HomeMy WebLinkAboutZ23-21 Staff Report PBZ23-21 Staff Report PB 11.2.2023 Page 1 of 20
STAFF REPORT FOR Z23-21
CONDITIONAL REZONING APPLICATION
APPLICATION SUMMARY
Case Number: Z23-21
Request:
Rezoning to a Conditional RMF-M district
Applicant: Property Owner(s):
CIP Construction Company
Bee Safe Porters Neck, LLC
Herbert E Parham
Robert L Yunaska
Location: Acreage:
8100 Block of Market Street 33.54
PID(s): Comp Plan Place Type:
R03600-005-006-002, R03600-005-007-000,
R03700-004-147-000, R03700-004-148-000,
R03700-004-189-000, R03600-006-082-000
General Residential & Urban Mixed Use
Existing Land Use: Proposed Land Use:
Vacant Office, Undeveloped & Forestry Townhomes (Attached Single-Family, Row-
House) (Maximum 348 units)
Current Zoning: Proposed Zoning:
B-2, Regional Business & R-15, Residential, and I-
1, Light Industrial (CZD) RMF-M
SURROUNDING AREA
LAND USE ZONING
North Self-Storage and Food Lion Shopping Center, Open
Space B-1, B-2 & R-15
East Single-Family Residential R-15
South Single-Family Residential
R-15
Z23-21 Staff Report PB 11.2.2023 Page 2 of 20
West
Offices & Light Industrial (directly west) Porters Neck
Shopping Center (Walmart), Doctors Offices (across
Market St)
I-1 & B-2
ZONING HISTORY
July 6, 1971 Initially zoned R-15 and I-1 (Area 5).
December 2,
1985
B-2 portion rezoned to be compatible with the auto parts store in
operation on the site (Z-249)
COMMUNITY SERVICES
Water/Sewer
Water services are available through CFPUA. Sanitary sewer is available
through CFPUA with a force main connection or can be serviced by a private
septic system approved and permitted by the NHC Health Department.
Fire Protection New Hanover County Fire Services, New Hanover County Northern Fire
District, New Hanover County Porters Neck Station
Schools Porters Neck Elementary, Holly Shelter Middle, and Laney High Schools
Recreation Ogden Park
CONSERVATION, HISTORIC, & ARCHAEOLOGICAL RESOURCES
Conservation No known conservation resources, there is an existing pond on the eastern
boundary of the site which will remain.
Historic No known historic resources
Archaeological No known archaeological resources
Z23-21 Staff Report PB 11.2.2023 Page 3 of 20
APPLICANT’S PROPOSED CONCEPTUAL PLAN
Includes Staff Markups
• The applicant is proposing to construct a maximum of 348 townhouse units with an associated
amenity center.
• The applicant’s proposed conceptual plan includes a building height maximum of 3 stories.
• In each row, the end unit townhomes are two stories with a driveway and no garage. The
units in between in each row are three stories with a garage on the ground floor. The
townhomes closest to the single family homes are placed in proximity to the common areas
of the existing abutting neighborhoods.
• The concept plan places the amenity center and leasing office at the entrance to the
development, abutting the commercial corridor.
• The applicant’s proposed conceptual plan indicates that 13 acres (about 39%) of the site
will be reserved as open space, exceeding the UDO requirement of providing 20% open
space.
• The concept plan preserves the existing live oak trees on the site and the existing pond
toward the rear of the development.
• The applicant’s proposed conceptual plan includes opaque buffers along all property
boundaries that abut residential uses, noting that existing vegetated areas along the
periphery will be preserved and used as buffers. This feature of the concept plan has been
included as a condition.
Stormwater Pond
Ma
r
k
e
t
S
t
Brays Drive Access
Point
Amenity Center
and Main Access
Point Existing Pond
Z23-21 Staff Report PB 11.2.2023 Page 4 of 20
ZONING CONSIDERATIONS
• The R-15 district in this area were established in 1971. At the time, the purpose of the R-
15 district was to ensure that housing served by private septic and well would be developed
at low densities. Since that time, water and sewer services have become available to the
surrounding area.
• As currently zoned, the R-15 portion of the site would allow 75 dwelling units under a
performance residential subdivision.
• The B-2 portion of this site was rezoned in 1985 to be compatible with the auto parts
business that was already in operation on the site. That auto parts store is no longer on the
site.
• The B-2 portion at 2.88 acres could support approximately 22,500 square feet of
traditional retail uses based on a typical 18% building area for this type of zoning.
• The I-1 zoning designation for this property reflected the industrial uses already in existence
at the time this area of the county was initially zoned. The existing industrial uses and
properties will remain and are not affected by this rezoning. The I-1 portion of the site is
only 0.15 acres which is too small for consideration of possible development. It is included
in this development to provide sufficient access to the interior of the site.
• The proposed site is located in the Special Highway Overlay District (SHOD), which
prescribes a minimum 100’ front setback for buildings. This may be reduced by 25% if the
development provides additional plantings along the right-of-way. The SHOD also
prescribes maximum square footage and height of signs. The proposal meets the SHOD
requirements.
• While the site is zoned B-2, I-1 and R-15, the site is surrounded by commercial uses on its
market street frontage and single-family residential, zoned R-15, to the east, north and
south.
• The RMF-M district was established to provide lands that accommodate moderate density
single-family and multi-family development. The intent of the RMF-M district is to function as
a transitional district between intensive nonresidential development and higher density
residential areas. The district is designed to provide a reasonable range of choice, type,
and location of housing units.
• Under the RMF-M zoning district, there is a maximum density of 17 units per acre and
structures are limited to 3 stories unless an additional height allowance is granted, which
requires stricter setbacks. The applicant has specified a height maximum of 3 stories on their
concept plan.
• The proposed project has an overall density of 10.94 dwelling units per acre.
• The UDO requires streets to be continuous and to connect to existing or platted streets
without offset, including streets to adjacent developments.
• The UDO requires Type A: Opaque Buffers where the site abuts single-family residential
zoned parcels. This can include fencing, a berm and/or vegetation. The concept plan
proposes wider buffers than required, including using the existing vegetation on-site.
Z23-21 Staff Report PB 11.2.2023 Page 5 of 20
• If approved, the project would be subject to Technical Review Committee and zoning
compliance review processes to ensure full compliance with all ordinance requirements and
specific conditions included in the approval. Only minor deviations from the approved
conceptual plan, as defined by the UDO, would be allowed.
AREA DEVELOPMENTS
Z23-21 Staff Report PB 11.2.2023 Page 6 of 20
TRANSPORTATION
CURRENT CONDITIONS
Intensity of Current Zoning
Typical development under current zoning would allow a
maximum of 75 single-family dwelling units and approximately
22,500 sq ft of traditional retail.
PROPOSED ACCESS
Primary Access Market Street via a right-in, right-out driveway.
Secondary Access Brays Drive (Dedicated for public use, but privately owned
and maintained by the Porters Pointe HOA)
EXISTING ROADWAY CHARACTERISTICS
Affected Roadway Market Street (US 17) Porters Neck Road
Type of Roadway NCDOT principal arterial NCDOT minor collector
Z23-21 Staff Report PB 11.2.2023 Page 7 of 20
Roadway Planning Capacity
(AADT) 41,369 10,979
Latest Traffic Volume (AADT) 42,500 15,000
Latest WMPO Point-in-Time
County (DT) 49,785 15,392
Current Level of Congestion Above planning capacity Above planning capacity
Z23-21 Staff Report PB 11.2.2023 Page 8 of 20
NEARBY NCDOT STIP ROADWAY PROJECTS
U-4902D – Market Street
Improvements
(2023 Completion)
- Access management improvements from N. College
Road to Station Road and from Middle Sound Loop
Road to the Mendenhall Drive/Marsh Oaks Drive
intersection.
- Installation of a center median and pedestrian
accessways along Market Street from Middle Sound
Loop Road to Marsh Oaks Drive. The pedestrian
accessways will consist of a 10-foot wide multi-use path
on the eastern side of the street and a 5-foot wide
sidewalk on the western side of the street.
- With the widening of Market Street there will be a
signalized U-turn with a bulb-out just south of the
proposed entrance.
TRAFFIC GENERATION
Traffic
Generated
by Present
Designation
(R-15, 75
du)
Traffic
Generated
by Present
Designation
(B-2,
22,500 sq
ft retail)
Traffic
Generated by
Proposed
Designation
Potential
Impact of
Proposed
Designation
AM Peak Hour Trips 53 53 131 +25
PM Peak Hour Trips 71 148 170 -49
TRAFFIC IMPACT ANALYSIS (TIA)
New developments that are anticipated to generate more than 100 trips during any peak hour
period are required to submit a traffic impact analysis (TIA) as part of their rezoning application. A
team of NCDOT, WMPO, and County planning staff work with an applicant’s traffic engineers to
develop the scope for the TIA, including the study area, the traffic data which must be collected, trip
distribution, and the developments and background traffic growth that must be analyzed. This
document is used to identify off-site transportation improvements required to mitigate the impacts of
the development and must be approved by the WMPO and NCDOT.
Approval Date January 31, 2023
Development Proposal
Analyzed 348 Dwelling Units- Multi-Family (low rise) residential.
Z23-21 Staff Report PB 11.2.2023 Page 9 of 20
Study Intersections
- Market Street and Hays Lane/Commercial Driveway
- Market Street and Cypress Pond Way
- Market Street and Porters Neck Road
- Porters Neck and Brays Drive (Site Access 2)
- Market Street and Site Access 1
Trip Generation
- 131 AM peak hour trips
- 170 PM peak hour trips
- 2,306 average daily trips
Traffic Data Collection - September 13, 2022
Trip Distribution and
Assignment
- 60% to/from the south on Market Street
- 40% to/from the north on Market Street
Approved
Developments &
Background Growth
- Marsh Oaks Mixed Use- 10,200 sq ft of medical, 6,300 sq ft
of strip retail, and 2,400 sq ft of high-turnover sit-down
restaurant.
- Primrose School of Mayfaire, 191-student daycare.
- Planned Roadway/Intersection Improvements
o Military Cutoff Road Extension (TIP U-4751), opened
October 2023
- Full Build – 2023
- Growth Rate – 1% per year
Z23-21 Staff Report PB 11.2.2023 Page 10 of 20
Required Improvements
Intersection: Market St and Hays Lane/Commercial Driveway
- No improvements required
Intersection: Market St and Cypress Pond Way
- Install a traffic signal and provide necessary coordination.
Intersection: Market St and Porters Neck Road
- No improvements are required
Intersection: Porters Neck Road and Brays Drive
- No improvements are required.
Intersection: Market St and Site Access 1
- Construct a continuous northbound thru-right turn lane on Market
St from the ABC store driveway continuing up to the thru-right
lane at the intersection of Market St and Porters Neck Road.
SUMMARY
The proposed project is located along a principal arterial highway that is currently over capacity;
however, the Military Cutoff Extension recently opened and is anticipated to reduce traffic congestion
in the Porters Neck area. The applicant has had a TIA approved by the NCDOT and WMPO requiring
several roadway improvements, including a new right-turn lane on Market Street on a northbound
approach to this development and a new traffic signal at Cypress Pond Way. There is a connection
to Brays Drive which the applicant has proposed for emergency access only. The TIA approval was
based on full access at Brays Drive, which staff would recommend. If the Board is in support of the
applicant’s proposed gated access at Brays Drive, an updated TIA approval letter would be required
from the WMPO and NCDOT.
ENVIRONMENTAL
• This property is not within a Natural Heritage Area. There is an existing pond on the site.
Per New Hanover County Engineering, the end of Lantana Lane and areas adjacent to the
existing pond have some historic flooding concerns. There is a suggested condition for an
overland relief path, such as a drainage ditch, within a public drainage easement from that
pond to the stormwater pond outfall.
• The property is within the Pages Creek watershed.
• Per the Classification of Soils in New Hanover County for Septic Tank Suitability, soils on the
property consist of Class II (Moderate), Class III (Severe) and Class IV (Unsuitable) soils.
However, the project will be served by CFPUA public water and sewer.
• The concept plan notes wetlands that were determined on a survey completed in 2003. The
concept plan states the permits will be updated through the Army Corps of Engineers. The
wetland designation was determined before recent changes to the federal definition of
wetlands.
Z23-21 Staff Report PB 11.2.2023 Page 11 of 20
OTHER CONSIDERATIONS
Schools
• Students living in the proposed development would be assigned to Porters Neck Elementary
School, Holly Shelter Middle School, and Laney High School. Students may apply to attend
public magnet, year-round elementary, or specialty high schools.
• A maximum of 75 dwelling units would be permitted under the current R-15 zoning base
density, and 348 units could potentially be developed under the proposed zoning for an
increase of 273 dwelling units.
• Based on a generalized historic generation rate*, staff would estimate that the increase in
homes would result in approximately 60 additional students than would be generated under
current zoning.
• Staff is in the process of analyzing the school capacity for the new school year and
anticipates providing updated data for school enrollment and capacity at the Planning
Board meeting.
• The general student generation rate provides only an estimate of anticipated student yield
as different forms of housing at different price points yield different numbers of students.
Over the past four years, staff has also seen a decline in the number of students generated
by new development. Student numbers remained relatively stable between 2015 and
2020 (excepting the impacts of the COVID-19 pandemic), while 14,500 new residential
units were permitted across the county. In addition, the student population is anticipated to
only grow by approximately 1,300 students over the next 10 years based on the most
recent New Hanover County Schools Facility Needs Study.
Development Type Intensity Estimated Student Yield
(current general student generation rate) *
Existing Development Undeveloped Approximate** Total: 0
(0 elementary, 0 middle, 0 high)
Typical Development Under
Current Zoning 75 residential units Approximate** Total: 17
(7 elementary, 4 middle, 5 high)
Proposed Zoning 348 residential units Approximate** Total: 77
(31 elementary, 17 middle, 24 high)
*The current general student generation rate was calculated by dividing the New Hanover County public school student
enrollment for the 2022-2023 school year by the number of dwelling units in the county. Currently, there are an
average of 0.22 public school students (0.09 for elementary, 0.05 for middle, and 0.0 7 for high) generated per
dwelling unit across New Hanover County. These numbers are updated annually and include students attending out -
of-district specialty schools, such as year-round elementary schools, Isaac Bear, and SeaTech.
**Because the student generation rate often results in fractional numbers, all approximate student generation yields
with a fraction of 0.5 or higher are rounded up to a whole number and yields with a fraction of less than 0.5 are
rounded down. This may result in student numbers at the elementary, middle, and high school levels not equaling the
approximate total.
• Developments of the size and type associated with the proposed rezoning may not reach
full build-out for a few years, as reflected in the anticipated 2024 build-out referenced in
the Traffic Impact Analysis. As a result, existing school enrollment and capacity is not likely
to be relevant. New Hanover County Schools staff would include this project if approved
in future facility planning initiatives in order to accommodate any resulting student growth.
Z23-21 Staff Report PB 11.2.2023 Page 12 of 20
• Staff has provided information on existing school capacity to provide a general idea of the
potential impact on public schools, but these numbers do not reflect any future capacity
upgrades.
School Enrollment* and Capacity** (2022-2023 School Year)
*Enrollment is based on the New Hanover County Schools student numbers for the 2022-2023 school year.
**Capacity calculations were determined based on the capacities for the 2022-2023 school year, and funded or
planned capacity upgrades were those included in the Facility Needs Study presented by New Hanover County Schools
to the Board of Education in January 2021. This information does not take into account flexible scheduling that may
be available in high school settings, which can reduce the portion of the student body on campus at any one time.
• The 2021 facility needs survey prepared by Schools staff indicates that, based on NC
Department of Public Instruction (DPI) student growth projections and school capacity data,
planned facility upgrades, combined with changes to student enrollment patterns, will result
in adequate capacity district wide over the next ten years if facility upgrades are funded.
Level
Total
NHC
Capacity
School
Enrollment of
Assigned
School
Capacity of
Assigned
School
w/Portables
Capacity of
Assigned
School
Funded or
Planned
Capacity
Upgrades
Elementary 95% Porters Neck 601 549 109% None
Middle 108% Holly Shelter 851 991 86% None
High 93% Laney 2214 1941 114.1% None
Z23-21 Staff Report PB 11.2.2023 Page 13 of 20
New Hanover County Strategic Plan
On July 17, 2023 the Board of Commissioners adopted a new strategic plan for Fiscal Years 2024-
2028. This plan focuses on three core areas: workforce and economic development, community
safety and well-being, and sustainable land use and environmental stewardship.
Strategic Plan Outcomes Relevant to
Proposal Analysis
Through planned growth and development,
residents have access to their basic needs.
The strategic objective to achieve this desired
outcome includes the provision of a variety of
housing options. The proposed CZD RMF-M
rezoning will provide new attached single-
family homes in an area of the county that is
largely single-family, detached and can aid in
achieving the target of increasing the housing
supply to a level of one residential unit per
every two residents. The 2022 Housing Needs
Assessment, also known as the Bowen Report,
concluded there is an estimated overall housing
gap of 12,147 rental units and a gap of
16,875 for-sale units within the County over the
next 10 years.
Natural areas and critical environmental
features are enhanced and protected.
While the conceptual plan included as part of
the proposed rezoning shows wetlands on the
site, the proposed development will not disturb
a large component of them and the areas that
will be impacted have been determined to not
be jurisdictional wetlands subject to Army
Corps of Engineers regulations. Homes are not
proposed to be located near the existing pond
on site. The proposed project sets aside
approximately twice the amount of open
space, at 13 acres, or 39% of the overall site.
The plan also proposes to protect existing large
live oak trees on the site.
Z23-21 Staff Report PB 11.2.2023 Page 14 of 20
Representative Developments
Representative Developments of R-15 (Existing Zoning):
Cottage Grove
B-2 Retail Development along Major Road Corridor
Z23-21 Staff Report PB 11.2.2023 Page 15 of 20
Representative Developments of Townhomes (Proposed Zoning/Land Use):
Plantation Village
Z23-21 Staff Report PB 11.2.2023 Page 16 of 20
Context and Compatibility
• The property is located in one of the county’s more densely developed corridors and
partially within the Porters Neck growth node as identified in the Comprehensive Plan.
• The property can only be accessed along Market Street via a right-in/right-out driveway.
The Brays Drive connection is proposed for emergency access only. However, the County
can require a through connection.
• While the eastern part of the property was zoned for lower density resident development
in the early 1970’s, both public water and sewer services are now available, which makes
this area less likely to be developed for low-density residential.
• The site plan places the amenity center closer to Market Street, a largely commercial
corridor. This serves as a transition from that corridor to the residential development.
• The recently opened Military Cutoff Extension is anticipated to alleviate some traffic
concerns in the Porters Neck Area, with Porters Neck becoming more of a local destination
rather than a thru-way for traffic traveling to and from Pender County.
• Required setbacks and transitional buffers provide additional mitigation for aesthetic
effects along the property boundaries. Multi-family residential developments require
transitional buffers where the site abuts single-family residential, consisting of vegetation,
berms, or fences with vegetation.
• Due to the location and surrounding development patterns, the property is less likely to be
developed with low density housing.
• The site plan does take into consideration the preservation of large live oak trees on the
site, most of which are considered specimen trees. The site plan also does not place
development close to the existing pond on site.
Z23-21 Staff Report PB 11.2.2023 Page 17 of 20
2016 COMPREHENSIVE PLAN
The New Hanover County Future Land Use Map provides a general representation of the vision for
New Hanover County’s future land use, as designated by place types describing the character and
function of the different types of development that make up the community. These place types are
intended to identify general areas for particular development patterns and should not be
interpreted as being parcel specific.
Future Land Use
Map Place Type
Urban Mixed Use and General Residential
Because of the general nature of place type borders, sites located in
proximity to the boundaries between place types could be appropriately
developed with either place type, allowing site-specific features and
evolving development patterns in the surrounding area to be considered.
Place Type
Description
Urban Mixed Use: promotes development of a mix of uses at higher
densities. Types of uses encouraged include office, retail, mixed use, small
recreation, commercial, institutional, single-family, and multi-family
residential.
General Residential: focuses on lower-density housing and associated civic
and commercial services. Types of uses include single-family residential, low
density multi-family residential, light commercial, civic, and recreational.
Commercial uses should be limited to strategically located office and retail
spaces, while recreation and school facilities are encouraged throughout.
Z23-21 Staff Report PB 11.2.2023 Page 18 of 20
Analysis
The proposed townhome development is located along the Market Street
corridor in the Porters Neck area, which is identified as a high growth area
in the Comprehensive Plan.
Generally, the Comprehensive Plan designates areas along major
roadways for higher densities of residential and commercial development.
The Urban Mixed Use place type is closer to Market Street, transitioning to
General Residential as the property moved away from the higher intensity
road corridor. Place type borders are not fixed; however, the intent is for
that transitional development pattern between different levels of intensity.
In the past, where projects were located in more than one place type,
densities that are in the range between those two place types have been
seen as consistent as long as the development tries to transition or buffer
into lower density areas.
The overall project density of 10.94 dwelling units per acre is in between
that of the recommended densities of the General Residential place type of
no more than 8 units per acre, and the Urban Mixed Use place type of no
more than 25 units per acre. Given that the majority of the site lies within
the General Residential place type, the overall density being only slightly
higher than the General Residential place type recommendation is
appropriate.
The site plan takes into consideration existing natural features of the site,
including large live oak trees and a pond on the rear of the site.
The TIA approval includes a full access at Brays Drive, which staff is in
agreement with. If the Board is in support of the applicant’s proposed gated
access, an updated TIA approval letter would be required from the WMPO
and NCDOT.
While staff would generally prefer more commercial development directly
along commercial corridors and in growth nodes as provided by the existing
B-2 zoning, the site plan places the amenity center and leasing office along
Market Street, which does create a non-residential use in this portion of the
site.
The proposed RMF-M district and project are in line with the Comprehensive
Plan’s recommendations for the Urban Mixed Use and General Residential
place types. While the proposed project’s density is lower than
recommended for the Urban Mixed Use place type, it is higher than that
which is recommended for General Residential. This proposed project fits in
between the two place types. The application provides for the type of use
and density that is appropriate within this area and within the growth node.
Consistency
Recommendation
The proposed RMF-M zoning is generally CONSISTENT with the 2016
Comprehensive Plan because the district is more in line with the densities that
are appropriate for properties located in both the Urban Mixed Use and
General Residential place types. While staff would prefer additional
connections and more commercial development along the commercial
corridor, the application provides housing and an appropriate transition
from the commercial node to the lower density residential areas to the east.
Z23-21 Staff Report PB 11.2.2023 Page 19 of 20
STAFF RECOMMENDATION
Staff’s recommendation is based on the policy guidance of the 2016 Comprehensive Plan, zoning
considerations, and technical review. The proposal includes a density and housing type that
appropriately sits in between the recommended densities for the General Residential place type
and the Urban Mixed Use place types. Staff is in support of the additional connectivity included in
the approved TIA, and while staff would prefer more commercial development along the Market
St corridor, the application provides housing and an appropriate transition from the commercial
node to the lower density residential areas to the east.
As a result, Staff recommends approval of the proposal and suggests the following motion:
I move to recommend APPROVAL of the proposed rezoning. I find it to be
CONSISTENT with the purposes and intent of the Comprehensive Plan because the
district is more in line with the densities that are appropriate for properties located in
both the Urban Mixed Use and General Residential place types. I also find
recommending APPROVAL of the rezoning request is reasonable and in the public
interest because the application provides housing and an appropriate transition from
the commercial node to the lower density residential areas to the east.
Applicant Proposed Conditions:
1. Access to and from Brays Drive shall be gated and restricted to emergency vehicles
only.
2. Buffers against residential properties are widened beyond New Hanover County
minimum buffer width requirements as shown on the conditional zoning plan. The
buffers and open space areas are variable widths and will contain a mixture of
preserved existing trees and/or augmented vegetation.
3. Areas of buffer and open space outside of essential site improvements and
easements will preserve existing trees that are not dead, dying, or otherwise
hazardous.
Staff Recommended Conditions, in addition to applicant proposed conditions:
1. The connection to Brays Drive shall be a full through connection.
2. Bicycle and pedestrian infrastructure shall be installed up to the property line where
internal roads connect to adjacent parcels.
3. An overland relief path within a public drainage easement will be provided from
the existing pond to the proposed pond outfall.
4. Buildings will be a maximum of three stories.
Z23-21 Staff Report PB 11.2.2023 Page 20 of 20
Alternative Motion for DENIAL (if based on information presented at the public hearing or other
consideration beyond the scope of staff review, the board finds denial appropriate.)
I move to recommend DENIAL of the proposed rezoning. While I find it to be
CONSISTENT with the purposes and intent of the Comprehensive Plan because the
district is more in line with the densities that are appropriate for properties located in
both the Urban Mixed Use and General Residential place types., [and] I find
recommending DENIAL of the rezoning request is not reasonable and in the public
interest because the existing B-2 zoning is more appropriate along the Market Street
corridor and the proposal funnels to only one access point.