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Western Schools Task Force Report 19 December 2007

Background
On 6 February 2007 the Board of Supervisors initiated a Western Schools Task Force. The idea for such a Task Force emerged out of the HS-3 site debate. The HS-3 site debate was extremely emotional, dividing members of both Boards, elected officials of the different Towns, citizens, and even family members. The rancour of that debate indicated the need for greater dialogue between the various stakeholders and a forum in which that dialogue might take place. According to the original proposal,1 the Board formed the Task Force to provide a forum for dialogue, to discuss the School Boards future strategy for meeting Western Loudouns school needs, and to explore alternative strategies for Western school growth and site selection. The proposal suggested a list of possible issues for discussion and examination, including: School Size: size vs. cost debate, cluster-school size symmetry School Design: cookie cutter, site-specific design, design-build, etc. Clustering: standard clustering, no clustering, clustering plus specialty schools Year-Round Schooling Interim solutions for the overcrowding of Loudoun Valley, Harmony, & Blue Ridge during the 2007-2008 school year and, if necessary, during the 2008-2009 school year. Preferred Locations: in what general geographic areas should schools be sited; what criteria should the School Board use for site selection; review current policies and standards for school siting; etc.

Task Force members included two representatives from the Board of Supervisors, the School Board, the Mayors of the incorporated Towns, and three members of the public.2 A list of members can also be found in Appendix 1.

1 2

See Appendix 1 The three citizens representatives were selected by the Board of Supervisors, the School Board, and the Coalition of Loudoun Towns (COLT), respectively. 1

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Meetings
March
The Task Force held its first meeting on March 14, 2007.3 The focus of that meeting was information gathering. School Board Chairman Robert DuPree led two discussions: (1) the roles and responsibilities assigned to the local School Board by State code and case law; and (2) a summary of the School Boards 2004 analysis on school size and construction. Afterwards, members of the Task Force received a variety reports prepared by citizens on the subject of Western schools.

Key Takeaways
Legal Authority o Under Virginia Code, Constitution, and case law, the School Board is the sole decision-making authority for school site selection. o The School Board must comply with local Zoning Ordinances. o The Board of Supervisors has no control over how the School Board spends its budget, only the amount of the lump sum to be allocated to the School Board. 2004 School School Size and Construction Study o Study generated by concerns among new Board members (Supervisors and School Board) about the cost of schools. Such exercises seemingly repeated by each new Board. o Items Considered: School Size, both in terms of square footage and students Campus and Building Designs Building Materials Private-Public Partnerships Additions and Renovations to Existing Buildings Trailers Optimal utilization and capacity o Conclusions A majority of the School Board felt small class sizes more important than small school buildings. This led to a decision to increase building sizes, while making further efforts to decrease classroom populations. While high schools were already being built with a second story, the School Board decided to develop two-story middle and elementary school prototypes. However, second story only reduces necessary acreage requirement 1 acre for an elementary school and 2-3 acres for middle and high schools. Campus size could only be shrunk by eliminating community and extra-curricular activities.

Copies of each meetings Agendas, Meeting Summaries, and Hand-Outs can be found in Appendices 3-9. 2

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7/27/2011 The School Board reaffirmed its support for the use of building prototypes as the best means to save money in construction costs. The School Board reaffirmed its preference to limit the use of trailers. With regards to additions, renovations, and private-public partnerships the School Board decided it would look at each circumstance individually.

April
The April Task Force meeting began with a presentation on the Countys Capital Planning Process by County Deputy CFO, Ben Mays. Afterwards, the Task Force focused on finalizing its scope of study, determining its approach to the material, and the structure of its meetings. The members agreed to meet monthly on the fourth Wednesday of each month at 6:30 pm. They also agreed that they would prefer to consider each issue as a group rather than to break up into smaller groups and each pursuing one issue in depth. The members also adjusted the Task Force scope as follows [items in italics were additions or amendments to the original scope proposed]: School Size To be the subject of the May meeting with the 1999 Rural Loudoun School Study Committee Report as the starting point for the discussion School design: cookie cutter, site-specific design, design-build, green building, etc. East-West philosophy, politics Facility sharing Site selection process: limitations (e.g., condemnation); communications policy; criteria (what criteria should the School Board use for site selection; review current policies and standards for siting of school; etc.) Preferred locations: in what general geographic areas should future schools be located; consistency with (or changes needed to) County and Town Comprehensive Plans Interim solutions for the overcrowding of Loudoun Valley, Harmony, & Blue Ridge during the 2007-2008 school year and, if necessary, during the 2008-2009 school year

Based on research by Supervisor Kurtz, year-round schooling requires too much prior planning to serve as an interim solution. Given the level of required planning, the Task Force decided not to pursue the issue without an upfront expression of support and interest by the School Board.

Other Key Takeaways

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Current financial planning documents call for two more elementary schools, one additional middle school, and one additional high school in the West by 2018. The middle school and one of those elementary schools are planned for the Grubb property. While the Task Force can discuss these schools and make recommendations, it should not expect to derail projects already underway. The 1999 Rural Loudoun School Study Committee Report captures many of the concerns still felt by Western Loudoun residents. However, the political reality is most School Board members live in the East. The Task Force needs to address how to market its recommendations to the Eastern School Board members and their constituents, in particular, how to fiscally justify treating the West differently from the East. School size impacts competition schedule. o Loudoun Valley competes as a AAA school, because it includes all the freshmen at Harmony in its activities. Other Loudoun HS compete at AA. Thus, LVHS students do not compete against other Loudoun County schools; have to travel out-of-county o Too small a school, however, and not able to win at state levels. School size impacts academic programmes AP classes require a minimum of 1500-1800 student schools.

May
No meeting held.

June
The Task Force focused its attention on issues of school size. Blue Ridge School Board member, Priscilla Godfrey, provided an overview of the history of changes in school size. Nancy Doane, who chaired the 1999 Rural Loudoun School Study Committee, summarized the committees findings and recommendations and answered questions from the Task Force.

Key Takeaways
History of Changes in School Size o High schools have increased in capacity from 1350 to 1400 to 1600 to 1800. The last increase in size to 1800 was a response to the concerns expressed by the Board of Supervisors in 2004 regarding the cost of new school construction. In an attempt to be sensitive to the Western community and environment, HS-3 will be 1600. However, HS-10 is likely to be 1800 based on the planned sizes for MS-10 and Culbert ES. HS-3 is planned to last until 2017.

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o Campus needs have increased as well, primarily due to the increase in interscholastic sports programs Currently, 13 varsity sports programs, the majority of which require outdoor fields Title IX requirements for equal support of mens and womens sports has helped to drive those increases. o The number of classrooms needed has also increased. Desire for smaller class sizes Increases in the number of Special Needs classes offered, which require smaller rooms. o 1800 is the cap on core facilities. o According to research collected by school statistician, higher socioeconomic demographics can sustain bigger schools without a negative impact on education. o School Board plans for schools reactively. Developers proffer school sites based on what they are told the School Board requires at the time of their application. Summary of 1999 Rural Loudoun School Study Committee Report o Most recommendations still unimplemented despite every School Board candidate in 2000 endorsing the committees report. Same issues being rehashed today. o Recommendations: Communities coalesce around high schools. Therefore, clusters should be in place from the beginning so that students know what high school they will be attending from the day they enter Kindergarten. School growth policy and planning should accommodate that. School planning should be highly transparent and strongly community-based. While there have been changes in the cluster / boundary process, things are still not as transparent as the committee would have liked. School Board should experiment with RFPs for land acquisition. The lower levels of density in the West lead to longer bus commutes. The committee recommended 3 ES classrooms per grade (expandable to 4, as needed) a 600-student elementary school. Class size was very important to the committee. 1:22 teacher-student ratio desired. Elementary schools should be sized so that a principal could know the name and face of every student. High schools and middle schools should be placed on adjacent parcels with co-location of other County facilities (e.g., libraries, public safety) and shared parking.

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7/27/2011 While prototype schools provide many benefits, the Committee believed that the existing prototype might need to be adjusted or replaced.

Discussion o Task Force should just sign its name to the 1999 study. o The current joint BOS-School Board Standing Committee only meets as necessary, usually when there is a crisis, focuses only on fiscal issues. The next Boards should institute a committee that meets monthly and expands its scope beyond simply fiscal issues. o The challenge for the School Board is to identify today where the communities will be in the future, buy the relevant properties, and then landbank them. o BOS can buy land, but they cannot force the School Board to use it for a school. o RFPs might eliminate the need for condemnation and secrecy. o Elementary schools serve a dual purpose as academic centers and community centers. o Using 2006 Western zoning ordinance amendments, school staff now calculate that Western Loudoun at build-out will require in addition to Woodgrove High School and Culbert Elementary School 12 additional schools: 8 Elementary Sschools 1.5-2 Middle Schools 1.5-2 High Schools

Questions Raised
What are the bottom-line campus requirements when the required acreage is not available? Is the current planning process for clusters working in terms of matching up schools to available sites? Health Care CPAM is an example of long-term planning for specific facilities. Why cant we have a build-out plan for schools with trigger points for particular clusters? Does the current condemnation policy need to be revisited? Instead of using letters (like in PUGAMP) to identify planned schools, why not set different radii around the Towns for where schools will go (i.e., a high school will be located within x-miles of this Town, a middle school within y-miles, etc.)? Or would this be too general and lead to future misunderstandings?

July
Based on the discussion at the June meeting, the July meeting revolved around a discussion of criteria for school site selection and what type of planning process the Task Force might want to undertake. Staff from the Research Unit of the Countys Financial
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and Management Services Department provided population projections for Western Loudoun.

Key Takeaways
Rural Policy Area Total Build-Out (not including Towns and JLMAs): 18,337 o Route 7 will continue to be focus of growth; Lovettsville, Lucketts also growth centers. o Development of half that potential would require two additional clusters, HS-10 plus one more. o Unclear whether HS-5 is intended to absorb all of the development around Lucketts or whether Western clusters will absorb the increases in density in the Northern Route 15 sub-area. Planning Process o Time Horizon: focus on the first ten years, then continue outwards with 10 year increments o Alternative scenarios: slow development, fast-track build-out, changes in water availability, etc. o Use overlays to define constraints. o Specificity Being site specific on a map is too precise Decide how many schools should go to a Town and get those reservations in place Pre-define attendance and cluster boundaries Site Criteria o Basic issue is whether or not to affirm the current Comprehensive Plan which recommends that schools be built in or near existing population centers. o Need to integrate or coordinate County and Town plans, ordinances, and facility standards o Have to consider utilities, transportation, road network and other variables. o Financial burdens placed on Towns to plan for a facility that doesnt get built. o Avoid weighting. Utility Planning o Receiving streams a key factor. o Chesapeake Bay mandates also now need to be taken into consideration an unfunded mandate on water and sewer providers o Continuing dialogue over a regional cooperative system between the Towns o Greenfield schools also impact Town water supply through drawdown on aquifer, especially in a drought. o Current State law allows every landowner to put a straw(s) into the aquifer and draw down, no matter what the impact on neighbors.

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August
The Task Force continued its discussion of Site Selection criteria at this meeting. At the July meeting a smaller sub-group had agreed to collect and evaluate past suggestions for criteria. School staff provided a comprehensive list derived from a past consideration of criteria needed to evaluate site bids if the School Board were ever to issue an RFP for sites. The Task Force also discussed a meeting held earlier that week in Lovettsville at which School staff presented a proposal for a Lovettsville-area high school.

Key Takeaways
The idea of an RFP for properties continues to make sense. Criteria o Appropriate criteria includes proximity to population growth, proximity to population centers, length of bus ride, acreage and topography, access to roads and trails, availability of support facilities and infrastructure, neighboring land uses, compatibility with Town plan(s). o However, such criteria need to be better defined: What is a population center? What is an acceptable bus ride length? Accessibility to what kind of roads? Any roads, a major corridor? What types of support facilities? Are some support facilities required and others merely optional? o With large lots disappearing and 5-acre zoning instituted in the areas with the largest growth, need to review current condemnation policy. o Willingness to compromise on building and campus design, facility requirements, etc. key to working with the criteria. Currently, the prototype trumps all of the other criteria. Overwhelming sentiment in Lovettsville was that people wanted AA-size school so that they could compete against other Loudoun County schools. Need to include Building & Development staff during planning process, not just Planning staff to ensure ordinance interpretations wont change between the land use planning process and the construction planning process.

September
A draft report was sent out to members of the Task Force just prior to the September meeting. During the September meeting, the Task Force reviewed the draft report and laid out a strategy for the rest of the year.

Key Takeaways

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Comments Regarding the Draft Report o Add 3-story schools as a recommendation a sense that the only thing that should constrict design is the Zoning Ordinances o Stay away from trailers as a recommendation o Busing may not be a real interim option because seats in existing schools filling more rapidly than expected o Closed school facilities may not be a valid interim option because they are being used for other things o Emphasize the main points of the 1999 study, especially regarding school size recommendations o Find a balance between two much specificity in long-term site planning and not enough o Consultation with the Towns is not a strong enough word for some; however, others emphasized the need for compromise from the Towns o Emphasize the desire for a thorough planning process o Recommend review of current condemnation policy o Difference of opinion over current plan language regarding location of schools and staff interpretation of that language. Focus of October meeting should be Interim Solutions.

October
Prior to the meeting, the Task Force received suggestions from Schools Superintendent Hatrick and several citizens for discussion by the Task Force. These were condensed into eleven items on a Summary Sheet. Both the individual suggestions and the Summary Sheet can be found in Appendix 8.

Key Takeaways
Historically, Eastern schools have suffered though similar or higher levels of crowding. For example, Stone Bridge High School has a capacity of 1500 students, but operated at approximately 1800 for three years until Briar Ridge High School opened. This was accommodated primarily through increases in class sizes. The Task Force agreed they wanted to make some type of recommendation to the School Board regarding interim solutions. The Task Force undertook an initial evaluation of the suggestions presented and agreed to continue the discussion during its November meeting. Supervisor Kurtz asked that the suggestions be placed in a timeline format.

November
The comments from the October meeting were organized into two documents a matrix and a timeline, which can be found in Appendix 9 and the Task Force finalized its recommendations regarding interim solutions. The Task Force also discussed Next Steps.

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Key Takeaways
Interim Solutions o Attendance information found in the Grubb Property Special Exception presentation suggests that there may be more than sufficient capacity for middle and high school needs if Culbert is temporarily used for 6th graders as suggested in Superintendent Hatricks memorandum of 23 October 2007. However, it was also noted that such usage would merely drive the crowding problems to the elementary school level. o The Task Force decided to present all of the ideas to the School Board, explain how they were created, and comment on each. However, members also felt strongly enough about the alternatives to make a specific recommendation. o The Task Force decided to divide the suggestions into two categories: interim solutions and long-term replacement solutions. Next Steps o Update the Draft Report from September to include the discussions regarding interim solutions and distribute to members. o Members will gather comments from members of their bodies and forward to Supervisor Burton for inclusion. o Task Force will present report and recommendations to the Board of Supervisors and request the funding of a Phase II.

Task Force Current Status

At this time, the Task Force has considered five of the seven issues it laid out during its April meeting: School Size To be the subject of the May meeting with the 1999 Rural Loudoun School Study Committee Report as the starting point for the discussion. School design: cookie cutter, site-specific design, design-build, green building, etc. East-West philosophy, politics Facility sharing Site selection process: limitations (e.g., condemnation); communications policy; criteria (what criteria should the School Board use for site selection; review current policies and standards for siting of school; etc.) Preferred locations: in what general geographic areas should future schools be located; consistency with (or changes needed to) County and Town Comprehensive Plans Interim solutions for the overcrowding of Loudoun Valley, Harmony, & Blue Ridge during the 2007-2008 school year and, if necessary, during the 2008-2009 school year

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Based on its research of available materials and discussions at its meetings, the Task Force is prepared to make certain initial recommendations to the Board of Supervisors, the School Board, the various Town Councils, and to Loudoun citizens. These recommendations will include requests for immediate specific actions on the part of the various public bodies as well as ideas for long-term consideration.

Initial Recommendations
1. The Task Force affirms the School Profile and Facilities findings and recommendations of the 1999 Rural Loudoun School Study Committee, believes that despite the passage of almost a decades time they retain relevance, and strongly recommends their implementation. a. Maintain small, community-based schools. b. Continue to foster small class sizes. c. Organize clusters by community boundaries that provide continuity. throughout a students educational experience. d. Anticipate adjustments to clusters and boundaries. e. Involve the community in the planning process. f. Locate new schools to accommodate current projected growth patterns. g. Locate middle and high schools together. h. Utilize value-engineering precepts, life-cycle costs, and the highest industry standards for all new construction. i. Limit school bus routes to one hour or less. j. Create opportunities for students to walk or bike to school. 2. The Task Force supports the site selection criteria presented at its August meeting in emails from Greg Wagner and Sara Howard-OBrien.4 a. It recommends that the School Board provide greater specificity to some of the language and then formally adopt and use it for future site selection. b. The Task Force further recommends that the School Board should let criteria other than the current school prototype drive site selection. 3. The Task Force affirms the current wording of the Countys Comprehensive Plan which advises that schools be placed near existing towns and villages whenever possible. 4. Recognizing a need to integrate or coordinate County and Town plans, ordinances, and facility standards the Task Force offers the following recommendations: a. The Towns should decide what types of facilities they would like to see added to each of their communities and negotiate with the County to place those facilities in the Countys Comprehensive Plans. Once negotiated, this list should be included in the Towns Comprehensive Plan. b. The County should provide assistance from its mid-level Building and Development staffs (not just Planning staff) to Town planning processes. Alternatively, the County should assign a Building Project Manager to
4

See Appendix 6. 11

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5.

6.

7. 8.

coordinate County, Town, and School projects from Planning through Inspection. Given the increasing unavailability of large parcels, the Task Force makes the following additional recommendations regarding the search for sites: a. that criteria other than the prototype should drive site selection; b. that a review of the current prototype and its feasibility occur, including consideration of 3-story schools; c. that the School Board should plan proactively, rather than reactively, determining where population growth will occur and purchasing land in advance of need and that the Board of Supervisors should finance such purchases especially during real estate value downturns; d. that the School Board initiate land searches through the use of RFP's, especially as RFPs also provides greater transparency to the public, and may, through the use of market forces, depress prices; e. that the School Board expand it search to include the purchasing several smaller adjacent parcels rather than one large parcel; f. and that, as a last resort, the School Board and the Board of Supervisors may need to review the current condemnation policy. Regarding interim solutions, the Task Force offers the following Final Matrix and Timeline of Interim and Replacement Solutions for the School Boards use and consideration. However, the Task Force did have a strong preference which it wanted to share with the School Board: a. As suggested by Superintendent Hatrick, install Grade 6 at Culbert Elementary School. However, the Task Force believed such installation should occur as soon as construction of the school concludes (currently scheduled for Fall 2009) b. Use the Harmony and Loudoun Valley facilities for all four high school classes (Suggestion 2) holding classes with specific high school facility needs in Valley and other classes in Harmony. i. In order to limit student commuting and school traffic the Task Force suggested that students class schedules would keep them in a single building throughout the day (e.g., lab classes in Valley on Tuesdays and Thursdays; English classes in Harmony on Monday and Wednesday). ii. In order to address possible citizen concern, such arrangement would be accompanied by a Memorandum of Understanding limiting the arrangement to a specified time period. The Board of Supervisors and the School Board should set up a Joint Standing Committee that meets monthly to discuss both immediate issues of concern and long-term strategy. The Board of Supervisors should undertake a full-scale Facilities CPAM similar to that undertaken for Health Care facilities. A Western Schools CPAM could serve as a pilot for such a CPAM.

Next Steps

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Moving forward, the Task Force believes that the biggest difficulty facing all of the stakeholders is the lack of long-term, proactive planning with regards to future school and other institutional sites. The Task Force points to the recent Health Care CPAM in which potential medical care centers were considered and located as an example of the type of strategic planning that could be done for school sites in Western Loudoun and elsewhere in the County as well as for other institutional sites, including parks, public safety stations, and community centers. With the assistance of County and School planning and building staffs the Task Force would like to initiate an undertaking similar to that of the Health Care CPAM. The Task Force believes that such a planning process will provide numerous benefits. The most important benefit is that such a process lays out a clear framework of expectations for all stakeholders: Family and student expectations for school attendance boundaries Landowner expectations of neighboring property uses Town expectations for infrastructure demands School Board expectations that land chosen will be acceptable, allowing for the possibility of a streamlined or advance land use process County expectations for a wise use of County funds that is acceptable to all stakeholders.

Such a framework for expectations prevents misunderstandings and resists the sudden changes in policy that bedeviled the stakeholders throughout the HS-3 debate. County residents know what school facilities are expected and approximately where and when those facilities will appear.

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Western Schools Task Force DRAFT Suggested Interim Solutions: Summary Sheet Task Force Recommendation No Preferred Approach in combination with #2 to start as soon as Culbert opens (Fall 2009). Preferred Approach in combination with #3 to start as soon as Culbert opens (Fall 2009).

December 2007

No. 1. 3.

Suggestion Return Grade 6 to Elementary Schools Install Grade 6 at Culbert Elementary School upon its completion

Notes No room; missing facilities. Need to construct Culbert with 6th Grade facilities just in case.

2.

Use Harmony and LVHS facilities to serve Grades 9-12 Hold classes with specific HS facility needs in LVHS Hold classes without specific HS facility needs at Harmony

4-5.

Install Grades 9 and 10 at Harmony; Install Grades 11 and 12 at LVHS

Possible

Must be combined with either 1 or 3. Must be accompanied with a Memorandum of Understanding that only an interim measure for a specified time period. In order to limit commuting time and traffic, students would alternate days in each school (e.g., all Harmony classes for some students would take place on Monday and Wednesday and all their Valley classes would take place on Tuesdays and Thursdays; for other students it would be the reverse). Must be combined with either 1 or 3. Might be a better idea from a traffic point of view to use Blue Ridge instead of Harmony. Core facilities must be increased proportionately. IGA Building

8.

Enlarge class sizes

Only if certain conditions met.

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Western Schools Task Force DRAFT Suggested Interim Solutions: Summary Sheet No. Suggestion Task Force Recommendation

December 2007

Notes Additional Trailers (on vacant 3-acre lot behind IGA) Modular systems (on vacant lot on vacant 3-acre lot behind IGA) Additional playing fields (on vacant lot on vacant 3-acre lot behind IGA) Need better definition of how it works, what it entails.

9. 10. 11.

Split shifts at LVHS Busing to other high school facilities Zero classes

No No School Board should explore idea beyond its current use.

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Western Schools Task Force DRAFT Suggested Replacement Solutions: Summary Sheet

December 2007

No. 6. Suggestion Immediate expansion of LVHS.

Task Force Recommendation If certain conditions met.

Notes Increases traffic in Town Increased demand on Town water/sewer Sufficient core facility capacity? Structural engineering limitations? Time to design, build?

7.

Fast track construction on existing Countyowned Lovettsville park property. Begin land preparation work concurrent with land use application process Retain a management/consulting firm to design/build school and work through/improve government processes Provide financial incentives to the construction company that will encourage accelerated completion Find another site Change HS-5 boundaries

Construction only takes 18-24 months but still have to go through site analysis, land use, site plan process and negotiations with Town. Conditions o Must have replacement site for Park before Town would be willing to provide utilities. o School Board must immediately start looking for HS-10 site.

12. 13.

4-5 year process. Must be small enough to be permanent; big enough to meaningfully relieve pressure on Valley

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Western Schools Task Force DRAFT Suggested Interim and Replacement Solutions: Timeline
2007-08 Interim Solutions Enlarge class sizes Increase Core facilities: IGA building, trailers, modular units or playing fields on vacant lot behind IGA Busing to Other Facilities 6 Grade to Culbert / 7 & 8 Grade to Blue th th th Ridge / 9 & 10 Grade to Harmony / 11 & th 12 Grade to Valley 6 Grade to Culbert / 7 & 8 Grade to Blue th th Ridge / 9 -12 Grades Share Harmony and Valley facilities depending on classroom requirements 6 Grade to Culbert / 7 & 8 Grade to Blue th th th Ridge / 9 & 10 Grade to Harmony / 11 & th 12 Grade to Valley Split Shifts Replacement Solutions Expansion of LVHS Fast track Lovettsville Park Property Change HS-5 Boundaries Find another site
th th th th th th th th th

December 2007

2008-09

2009-10[1]

2010-11

2011-12

2012-13

Green Text comes from 23 October 2007 Memo from Dr. Hatrick to the School Board. [1] Culbert ES opens [2]Source: 23 October 2007 memo from Dr. Hatrick to the School Board for Capacity and 2007 Enrollment figures; 16 July 2007 LCPS Presentation to the Planning Commission on the Grubb Property for Enrollment Projections. [3] Encompasses Blue Ridge Middle School, Harmony Intermediate School, and Loudoun Valley High School 2007-2009; Adds 875 seats at Culbert ES in 2009-10. Source: 23 October 2007 memo from Dr. Hatrick to LCPS. [4} Does not add Culbert ES capacity.

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