleptocracy Paper prepared for “Improving the Human Rights Dimension of the Fight against Corruption,” Conference organized by the Centre for Civil and Political Rights Geneva, February 19 –20, 2018. Ndikumana, Leonce. 2016. Trade Misinvoicing in Primary Commodities in Developing Countries: The cases of Chile, Cote d’Ivoire, Nigeria, South Africa and Zambia. Geneva: UNCTAD. - Nitsch, Volker. 2016. Trillion Dollar Estimate: Illicit Financial Flows from Developing Countries. In: Darmstadt Discussion Papers in Economics, 227. Darmstadt. OECD. 2014. Illicit Financial Flows from Developing Countries. Open Oil. 2016. Financial analysis of the Acacia Mining tax dispute OpenOil, June 10, 2016. Picciotto, Sol. 2018. Illicit financial flows and the tax haven and offshore secrecy system. Tax Justice Network. https://www.taxjustice.net/2018/02/08/illicit-financial-flows-tax- haven-offshore-secrecy-system/. Readhead, Alexandra (2016) Preventing Tax Base Erosion in Africa: A Regional Study of Transfer Pricing Challenges in the Mining Sector. Reuter, P. (Ed.). 2012. Draining Development? Controlling Flows of Illicit Funds from Developing Countries. Washington, DC: World Bank. Reuter, Peter and Edwin Truman. 2005. “Chasing Dirty Money: The Fight Against Money Laundering.” Reuter, Peter. 2016. Illicit Financial Flows and Governance: The Importance of Disaggregation. Working Paper for the 2017 World Development Report. Washington, DC: World Bank. Sharman, Jason. 2012. Chinese capital flows and offshore financial centers. The Pacific Review Volume 25, 2012 - Issue 3. Tilley, Helen. 2016. Case study on Norway's engagement in the fight against illicit financial flows and tax havens: commercial tax evasion. TJN. 2017. Tax Justice Network warns at the UN against subversion of Sustainable Development Goals. Transparency International. 2004. Global Corruption Report. Truman, Mike. 2010. Lack of evidence. Taxation Magazine. February 17 2010. https://www.taxation.co.uk/articles/2010/02/17/19977/lack-evidence. 33 UN Human Right Council. 2016. Final study on illicit financial flows, human rights and the 2030 Agenda for Sustainable Development of the Independent Experts. United Nations. 2016. Coherent Policies for Combatting Illicit Financial Flows. United Nations. 2016. World Economic Situation and Prospects 2016. Vienna University. 2016. Tax and Good Governance Overview of the project. Weisman, Jonathan. 2002. Phony Prices May Hide Import-Export Profits From IRS. World Bank. 2016. The World Bank Group’s response to illicit financial flows: a stocktaking. Zucman, Gabriel, A. Alstadsæter and N. Johannesen. 2017. Who Owns the Wealth in Tax Havens? Macro Evidence and Implications for Global Inequality. NBER Working Paper. 1 Baumb, Nelly From:Aram James <abjpd1@gmail.com> Sent:Saturday, May 15, 2021 9:47 PM To:Council, City; city.council@menlopark.org; City Mgr; Planning Commission; Human Relations Commission; chuck jagoda; wilpf.peninsula.paloalto@gmail.com; Roberta Ahlquist; Shikada, Ed; ParkRec Commission; Joe Simitian; cindy.chavez@bos.sccgov.org; Anna Griffin; supervisor.ellenberg@bos.sccgov.org; mike.wasserman@bos.sccgov.org; paloaltofreepress@gmail.com Subject:Young Palestinian speaking truth to power -very nicely gone!! Attachments:IMG_9404.mov CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.  ________________________________      Sent from my iPhone  2 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Saturday, May 15, 2021 7:40 PM To:Allan Seid Subject:Fwd: Scan Attachments:20210515182951027.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.      Date: Sat, May 15, 2021   Subject: Understanding Asian American and Pacific Islander Experience  Source: Palo Alto Daily Post  Fr: Allan Seid       Asian Americans for Community Involvement (AACI) AAPls' identities call be mistaken. BY KYLE MARTIN Daily Post Staff Writer experts told Santa Clara County Super- visor Joe Simitian. alize AAPis as simply either Chinese or Japanese, whereas younger generations have had more experience with more ethnic groups. · Asian American and Pacific Island- . ers can often be mistaken to have the wrong country of origin, or be another ethnicity altogether, a panel of AAPI Natalie Masuoka, an associate pro- fessor of political science and Asian American studies at UCLA, told Simi- tian some older generations may gener- But this means AAPis often grew up · [See AAPI, page 34] being mistaken for ethnicities they don't claim for many reasons, the most obvious being that somebody who maybe has had little to no exposure to Thai, Viet- namese, Korean or Filipino cultures might mistake one of these people for a Chinese or Japanese person. Asian Americans and Pacific Islanders (AAPI) come from countries and territories such as The Phil- ippines, China, Vietnam, Korea, Thailand, Cambo- dia, Japan, Taiwan, Laos, New Zealand, American Samoa, Samoa, Tonga, Guam, the Commonwealth of the Northern Mariana Islands and elsewhere. Native Hawaiians are also considered Pacific Islanders. And Santa Clara County is known to have one of the most abundant, if not the most, Vietnamese populations outside of Vietnam. Pawan Dhingra, an author and professor at Am- herst College in Massachusetts, said often people mistake Indian Americans for another ethnic group from South Asia. · Dhingra helped Simitian understand ways to re- fer to people from South Asia, such as people from India. If you are certain of the ethnicity of the per- son you are referring to, "Asian Indian American" or "Indian American" are appropriate terms . to describe someone, Dhingra said. Though he added the more "inclusive" term for someone whose ethnicity you are describing, but think they could be from India or another nearby country, you can use "South Asian American," referring to th~ entire subcontinent. Different connections to immigration And Masuoka pointed out that different AAPis grow up with different connections to immigration, with som~ having never immigrated at all after being born of immigrant parents in America. Masuoka said some AAPis are often recruited to come to America to work in industries throughout the country, while others are refugees. Some weren't allowed to come to the country until 1965 when the Immigration and Nationality Act was passed. Daily Post Saturday, May 15, 2021 Dhingra pointed out to Simitian that often immi- grants, especially .undocumented immigrants, arrive in America under a certain work or tourist visa and ei- ther accidentally or purposefully overstay past the vi- sa's expiration. He said South Asian Americans own about half of the country's motels. And he shared what it's like to be mistaken for another ethnicity. Whereas Masuoka said she thinks Japanese Ameri- cans are more like Europeans who mostly immigrated to America five or six generations ago. "You have a much smaller share of the Japanese American population that's actually connected with the immigration experience," she said. Term from 1960s · Dhingra also explained that the term "Asian Amer- ican" is a "historically invented term" dating back to the 1960s in the same era as the Black Power move- ment. "It was a way to move away tram the term of the day, which was "oriental," which has within it an in- herent foreignness and a lack of human quality, frank: ly," Dhingra said. "So 'your rugs may ~e oriental, but people aren't,' is what people said." Michele Lew, CEQ of nonprofit The Health Trust, which helps people find food, housing and health · care, joked with Simitian and said she identifies as "ABC," or "American Born Chinese." Simitian joked that it could also mean "Armenian By Choice." And Lew said "I'm really excited for the next generation," which includes her .son, who is mixed of Chinese and European descent, she said. "We teach our son that eventually all Californians are going to be brown haired and brown eyed just like he is. But we really want to make sure that we are ex- posing him to all aspects of his heritage and then we will support him in whatever terms he chooses to use for his identity/' Lew said. "It's helpful to, I think, be able to sort of put a per- sonal framework around these sort of abstract and ac- ademic issues," Simitian said. Simitians next panels will be over the next two Thurs.days from 6:30 p.m. to 8 p.m. ·To register, visit www.tinyurl.com/understandin- gaapi. anta ara ounty uperv1sor JOE SIMITIAN 3 Baumb, Nelly From:Yahoo Mail.® <honkystar@yahoo.com> Sent:Thursday, May 13, 2021 9:26 PM To:Honky Subject:SUICIDES, VACCINES & THE JUDGMENT DAYS By Eric V. Encina Attachments:SUICIDES AND VACCINES II.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.  SUICIDES, VACCINES & THE JUDGMENT DAYS    By Eric V. Encina  More than 3,000 to 4,000 super-rich bunch of cold-blooded global elitesof various races and colors, and their minions and wannabes all over the world,of tens to hundreds of trillions of dollars $$$ of assets, and ofvarious ventures, of lines of expertise,and of philosophies of life, andabsolutely with pestiferous spirits, in this damned planet earth, have, of points of NO return, and no probable recanting, unanimously, deviously, determinedly, with all their guts and wealth, totally marshalled onward and forward to indubitably, eccentrically,adroitly ANNIHILATE, “billionsof people in this planet” (initially, 3billion to kill in the span of 48 months’ time), likewise of various races, directly targeting the silly compliant, brainwashed and mind-conditioned poor and the ageing inhabitants and the entireunsuspecting public, of increasingly-made-goyim of all races, technicallyand technologically BY WAY OF THE STINGS OF SWAB TESTING, AND CERTAINLY BY WAY OF COVID-19 mRNA experimental injections or otherwise known as COVID-19VACCINATION of extremely questionable poisonous ingredients with nano- technology insidiousparticles for monitoring and surveillance living or dead, along with the HIGHLYXENOBIOTIC, PULSE MODULATED MICROWAVE RADIATION OF 5G TECHNOLOGY, hence,that causes viruses because of radiationpoisoning.   Mysteriously, or, fortunately, orunfortunately, God is seemed to be in line with the EVIL PLANS or planned-demic schemes of the 3,000 to4,000 super-rich bunch of cold-blooded global elites, not because they are good, but because GOD is also using them, andtheir pestiferous METHODS, to judge HUMANITY, the poor, and all others, since after all, MAJORITY OF THE POOR DO NOT ALSO LISTEN TO GOD, DO NOT OBEY HIS COMMANDMENTS, AND THEREFOREDO NOT DO HIS WILL. LIKEWISE, THE POOR DONOT RECOGNIZE THE TRUTHS AND THE FACTS EVEN THERE ARE SIGNS THAT THEY SHOULD DOSO.   So many poor Filipinos every day at increasing numbers, SOONAT AROUND 50 TO 70 MILLION FILIPINOS, apparently convinced, brainwashed andmind-conditioned and whatever reasons in the SUICIDAL MODES and while obsessed media guys are parroting and the heartless politicians, ANDVACCINE SYNDICATES IN THE COVID-19VACCINE ADDICTION, FOR THEIR EXPECTED PROTECTIONS fromdiseases here in the Philippines: multitudesof educated, and uneducated, very poor and middle classes citizens, religious and secular, working andnon- working, retired and not-yet-retired, vagabonds and non-vagabonds, pensioners and non- pensioners,unfortunately, some are farming, ofvarious walks of life, including those partially paralyzed or withcomorbidities, are LINING UP mindlessly and thoughtlesslywearing face masks and face shields in fear and trembles in various places here in the Philippines of Covid-19 vaccine centers, now with theCovid-19 mega-vaccine centers in preparations, FOR COVID-19 VACCINATION.   4 Strangely, even those who seriously suffered, and are suffering ADVERSE EFFECTS,they say, they don’t regret having Covid-19 vaccine injections, and they still encourage others. That’s why Isay, “VACCINATED PEOPLE ARE DAMNED PEOPLE”, also poisoning their brains other thantampering their DNA or genes, believing things of incredible lies, andpersuading others to do the same as if WE ARE NOW VERY CLOSER TO ZOMBIENISM sosoon. And even I think, of those who died of Covid-19 vaccines, their souls arecertainly damned even if their spirits promote the vaccines to the living. ONCE COVID-19 INJECTIONS are injected to HUMANBODIES, SUCH PERSONS and thus their souls are therefore damned forever, the eternalsuicide.   Therefore, my deduction is that, WE’RE NOW INTHE JUDGMENT DAYS, though not yet final, but we see the meaning of “Matthew25:31‐46” – “The Sheep and the Goats”.  THEY GIVE VACCINES, INSTEAD OF FOOD FOR THE HUNGRY, THESTARVING, AND FOR THE POOR. Now, thepoor are also looking for vaccines instead of food. And remember, there’s “World to increasingly spend US$157 Billion on COVID-19 vaccinesthrough 2025” – https://www.msn.com/en‐ph/money/business/world‐to‐spend‐dollar157‐ billion‐on‐covid‐19‐vaccines‐through‐2025/ar‐BB1gbIFF?ocid=PanCafe&li=BB15QWvV, that accordingly, total  global spending on coronavirus disease 2019(COVID‐19) vaccines is projected to reach $157 billion by 2025,  driven by massvaccination programs underway and “booster shots” expected every two years.   In the Philippines, there’s      PHP 75 BILLION (lessthan US$1 billion?) as needed for expanded Covid- 19 vaccination of Filipinos targeting 50- 70Million Filipinos including an anticipating additional expenditure of about PHP20 billion orto vaccinate approximately 15 million Filipino kids aged 12 to 17, till end of the year2021 until next 2022 with the   “foreign loans secured for its pandemic response had reached$18.4 billion as of last month, April 2021, after the state increased Philippine borrowingsto plug its ballooning deficit that is 8.9% of gross domestic product this 2021.–   https://www.msn.com/en- ph/money/business/p75b-needed-for- expanded-vaccination/ar- BB1gHjVJ?ocid=PanCafe&li=BB15QWvV    5 We are in the judgment days by WAY OF COVID‐19PLANNED‐DEMIC. COVID‐19 PRC TESTING IS A JUDGMENT DAY,  positive or negative,COVID‐19 VACCINE IS A JUDGMENT DAY. 5G TECHNOLOGY IS  a judgment day.  And since we’re in  the judgment days, we aretherefore in TOTAL SELF‐ANNIHILATION.   600,000 Filipino hired contact tracers withapparent good salary grade offers, offering employment to Filipinos,   are  onthe way to track every Filipino of the Covid‐19 viruses while at the same time,the real viruses of mRNA injections  are injected to Filipinos.  Yesterday, a Filipino man, a senior citizen,aged 73, died, following Covid‐19 vaccine, and yet it is denied as related to  the vaccine, since accordingly, that person died only of heart attack.   To those who are not  vaccinated, be counted as the blessedremnants of the present (damned) civilization. You may  die, naturally ofcourse, but  better withoutvaccines,  and not participants of theglobal crimes, of lies and of  wickedness. Unvaccinated people are eternally blessed.   Eric V. Encina Filipino Freelance Writer/Author/Campaigner Filipino C.H. Douglas Social Crediter/MonetaryReformer Practical Christian For Life, Family, Justice,Peace & Reforms Quezon Province Email Addresses: eric_encina@yahoo.com, ericencina@protonmail.com      SUICIDES, VACCINES & THE JUDGMENT DAYS By Eric V. Encina More than 3,000 to 4,000 super-rich bunch of cold-blooded global elites of various races and colors, and their minions and wannabes all over the world, of tens to hundreds of trillions of dollars $$$ of assets, and of various ventures, of lines of expertise, and of philosophies of life, and absolutely with pestiferous spirits, in this damned planet earth, have, of points of NO return, and no probable recanting, unanimously, deviously, determinedly, with all their guts and wealth, totally marshalled onward and forward to indubitably, eccentrically, adroitly ANNIHILATE, “billions of people in this planet” (initially, 3 billion to kill in the span of 48 months’ time), likewise of various races, directly targeting the silly compliant, brainwashed and mind-conditioned poor and the ageing inhabitants and the entire unsuspecting public, of increasingly-made-goyim of all races, technically and technologically BY WAY OF THE STINGS OF SWAB TESTING, AND CERTAINLY BY WAY OF COVID-19 mRNA experimental injections or otherwise known as COVID-19 VACCINATION of extremely questionable poisonous ingredients with nano-technology insidious particles for monitoring and surveillance living or dead, along with the HIGHLY XENOBIOTIC, PULSE MODULATED MICRO-WAVE RADIATION OF 5G TECHNOLOGY, hence, that causes viruses because of radiation poisoning. Mysteriously, or, fortunately, or unfortunately, God is seemed to be in line with the EVIL PLANS or planned-demic schemes of the 3,000 to 4,000 super-rich bunch of cold-blooded global elites, not because they are good, but because GOD is also using them, and their pestiferous METHODS, to judge HUMANITY, the poor, and all others, since after all, MAJORITY OF THE POOR DO NOT ALSO LISTEN TO GOD, DO NOT OBEY HIS COMMANDMENTS, AND THEREFORE DO NOT DO HIS WILL. LIKEWISE, THE POOR DO NOT RECOGNIZE THE TRUTHS AND THE FACTS EVEN THERE ARE SIGNS THAT THEY SHOULD DO SO. So many poor Filipinos every day at increasing numbers, SOON AT AROUND 50 TO 70 MILLION FILIPINOS, apparently convinced, brainwashed and mind-conditioned and whatever reasons in the SUICIDAL MODES and while obsessed media guys are parroting and the heartless politicians, AND VACCINE SYNDICATES IN THE COVID-19 VACCINE ADDICTION, FOR THEIR EXPECTED PROTECTIONS from diseases here in the Philippines: multitudes of educated, and uneducated, very poor and middle classes citizens, religious and secular, working and non-working, retired and not-yet-retired, vagabonds and non-vagabonds, pensioners and non- pensioners, unfortunately, some are farming, of various walks of life, including those partially paralyzed or with comorbidities, are LINING UP mindlessly and thoughtlessly wearing face masks and face shields in fear and trembles in various places here in the Philippines of Covid-19 vaccine centers, now with the Covid-19 mega-vaccine centers in preparations, FOR COVID-19 VACCINATION. Strangely, even those who seriously suffered, and are suffering ADVERSE EFFECTS, they say, they don’t regret of having Covid-19 vaccine injections, and they still encourage others. That’s why I say, “VACCINATED PEOPLE ARE DAMNED PEOPLE”, also poisoning are LINING UP mindlesslv and thouahtlesslv wearing face masks and face shields in fear and trembles in various places here m the PhJ/womes of Cov,d-19 vaccine centers, now with the Cov,d-19 meaa-vaccme centers in oreoarations. FOR COVID-19 VACCINATION. Strangely, even those who seriously suffered, and are suffering ADVERSE EFFECTS, they say, they don't regret of having Covid-19 vaccine injections, and they still encourage others. That's why I say, "VACCINATED PEOPLE ARE DAMNED PEOPLE", also poisoning their brains other than tampering their DNA or genes, believing things of incredible lies, and persuading others to do the same as if WE ARE NOW VERY CLOSER TO ZOMBIENISM so soon. And even I think, of those who died of Covid-19 vaccines, their souls are certainly damned even their spirits promote the vaccines to the living. ONCE COVID-19 INJECTIONS are injected to HUMAN BODIES, SUCH PERSONS and thus their souls are therefore damned forever, the eternal suicide. Therefore, my deduction is that, WE’RE NOW IN THE JUDGMENT DAYS, though not yet final, but we see the meaning of “Matthew 25:31-46” – “The Sheep and the Goats”. THEY GIVE VACCINES, INSTEAD OF FOOD FOR THE HUNGRY, THE STARVING, AND FOR THE POOR. Now, the poor are also looking for vaccines instead of food. And remember, there’s “World to increasingly spend US$157 Billion on COVID-19 vaccines through 2025” – https://www.msn.com/en- ph/money/business/world-to-spend-dollar157-billion-on-covid-19-vaccines-through-2025/ar- BB1gbIFF?ocid=PanCafe&li=BB15QWvV, that accordingly, total global spending on coronavirus disease 2019 (COVID-19) vaccines is projected to reach $157 billion by 2025, driven by mass vaccination programs underway and “booster shots” expected every two years. In the Philippines, there’s PHP75BILLION (less than US$1 billion) as needed for expanded Covid-19 vaccination of Filipinos targeting 50-70 Million Filipinos including an anticipating additional expenditure of about PHP20 billion or to vaccinate approximately 15 million Filipino kids aged 12 to 17, till end of the year 2021 until next 2022 with the “foreign loans secured for its pandemic response had reached $18.4 billion as of last month, April 2021, after the state increased Philippine borrowings to plug its ballooning deficit that is 8.9% of gross domestic product this 2021. – their brains other than tampering their DNA or genes, believing things of incredible lies, and persuading others to do the same as if WE ARE NOW VERY CLOSER TO ZOMBIENISM so soon. And even I think, of those who died of Covid-19 vaccines, their souls are certainly damned even their spirits promote the vaccines to the living. ONCE COVID-19 INJECTIONS are injected to HUMAN BODIES, SUCH PERSONS and thus their souls are therefore damned forever, the eternal suicide. Therefore, my deduction is that, WE'RE NOW IN THE JUDGMENT DAYS, though not yet final, but we see the meaning of" US$157 Billion In the Philippines, there's https://www.msn.com/en- ph/money/business/p75b-needed-for- expanded-vaccination/ar- BB1gHjVJ?ocid=PanCafe&li=BB15QWvV We are in the judgment days by WAY OF COVID-19 PLANNED-DEMIC. COVID-19 PRC TESTING IS A JUDGMENT DAY, positive or negative, COVID-19 VACCINE IS A JUDGMENT DAY. 5G TECHNOLOGY IS a judgment day. And since we’re in the judgment days, we are therefore in TOTAL SELF-ANNIHILATION. 600,000 Filipino hired contact tracers with apparent good salary grade offers, offering employment to Filipinos, are on the way to track every Filipino of the Covid-19 viruses while at the same time, the real viruses of mRNA injections are injected to Filipinos. Yesterday, a Filipino man, a senior citizen, aged 73, died, following Covid-19 vaccine, and yet it is denied as related to vaccine, since accordingly, that person died only of heart attack. To those who are not vaccinated, be counted as the blessed remnants of the present (damned) civilization. You may die, naturally of course, but better without vaccines, and not participants of the global crimes, of lies and of wickedness. Unvaccinated people are eternally blessed. Eric V. Encina Filipino Freelance Writer/Author/Campaigner Filipino C.H. Douglas Social Crediter/Monetary Reformer Practical Christian For Life, Family, Justice, Peace & Reforms Quezon Province Email Addresses: eric_encina@yahoo.com, ericencina@protonmail.com We are in the judgment days by WAY OF COVID-19 PLANNED-DEM IC. COVID-19 PRC TESTING IS A JUDGMENT DAY, positive or negative, COVID-19 VACCINE IS A JUDGMENT DAY. SG TECHNOLOGY IS a judgment day. And since we're in the judgment days, we are therefore in TOTAL SELF-ANNIHILATION. 600,000 Filipino hired contact tracers with apparent good salary grade offers, offering employment to Filipinos, are on the way to track every Filipino of the Covid-19 viruses while at the same time, the real viruses of mRNA injections are injected to Filipinos. Yesterday, a Filipino man, a senior citizen, aged 73, died, following Covid-19 vaccine, and yet it is denied as related to vaccine, since accordingly, that person died only of heart attack. To those who are not vaccinated, be counted as the blessed remnants of the present (damned} civilization. You may die, naturally of course, but better without vaccines, and not participants of the global crimes, of lies and of wickedness. Unvaccinated people are eternally blessed. 6 Baumb, Nelly From:Allan Seid <allanseid734@gmail.com> Sent:Thursday, May 13, 2021 4:56 PM To:Channing House Bulletin Board; CHOpinion@googlegroups.com Subject:Fwd: BLM Attacking and Robbing Asians Attachments:VIDEO-2021-05-13-10-03-27.mp4 CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.      From: Allan SEID  Date: Thu, May 13, 2021   Subject: A BRUTAL ATTACK IN ATTEMPT TO ROB ASIAN COUPLE       N n~ --1 :I: -t-< -< May 12, 2021 ::r-c,O -< ,--n fT1'9 .:-;o► Al City of Palo Alto Re: Public Hearing regarding waste water charges and changes on 6/21/2021 ):a (/)0 ::x > o, '!? ...,_, :::!o U1 "n .r:-IT:► The purpose of the change according to the proposal is to ensure that each ratepayer pays only its share of the system costs. This is NOT achieved when residential households of low discharge pays the same FLAT rate as households that are high waste water users. Residential households should pay a quantity Charge based on $/CCF. lffor example, they have a discharge of 1 CCF then they should pay between 8.09 and 12.07. And if they discharge 5 CCF then 5 times the rate between 8.09 and 12.07. That will meet the purpose of ensuring each ratepayer pays its proportionate share. Thank you for your consideration of the above Sincerely, \ Winnie Lewis 352 Fulton Street Palo Alto, CA 94301 S 1 eivti-rf C · (<At A ~~1 J1 [ M.t •t L •/7:..~ ~tl.V° ~t r) * t n' J ell-'llf 3~, ~ fe e"'f' +4~ ,~ WA.fey a..:f~-L "t. Cr"~£. , May 10, 2021 KELLY GORDQN·COMPANY 12241 SARA TOGA--SUNNYV ALE ROAD SARA TOGA, CA 95070 N :J: > -< (.,.) " ::i: ('")~ ~-i -<-< c,O ,-n rrl-0 :::::,> ~r via al> -,, .. ,,-i .. N _c c,· r.,-n City Clerk 250 Hamilton Ave. Palo Alto, Ca. 94301 Re: Proposed Waste Water Rate Change ~tJv//)7' .3 "1> I $" ~ 7 t!) City Council Members : -' We are the owners of two office buildings located at 3240 & 3260 Hillview Ave. and do hereby submit this protest of the rate change for the following reason. Under the S-2 classification the rate would be determined by the amount of water used per month. At our locations we have only one water meter per building. The bulk of our water is utilized to water our landscaping. Landscape water does not enter the sewer system for processing. We request that some formula is established to take this condition into consideration . P/l~J Brian J. Kelly >