I've incorporated my final comments into the attached draft (not red-lined).  Below are a couple of additional notes.

Footnote 4 does not appear at the bottom of the page where the actual footnote resides; it appears on the following page.  This may clear up when all the formatting is completed or it may be something that needs to be fixed.  Also, there is a line drawn above the footnote that should not be there.

I added language under #2 on page 3.  Our rationale in the second paragraph needed a lead-in, which I added to the end of the first paragraph.

For footnote 5, I deleted the text, which was from an earlier note of mine.  I changed the footnote to reference the new paragraph number instead of a page number in the NOPR.  The quote is in paragraph 7 of the NOPR.  Please revise the footnote to use the proper verbiage.


Thanks,
Theresa