DEPARTMENT OF PLANNING AND DEVELOPMENT 723 West Markham Street Little Rock, Arkansas 72201-1334 Phone: (501) 371-4790 Fax: (501) 399-3435 STAFF REPORT ITEM NO. A. DATE: APPLICANT: November 9, 2015 Jimmy Moses, Moses Tucker ADDRESS: 307 and 315 East Capitol Avenue COA REQUEST: Exterior renovations and signage PROJECT BACKGROUND AND DESCRIPTION: The subject property is located at 307 (311) and 315 East Capitol Avenue. The property’s legal description for 307 East Capitol is The E54.46' Of Lots 1,2 & 3 Blk 40 Replatted as Lot 1r Block 40 together with 1125 sq ft Closed Alley Lying Al Eln thereof per 2015-045361 Of The Original City of Little Rock, Pulaski County, Arkansas. The property’s legal description for 315 East Capitol is The N40' Of Lot 8 & All Of Lots 9 & 10 & The W75' Of Lots 11 & 12 Blk 40 together with 1792.5 Sq Ft Closed Alley Lying Al Wln thereof per 2015-045361 of the Original City of Little Rock, Pulaski County, Arkansas. The building at 307 East Capitol is known as the Paragon Printing building and is a contributing structure to the district. It was built in 1947 and expanded shortly Location of Project thereafter. The survey notes “International Style with floor to ceiling glass façade and large expanse of blank windowless walls. The building at 315 East Capitol Avenue is known as the MM Eberts American Legion Post and is not a contributing structure in the district. It was built around 1968. The survey notes “Commercial building with international style influences, including flat roof, simple geometric shapes and large grouped window and door opening.” This application is for both buildings for exterior renovations and signage. The Paragon Building is proposed to house a German beer hall and restaurant with outdoor seating on both sides of the building. The beer garden to the west will be 18’ wide for almost the entire length of the building. The beer garden on the east will be the width of the alley and as deep as the American Legion Building. The American Legion Building will be utilized as a restaurant, bar, and boutique bowling alley. Page 1 of 16 PREVIOUS ACTIONS ON THIS SITE: No previous actions were on this site were located with a search of the files on either property. American Legion Building north elevation 2006 Paragon Building north elevation 2006 PROPOSAL AND WRITTEN ANALYSIS OF THE APPLICATION BASED OFF OF INTENT AND GUIDELINES: On page 41 of the current Guidelines, they state: Buildings, which are designated as “contributing” to a National Register Historic District, or “significant” as a National Register Historic Place will be held to a higher standard than “noncontributing” structures. The HDC will consider the designation when it evaluates rehabilitation proposals. Contributing and Non-contributing map On page 44 of the current Guidelines under doors, they state: Original doors and/or their entranceway surrounds, sidelights, transoms, and detailing should not be removed or changed. Replacement of missing original doors should be like or very similar to the original in style, materials, glazing (glass area), and lights (glass pane configuration.) Doors should not be added to the primary façade or to a secondary façade where readily visible from the street. If doors are added to an inconspicuous secondary or rear wall, they should be similar to the original doors. On page 49 on the current Guidelines under Masonry, they state: Brick should not be painted unless it is extremely mismatched from earlier alterations or cannot withstand weather. On page 58 of the current Guidelines under Fences, they state: Page 2 of 16 Fencing material should be appropriate to the style and period of the building. Cast iron fences were common through the Victorian period and should be retained and maintained. Wrought iron and bent wire fences are also historic. Fences may be located in front, side, or rear yards, generally following property lines. Fences with street frontage should be no taller than three feet (36”) tall. On wood fences, pickets should be no wider than four inches (4”) and set no farther apart than three inches (3“). The design shall be compatible with and proportionate to the building. For larger scale properties, fence heights should be appropriate to the scale of the building and grounds. On page 60 of the current Guidelines under Lighting, they state: Original lights should be preserved. If fixtures are added, they should be from the period of the structure, or if new, simple in design, based on traditional designs of the early twentieth century. They should be mounted on porch ceilings or on the exterior wall adjacent to the primary entrance. Fixtures to avoid are carriage lamps or any fixtures evocative of a period earlier than the building. On page 63 of the current Guidelines under signage, they state: Signs should be subordinate to the architecture and overall character throughout the district. Historic signs should be preserved, including “ghost” signs on the sides of buildings. 1. Attached to Building: Signs attached to a building should not cover or obscure architectural features. Signs may be painted on windows, doors, or small panels at entrances or on awnings. Small signs may be flush-mounted on a building wall; may be hung on porches between posts; or may project from the structure. A sign on a masonry wall should be mounted in the mortar, not the masonry. 3. Materials for signs: Materials used for signs should be traditional, such as finished wood, glass, copper, or bronze, not plywood, plastic, unfinished wood, neon or other internally lighted materials, or flashing lights. Materials should be compatible with the building materials. 4. Design of signs: The design of the signs should be appropriate to the building, in size, lettering, and style. Business logos or symbols are desirable. If several businesses share a building, coordinate the signs. Flashing, rotating, moveable, or portable signs should not be used. 5. Lighting of signs: Lighting of signs should be from remote sources, preferably from the ground aimed directly at the sign and shielded from street view. Lighting should not use visible bulbs, internal sources or luminous paint. The Guidelines do not state a size for wall signs. The UU zoning provides for Institutional and Office zone signage regulations (36-553). That code is stated below: Page 3 of 16 Sec. 36-553 Signs permitted in institutional and office zones (a) The following signs are permitted in institutional and office zones: (1) All signs as permitted in sections 36-550 through 36-552. (2) One (1) freestanding sign per premises, not to exceed two (2) square feet in sign area for each linear foot of main street frontage up to a maximum of sixty-four (64) square feet. Such sign may not exceed a height of six (6) feet. In addition to the above freestanding sign, the owner may use one (1) of the following: a. Wall or mansard signs not to exceed ten (10) percent in aggregate sign area for that occupancy's facade area. b. One (1) under-canopy or projecting sign per occupancy, not to exceed twelve (12) square feet in sign area. (3) Where a building is on a corner or has more than one (1) main street frontage, one (1) wall sign and one (1) additional freestanding sign will be allowed on the additional frontage, not to exceed the size of other wall and freestanding signs. (b) All freestanding, projecting, and under-canopy signs shall have a minimum setback of five (5) feet from any property line and vehicular public right-of-way, measured from the closest edge of the sign, and a minimum clearance of thirteen (13) feet over any vehicular use area and nine (9) feet over any pedestrian use area. Illumination is allowed but not greater than two hundred (200) footlamberts of luminance. This Staff report will be broken down into two portions, one for each of the buildings. THE PARAGON BUILDING: The Paragon building, at 307 East Capitol, is a two story building in the “Structural Expressionist” architectural style. Simply stated, the structural members of the building are expressed in the building, namely the white columns and pilasters on the front corners and along the sides of the building. Mason Toms, Arkansas Historic Preservation Program, stated that this building may be the work of Dietrich Neyland. Mr. Neyland was brought to Arkansas to work in the Cromwell office in the 1950s. He liked the red with white accents color scheme in his buildings. One of his works locally is the KATV building on Ringo Street. The Cromwell archive is currently being digitized at Arkansas Studies Institute but it not available to the public at this time to confirm if this is or is not one of his works. The front of the building features a structural member frame in white that encases the building on the sides and top. The structural member appears to be stucco over metal lathe and that member extends inwards to become the soffit of the building over the entrance. The center portion of the front façade has a third type of brick, a more decorative brick with rounded edges that is red in color. The mortar has been dyed to match the brick. Mr. Toms stated that this front façade brick may be a “dipped brick”, where brick was dipped in paint before installation to achieve a uniformity in color that was unavailable from firing bricks alone. The balance of the façade is a two story glass storefront floor to ceiling windows and one door on the east side. The contrast of the red brick, red mortar and the white structural members provides architectural interest in this building along with the massing of the large rectangles of glass and decorative brick. Page 4 of 16 The side facades are broken into seven bays with the white structural members extending from the ground to the top of the parapet wall. The eastern façade has evidence of windows that have been bricked over. There were four large windows and one small window. There is an existing overhead door in the sixth bay. The seven bays on the east side are not a regular width as the bays on the west side are. The steel frame windows are still in place in the building, the brick was added to the exterior sill. The western façade of the building has seven bays with the first bay closest to Capitol Avenue having some of the two story floor to ceiling glass storefront windows. The brick on the sides of the building are not the same as the brick on the front. Part of the eastern wall nearest to Capitol Avenue is a buff brick that has been painted. The western wall appears to be the same brick as the balance of the eastern wall, a smooth red brick. The wall has been painted a similar color of red as the brick. A ghost sign appears on the western wall but is unintelligible. The Paragon Building Existing North Facade 2015 Page 5 of 16 The Paragon Building Proposed North Facade The proposal for the front of the building would keep the following items: 1. The white concrete structural members would be cleaned and repainted white. 2. The existing storefront windows on the west side would be repaired as needed or replaced to match the existing. The proposal for the front of the building would change the following items: 3. The single aluminum storefront door would be replaced with two wood doors. 4. A 2’ x 7’ stained and painted carved wood sign would be placed over the new wood doors. 5. A 12” thick wood awning with recessed lights in the soffit would be added over the front doors at the level of the beam between the first and second floor. 6. The red brick panel in The Paragon Building Existing West Façade 2015 the center of the building and the brick to the east of the front door would be painted gray. Page 6 of 16 7. A perforated metal screen would be added to the building in front of the brick panel. It would be blue in color and have a diamond pattern with cutouts. 8. A sign, 3’ x 25’ would be painted on the brick, beside of the diamond screen with the words “Fassler Hall”. This sign would be painted in white on the grey background. 9. There would be a fence added to the west side of the building placed on a wood slat base. The fence and base would be 8’ tall. The fence would be a decorative metal fence in a midcentury motif. 10. There would also be a gate installed in the alley on the east side of the building in the decorative mid-century motif. It would not have a wood slat base. The proposal for the west side of the building would keep the following items: 11. The white concrete structural members would be cleaned and repainted white. 12. The existing storefront windows on the west side would be repaired as needed or replaced to match the existing. The Paragon Building Proposed West Façade The west side of the building would have the following changes. 13. The brick would be painted gray. 14. There would be a painted logo on the wall near Capitol Avenue in the first bay of 42 square feet with the diamond blue background with a griffin. 15. Bays two, three, and four would feature glass front overhead doors centered in the bays (number one being closest to Capitol Avenue). The doors are 10’ x 10’. Page 7 of 16 16. A wood awning is above the overhead doors with 8” letters on the awning. “Sausage, Beer, and Live Music” are considered informational signage per the sign ordinance. 17. A proposed sign of 120 square feet sign (6’ x 20’) is proposed to be painted on the second floor of the building. (The dimensions of this sign are not correct, the building is approximately 150 feet long, the seven bays are approximately 22 feet long each, therefore the sign is The Paragon Building Existing East Façade 2015 approximately 60 feet long and from 6-13 feet high for an area of 540 feet.) 18. 14 new light fixtures will be installed on the building, two per bay. They will be Wheeler Dino Wall Sconce in yellow. They are commercial grade steel with a high gloss porcelain enamel finish. The projection from the building will be 15” or less. 19. The same decorative fence that will be on the front of the building will be extended down the west façade to enclose the outdoor dining and drinking area. 20. The southernmost bays (five through seven) will have the diamond patterned artwork painted on the brick. The Paragon Building Proposed East Façade The proposal for the east side of the building would keep the following items: 21. The white concrete structural members would be cleaned and repainted white. The east side of the building would have the following changes: 22. The brick would be painted gray. Page 8 of 16 23. Replace the existing overhead door with a 10’ x 10’ glass overhead door. 24. Install three additional 10’ x 10’ glass overhead doors in bays two, three and four (number one being closest to Capitol Avenue.) 25. Install 13 wall sconces as described above. 26. The northernmost bays (one through three) will have the diamond patterned artwork painted on the brick. 27. There is proposed to have a fence at the midpoint of the alley at the rear of the American Legion Building. The Paragon Building was deemed contributing in the last nomination of the district and it should be held to a higher standard than non-contributing ones per the Guidelines. Currently, the building has a single front door in an aluminum storefront system. Changing this to two wooden doors could be reversible in the future. The large panels has four vertical panes of glass now, replacing parts of the two center ones with doors could be appropriate for additional entry and exit from the building. More appropriate doors would be two glass aluminum doors that match the existing door. In light of the additional information from AHPP, Staff is concerned on the removing or covering of original architectural details. In this Structural Expressionist building, the three elements are the white structural members, the rectangular masses of brick and the two-story glass storefront windows. AHPP believes that the mortar was dyed and matched to the brick and that this front façade brick has never been painted. Evidence of paint on the mortar joints is not there. The guidelines state on page 49 that unpainted masonry should not be painted. The sign on the front façade of the building could be installed as metal individual cut letters mounted into the brick as the decorative screen is proposed to be. A different color combination could be used if the red/blue was not found suitable. The sign is quite large and measures differently than labeled. The zoning ordinance states that signs must be less than 10% of the façade. This sign appears to be almost at that maximum. On the east and west façade, it has been painted previously and further painting on these two facades will not diminish the contributing status of the building. Cutting six additional overhead doors into the building may make the building non-contributing in the next survey. Ralph Wilcox, in an email date November 2, 2015, stated “I believe that if the building is renovated and the garage doors are put into the building as proposed, that the project will make the building non-contributing.” Mid Century modern buildings are unique to the district. The guidelines state that fences with street frontages should be 36” tall. The requested fence is 8’ tall. Staff feels that the 8’ tall fence (wood slats and metal decorative fence combined) is too tall to be appropriate. The Guidelines state that fences should be designed with an appropriate style to the building and may be taller with larger scale properties. This is not a larger scale property but the use of a beer garden may prompt a taller fence of four feet total. Other restaurants that serve food an alcohol downtown have three foot fences. The lighting section of the Guidelines reference buildings that were built in the early part of the 20th century or late 19th century. These mid twentieth century buildings should have appropriate fixtures for their time frame. Staff believes that the proposed light fixtures are of an appropriate design for the buildings. Page 9 of 16 The sign on the front façade of the building measures almost six feet wide by twenty five feet tall. As proposed, the painted sign would be appropriate if the painting of the brick wall behind was appropriate. However, a metal sign with individual cut letters could be appropriate if they were attached into the mortar and stood away from the brick surface. No mention of lighting of the sign was made in the application. The sign on the west wall would be appropriate for materials, but may still be oversized at approximately 540 square feet based on the elevation provided. The size noted is incorrect. It will need to be reviewed by the Board of Adjustment since it does not have street frontage. The logo without words on it (diamond shield with griffin) may not be considered a sign. It is 42 square feet. The sign, Fassler Hall, is a sign without street frontage. This sign will require to be reviewed by the Board of Adjustment. Sec. 36-557 (a) All on-premises wall signs must face required street frontage except in complexes where a sign without street frontage would be the only means of identification for a tenant. THE MM EBERTS AMERICAN LEGION BUILDING: The MM Eberts American Legion building is a one story brick building with an entry door and sidelights on the eastern end of the front façade. The front façade is characterized by a raised planter on the western end. The doorway has a ramp leading to it that is entered near the center of the front façade and the retaining wall for the landing and an additional planter is in line with the planter on the west. A decorative cap of brick is a decorative element on the planter and retaining wall. This wall is roughly the height of the finished floor inside. The MM Eberts American Legion Building is not a particularly unique building. Some buildings are of a character that implies that they will be on the contributing list eventually, but this is probably not the case of this building. The American Legion Building Existing North Façade 2015 Page 10 of 16 The American Legion Proposed North Façade The front facade of the building would have the following changes: 1. The brick would be painted gray. There will be accents of orange at the top of the planter wall and green triangles on the western edge of the front façade. 2. The existing storefront entry would be replaced with an overhead door to fit the opening. 3. A new painted welded metal railing would be added on top of the planter wall. 4. The entry ramp would be changed in slope and direction so that the entrance would be on the eastern edge of the building. The planter wall/retaining wall would be cut on the eastern edge and filled in the center. The planter on the western edge would be shortened. 5. A new entrance would be cut into the wall near the western end of the building with two wood doors installed. Doors would be 3’ x 7’ tall. 6. A 3’-0” x 9’-4” storefront window will be added to the center of the building. 7. There is to be a new awning (canopy) over the ramp to the entrance that will be 12” thick and as wide as the distance from the building to the property line. It is to be lined with stained wood soffit and wall paneling. The green edge is to be hard plastic and internally lighted. The soffit is to contain recessed lighting. 8. Above the new double wood doors, an 8’-8” tall vertical wall panel will be installed with corrugated metal face. The sides and top will be green hard plastic and internally lighted. 9. A 2’ tall corrugated parapet will be added atop the wall. 10. 3 light fixtures will be added to the front façade. They will be the same as the other building. They will be Wheeler Dino Wall Sconce in yellow. They are commercial grade steel with a high gloss porcelain enamel finish. The projection from the building will be 15” or less. 11. There would be four signs on the front façade. The first would be the words “Dust Bowl” mounted upright on the fixed awning at the eastern end. In the center of the building, a 3’ x 7’ wall mounted sign will have the text “Dust Bowl lanes and lounge”. On the western edge of the front façade, there will be a neon sign 8’ in diameter that will feature a bowling pin with the words Dust Bowl with a circular motif behind it. The last sign is to be mounted on the existing flagpole that is not dimensioned. Page 11 of 16 The west elevation is a windowless elevation with the north portion of the building overhanging the foundation by about 24 inches. Underneath the overhang are fluorescent tube lights. The American Legion Building 2015 Existing West Façade The American Legion Proposed West Façade The west façade of the building would have the following changes: 12. The brick would be painted gray with green triangles on the north end by Capitol Avenue. A decorative graphic (mural) of a bowling ball and pins would be on the building for the majority of the length of the building. 13. Two glass overhead doors, 10’ x 9’-4”, would be cut into the west façade. They would have painted welded metal railings in front of the overhead doors. (These doors are not at the grade of the alley.) 14. Six additional wall sconces, described above, would be added to the façade. 15. The rear doors with the storefront entry would remain. 16. The graphic of the bowling ball moving toward the pin is a sign without street frontage. This sign will require to be reviewed by the Board of Adjustment. Sec. 36-557 (a) All on-premises wall signs must face required street frontage except in complexes where a sign without street frontage would be the only means of identification for a tenant. Page 12 of 16 17. Drawings have not been submitted for the east or south façade of the building. assumed by staff that it will be painted grey to match the remainder of the building. It is The MM Eberts American Legion building is non-contributing to the district as of the last nomination. The American Legion building was built with the one door with sidelights. The guidelines state that additional doors should not be added to the primary façade. With this being a noncontributing building, this could be an appropriate change. The guidelines state that brick that has not been painted before should not be painted. This brick appears to be able to withstand weather and is not mismatched. When the planter wall is cut and infilled, it may not be possible to reuse the brick or match it with new brick. Later mortar is more difficult to remove from brick in an effort to reuse them. Currently, the proposal is to paint both buildings gray. With the Paragon building front façade recommended to be left unpainted, and it is desired for both buildings to match, then a suggestion would be to paint the Eberts building to match the Paragon Building. Reutilizing the existing brick to fill voids in the planter wall would be the best solution and not requiring the brick to be painted. There is a fence proposed to be in the former alley area between the two buildings. This would be a gate in all probability. The guidelines state that fences with street frontages should be 36” tall. The requested fence is 8’ tall. Staff feels that the 8’ tall fence (wood slats and metal decorative fence combined) is too tall to be appropriate. The Guidelines state that fences should be designed with an appropriate style to the building and may be taller with larger scale properties. This is not a larger scale property but the use of a beer garden may prompt a taller fence of four feet total. Other restaurants that serve food an alcohol downtown have three foot fences. The lighting section of the Guidelines reference buildings that were built in the early part of the 20th century or late 19th century. These mid twentieth century buildings should have appropriate fixtures for their time frame. Staff believes that the proposed light fixtures are of an appropriate design for the buildings. The proposal is for four signs on the front of the building. From the left (east side), the first is the 2’ tall metal letters mounted to the top of the canopy. This would be about 24 square feet. The second is a wall sign noted to be 3’x7 but scales approximately 16’x5' for 80 square feet. The third, a wall sign with the bowing pin on it, is labeled 8’ in diameter for about 70 square feet. The last sign is on the existing flagpole. Proposed Wall sconce for both buildings This zoning ordinance for this UU zoned land states that freestanding signs (the sign on the flagpole) my not to exceed six feet in height, including pole. This sign is clearly taller than six feet. Staff feels that four signs on this façade is too much signage. Staff believes that the two Page 13 of 16 signs on opposite ends of the building (the large neon wall sign and the metal sign on top of the canopy) would be sufficient. SUMMARY In conclusion, concerning the Paragon Building, the guidelines state that Contributing buildings will be held to a higher standard than those that are non-contributing. More appropriate doors would be two glass aluminum doors that match the existing door although the wood doors are a reversible change. The guidelines state that unpainted brick should not be painted. The signage could be executed in a manner similar to the metal screen and still achieve as similar desired look. The signage would be large, if not the largest permanent sign in the district if approved. Cutting an additional six overhead doors into the building could make the building non-contributing, but is a reversible alteration. The guidelines state that fences with street frontages should be 36” tall and the requested fence is more than twice that tall. Concerning the American Legion Building, it is a non-contributing building and is not held to the high standard of contributing buildings. Adding additional doors could be an appropriate change with this non-contributing status. The guidelines state that unpainted brick should not be painted. With the Paragon building front façade recommended to be left unpainted, and it is desired for both buildings to match, then a suggestion would be to paint the Eberts building to match the Paragon Building. The guidelines state that fences with street frontages should be 36” tall and the requested fence is more than twice that tall. Four signs may be too many for the building. NEIGHBORHOOD COMMENTS AND REACTION: At the time of distribution, there were no comments regarding this application. STAFF RECOMMENDATION: Approval with the following conditions: 1. Obtaining building permit for each property. 2. Paragon Building: a. Do not paint brick on front (north) façade, b. Sign on front (north) façade to be individual cut metal letters mounted into the mortar joints. c. Reduce size of sign on front (north) façade by 25%. d. Reduce height of fence to 4’ including wood slats. e. Sign on West façade to be reviewed by BOA. 3. American Legion Building a. Reduce height of all fences to 4’. b. Reduce number of signs to two. Remove sign on flagpole and smaller wall mounted sign. Page 14 of 16 I It IC )Ck DEPARTMENT OF PLANNING AND DEVELOPMENT 1. . 723 West Markham Street Utde Rock. Arkansas 72201-l 334 Phone. 371-4790 Fax: (501) 399-3435 'li, .I: APPLICATION FOR A CERTIFICATE OF APPROPRIATENESS . Application Date: wok?" 2019 DatoofPubllc Hearing: atsm pm. wmamm; 3 e-cA?yw so?- Gamma. .LegaleOplionotPropeny: Dof?km mg ?um 16? .4 Lb. [IL-gum: 4o- oacmML 5. PropatyOwrm(Prlmod Nam. Address. Phone. Email): [8th mat-66:14! 7c Mam Tucwt- Loo mac Mute] Aw bso- vf M. wne?- -- .. La a. mum: (Printed Name. Address. Phone. Emu): GAMES A. zoo Rum WKET Ave. LATTLG ROLL ML. ?tum - 7. To 2 fountain. 7 or) WITDL, ?b BM. Wren Lugs. 8. EstimatedCoetot Improvements: 2.60 000 9. angeapetmn?lme? No 10.859naturoof0wnecaAoem: A, . NOTE: 5mm be charges mm mm (W. mandate. size. ac.) tram tho unmoved 00A. We Rock Hisiodc Diana Commission Action Sta? Signature: Date: Revised 812012 Application Page 15 of 16 MOSES TUCKER Mr. Brian Mlnyard October 8, 2015 MacArthur Part Historic District 700 W. Markham Uttieitock. Ar. 72201 RE: Certi?cate of Appropriateness?307 315 East Capitol Avenue Dear Brian. Please ?nd attached our request for the Historic Commission consideration oiour plans to make exterior improvements to two properties, the MM Eberts Leglon Post mum its neighbor immediatelytothewest,the Paragon tegionilow apartmentsinthe situatedandwearenowina positiontoreview plans for these commercial structures The Legion Building will be utilized as a restaurant/bar and boutique bowlir? aley. while the Paragon Building will be renovated and operated as a German beer hail [restaurant Outdoor seating is planned on eithersideofthe Paragon. Architects ls serving as the project architect for both renovations and our company represents both property owners. We think these restaurants will be a quality addition to the MacArthur Park and River Market District neighborhoods and hope the Commission will be willing to support our plans. Sincerely. KM CC: Graham Rich, Central Ar. Water Jamie Moses tunmmilal Balm-p- . New 0 Darla-rm"! 1 amullnm 2le Rover Marin Aw .Svule it: 0 Little Ink. Arkansas - Phone WI "60555 'u 5m WOW I um! rum-what]! ul?t Cover Letter Page16of16