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Home My WebLink About03/19/2025 - Agenda Packet AGENDA Planning Commission Meeting 6:00 PM - Wednesday, March 19, 2025 Council Chambers, 7th Floor, City Hall – 1055 S. Grady Way 1. CALL TO ORDER 2. ROLL CALL 3. CORRESPONDENCE RECEIVED 4. AUDIENCE COMMENT 1. Virtual Attendees 2. In-person Attendees Those attending virtually (Call 253-215-8782, Zoom meeting ID: 880 3465 9736, password: Weplan2024 or https://us06web.zoom.us/j/88034659736?pwd=z1TyxJNsMEloal0MglAamlJkjbnLaR.1) will be offered an opportunity to speak before the in-person (physical meeting at the City Hall, 7F Council Chambers) comments are completed. Please use your device to raise your (electronic) hand in order to be recognized by the Recording Secretary. Each speaker will be provided three (3) minutes to address an item. Groups or organizations are encouraged to select a spokesperson to speak on a group’s behalf. Alternatively, interested parties are encouraged to provide written comments to planningcommission@rentonwa.gov. Attendees will be muted and not audible to the Commission except during times they are designated to speak. Public can use the “Raise Hand” option if attending through video. If there are others calling in, you can be called upon by the last 4 digits of your telephone number. Phone instructions: *6 to mute/unmute, *9 to raise hand. 5. COMMISSIONER COMMENTS 6. ADMINISTRATOR'S REPORT 7. BRIEFING - D-237: HB 1042 CONVERSION OF COMMERCIAL TO HOUSING a) Page 1 of 14 -Matt -Angie 8. BRIEFING - D-236: HB 1110 MIDDLE HOUSING AND HB 1337 ADUS a) 9. COMMISSIONER COMMENTS 10. ADJOURNMENT Hearing assistance devices for use in the Council Chambers are available upon request. For more information please visit rentonwa.gov/planningcommission Page 2 of 14 -Katie Angelea D-237: Conversion to Housing March 13, 2025 CITY OF RENTON Community and Economic Development Department #D-237: Conversion to Housing (HB 1042) Staff: Angie Mathias, Long Range Planning Manager Date: March 13, 2025 STAFF REPORT _____________________________________________________________________________________ SUMMARY: Last year the State Legislature passed House Bill (HB) 1042 requiring jurisdictions to allow the conversation of commercial and mixed-use buildings to convert to residential buildings. The city must adopt the enabling regulations by June 30, 2025. This docket item is to comply with this requirement. General Description Current Renton Municipal Code does not prohibit commercial buildings converting to residential and the city has had discussions with some property owners considering such conversions. However, HB 1042 places limitations on what the city can require for such conversions and allows for greater density than what existing zoning would allow for the building. Below is a bulleted list of the requirements of the legislation: • Cities must allow converted buildings to have 50% greater density for residential than the zone allows. • New or additional parking to accommodate the residential cannot be required, however the existing parking can be required to be retained. • Architectural or design requirements cannot be required, the existing exterior structure can be utilized as is. • Life safety standards can be applied, as well as, energy code standards can be required for the new residential units, but not for portions of the structure that are not modified. • Existing non-conformities such as setbacks, building coverage, impervious coverage, etc. cannot be a justification for denial of a building permit. • Ground floor commercial can be required for buildings on major pedestrian corridors, as defined by city code. • Only buildings with Certificates of Occupancy that are at least three years old are eligible. Staff Recommendation Staff recommends that the Code be amended to implement the legislation adopted with HB 1042. Also, amend code to identify major pedestrian corridors as roadways classified as Principal and Minor arterials as identified on the city’s mapping system COR Maps. AGENDA ITEM #7. a) Page 3 of 14 Page 4 of 14 Staff reports from pages 5-13 CITY OF RENTON Community and Economic Development Department #D-236: Compliance with State Legislation; HB 1110 Middle Housing and HB 1337 ADUs Staff: Katie Buchl-Morales, Senior Planner, and Angelea Weihs, Associate Planner Date: March 14, 2025 Applicant or Requestor: Staff _____________________________________________________________________________________ GENERAL DESCRIPTION In 2023, the Washington State Legislature passed a series of housing and land use bills aimed at expanding housing options, increasing inventory, and incentivizing affordable housing. Among these include House Bill (HB)1110 and HB 1337, which are related to middle housing and accessory dwelling units (ADUs). In accordance with the Revised Code of Washington (RCW) 36.70A.635(11)(a) and (b) and RCW 36.70A.680 and 681 the City of Renton is required to amend Renton Municipal Code to implement the new housing regulations by June 30, 2025. BACKGROUND – HB 1110 MIDDLE HOUSING House Bill (HB) 1110 mandates cities to allow middle housing in residential zones where single- family detached housing is the predominant land use, and where multi-family development has historically been prohibited. As defined in HB 1110, middle housing refers to buildings that are compatible in scale, form, and character with single-family houses, and contain two (2) or more attached, stacked, or clustered homes. This legislation does not prohibit future single-family development, nor make existing single-family development non-conforming, but rather expands opportunities for the development and increases housing choice. The legislation categorizes cities into three (3) tiers based on population estimates from the Office of Financial Management, with specific regulatory requirements for each tier: • Tier 1: Cities with a population of at least 75,000 • Tier 2: Cities with a population of at least 25,000 • Tier 3: Cities with a population of less than 25,000, that are within a contiguous urban growth area and located within the largest city in a county with a population of more than 275,000 For the purposes of the middle housing regulatory requirements the City of Renton falls within the Tier 1 category. I. Middle Housing Typologies HB 1110 requires cities to allow six (6) of the nine (9) middle housing typologies. These options include townhouses, duplexes, triplexes, fourplexes, fiveplexes, sixplexes, stacked flats, courtyard apartments and cottage housing. Proposed Recommendation: Staff proposes to amend Renton Municipal Code to allow the following six (6) typologies within applicable zones recommended for middle housing: AGENDA ITEM #8. a) Page 5 of 14 #D-236 Page 2 of 10 March 13, 2025 • Townhouses • Duplexes • Triplexes • Fourplexes • Stacked Flats • Courtyard Apartments These middle housing typologies are proposed as they are the most compatible in scale, form, and character with single-family development. Furthermore, cottage housing is already an allowed use; therefore, staff recommends excluding cottage housing from the middle housing typology selection to ensure that projects are developed under the existing cottage housing standards. II. Residential Zones HB 1110 mandates that cities allow middle housing in residential zones where single-family development is the predominant land use. The table below summarizes permissibility of residential uses by zoning designation. Table 1. Allowed Housing Types by Residential Zoning Designations Residential Uses RESIDENTIAL ZONING DESIGNATIONS RC R-1 R-4 R-6 R-8 Residential Manufactured Home Park R-10 R-14 Residential Multi- Family Detached dwelling – Single family P P P P P P P Attached dwellings - Flats P P P Attached dwellings – Garden style apartments P Attached dwellings - Townhouses P P P13 Attached dwellings – Carriage houses P P P13 AGENDA ITEM #8. a) Page 6 of 14 #D-236 Page 3 of 10 March 13, 2025 Manufactured Homes P50 P50 P50 P50 P50 P P50 P50 P50 TABLE KEY: Blank = Not Allowed ▪ P = Permitted Use ▪ P# = Permitted provided condition can be met. P13 = Specified use(s) shall be subject to the standards of RMC 4-2-115, Residential Design and Open Space Standards, applicable to the R-10 and R-14 Zones, in lieu of the design district standards of RMC 4- 3-100. P50 = Manufactured homes shall be allowed only if in compliance with the Residential Design and Open Space Standards in RMC 4-2-115, as it exists or may be amended. As shown in Table 1, Allowed Housing Types by Residential Zoning Designations, residential zones RC through R-8 are exclusively designated for single-family dwellings, whereas R-10 and R-14 zones allow both attached multi-family and single-family dwellings. According to RMC 4-2-020, Purpose and Intent of Zoning Districts, the R-10 and R-14 zones were established to encourage higher-density residential development, incorporating a mix of residential styles to combine characteristics of both single-family and small-scale multi-family developments where densities range from five (5) to fourteen (14) units per net acre. To that end, the R-10 and R-14 zones already accommodate multi-family development similar to middle housing and have adequate existing development standards. Proposed Recommendation: Amend Renton Municipal Code to allow middle housing development in residential zones Resource Conservation (RC), Residential-1 (R-1), Residential-4 (R-4), Residential-6 (R-6), and Residential-8 (R-8). III. Units per Lot Currently, the maximum number of dwellings allowed within residential zones RC through R-8 is restricted to one (1) single-family dwelling with one (1) accessory dwelling unit. As a result, the existing regulations do not comply with HB 1110 requirements for minimum units per lot. HB 1110 requires Tier 1 cities to allow middle housing with up to four (4) dwelling units per lot, in all applicable zones, with the following additional allowances: • Up to six (6) dwelling units are allowed per lot on all lots within one-quarter mile walking distance of a major transit stop; and • Up to six (6) dwelling units are allowed per lot, if at least two (2) units are reserved and recorded as affordable. To qualify for the additional units permitted under HB 1110, cities must require applicants to record a covenant or deed restriction ensuring that designated affordable units remain affordable for no less than 50 years. Costs for dwelling units that qualify as affordable housing shall not exceed 30- percent (30%) of the monthly income of a household whose income does not exceed the following percentages of area median income (AMI) adjusted for household size, for the county where the household is located, as reported by the United States Department of Housing and Urban Development: AGENDA ITEM #8. a) Page 7 of 14 #D-236 Page 4 of 10 March 13, 2025 • Rental housing: 60% AMI • Owner-occupied housing: 80% AMI Proposed Recommendation: Amend Renton Municipal Code to comply with unit per lot requirements, as established by HB 1110. IV. Parking Standards HB 1110 prohibits cities from requiring off-street parking when located within a one-half (½) mile walking distance (“walkshed”) of a major transit stop. A major transit stop is defined as: • A stop on high-capacity transportation system funded or expanded under the provisions of chapter 81.104 RCW; • Commuter rail stops; • Stops on rail or fixed guideways systems; and • Stops on bus rapid transit routes, including those under construction. Key qualifying routes include the King County RapidRide F line, future Sound Transit Stride, and Future King County RapidRide I line. For areas outside of the one-half (½) mile walkshed, HB 1110 contains prescriptive language that restricts the amount of parking a city can impose based on lot size. See Table 2, Parking Requirements Applicable to Middle Housing Development below. Table 2. Parking Requirements Applicable to Middle Housing Development Lot size Maximum Parking That Can Be Required 6,000 sq. ft. or Less 1 parking space per dwelling unit 6,000 sq. ft. or Greater 2 parking spaces per dwelling unit Proposed Recommendation: Comply with parking requirements established by HB 1110 and adopt parking incentives to encourage off-street parking when not required. BACKGROUND – HB 1337 ACCESSORY DWELLING UNITS HB 1337 requires significant changes to Renton Municipal Code for regulating Accessory Dwelling Units (ADUs). The legislative mandates impact several existing development standards adopted in Renton Municipal Code, including but not limited to the maximum number of ADUs allowed, unit configuration, owner occupancy, parking requirements, and height restrictions. Under HB 1337, an ADU is a dwelling unit located on the same lot as a single-family housing unit, duplex, triplex, townhome, or other housing unit. The legislation aims to reduce barriers to ADU development to expand housing options, create opportunities to age in place, increase affordable housing, and reduce barriers of entry to high-opportunity neighborhoods with better access to transit, schools, and other public services. AGENDA ITEM #8. a) Page 8 of 14 #D-236 Page 5 of 10 March 13, 2025 I. Unit Configuration HB 1337 requires cities to allow at least two (2) ADUs on all lots in all zoning districts that allow single-family development. The ADUs may be configured in any of the following ways: - One (1) attached ADU and one (1) detached ADU; - Two (2) attached ADUs; or - Two (2) detached ADUs Additionally, cities must allow ADUs as accessory uses to all housing typologies allowed in the underlying zoning designation, including the six (6) middle housing typologies selected for implementation of middle housing. Considering the city’s proposed middle housing recommendations, this would mean that ADUs would be allowed on the same lot as townhouses, duplexes, triplexes, fourplexes, stacked flats, courtyard apartments, and single-family units. Currently, Renton Municipal Code allows one (1) ADU per legal lot and only detached ADUs are permitted. Proposed Recommendation: Amend Renton Municipal Code to comply with the unit configuration requirements of HB 1337. II. Residential Zones As previously stated, HB 1337 requires cities to allow ADUs in all zoning designations that allow for single-family development. In Renton, single-family development is allowed in the following residential zones: Resource Conservation (RC), Residential-1 (R-1), Residential-4 (R-4), Residential-6 (R-6), Residential-8 (R-8), Residential-10 (R-10), and Residential-14 (R- 14) – all of which currently allow ADUs. Proposed Recommendation: No amendments to Renton Municipal Code are necessary, as the existing regulations already comply with the requirements of HB 1337. III. Maximum Unit Size HB 1337 prohibits cities from imposing a maximum gross floor area requirement for ADUs that is less than 1,000 sq. ft. The legislation defines gross floor area as the “…interior habitable area of a dwelling unit, including basements and attics but not including a garage or accessory structure.” For a summary of the current ADU size allowance, refer to Table 3, Calculating Maximum ADU Size by Lot Area. Table 3. Calculating Maximum ADU Size by Lot Area Lot Area Maximum ADU Size Allowed 3,000 sq. ft. or less 600 sq. ft. 3,001 – 4,999 sq. ft. or less 700 sq. ft. 5,000 – 6,999 sq. ft. or less 800 sq. ft. AGENDA ITEM #8. a) Page 9 of 14 #D-236 Page 6 of 10 March 13, 2025 7,000 – 8,999 sq. ft. or less 900 sq. ft. Greater than 9,000 sq. ft 1,000 sq. ft. Current Renton Municipal Code allows a maximum ADU size of up to 1,000 sq. ft. of gross floor area, but unit size is further determined by lot area or restricted to 75% of the total gross floor area of the primary residence, whichever is smaller. Renton Municipal Code 4- 11-060 defines gross floor area as “the sum of the horizontal areas of all floors of a building measured from the face of each wall.” Although Renton Municipal Code complies with the ADU size requirement, the differing definitions result in a conflict between local and state regulations. Under HB 1337, gross floor area excludes garages and accessory structures, whereas Renton’s definition implies their inclusion, leading to inconsistencies in how gross floor area is calculated. Further, HB 1337 references “interior habitable area” in its definition of gross floor area but does not define the term. Washington Administrative Code (WAC) 246-359-010(15) and building codes consistently define habitable space as a “…room or space in a structure used for living, sleeping, eating, or cooking. Bathing facilities, toilet facilities, closet halls, storage or utility space, and similar areas, are not considered habitable rooms.” The inconsistency of terminology used, particularly the use of the term “interior habitable area” in HB 1337, could be interpreted to potentially allow ADUs to exceed the 1,000 sq. ft. limit. Proposed Recommendation: Amend Renton Municipal Code to establish a maximum gross floor area and total building area of 1,000 sq. ft. for ADUs. Additionally, staff recommends incorporating further clarifying language in the final ordinance to address the loophole created using “interior habitable area” in the legislation’s definition of gross floor area. IV. Owner Occupancy HB 1337 prohibits cities from requiring property owners to reside onsite in either the ADU or other onsite principal dwelling. However, an existing provision in Renton Municipal Code requires onsite owner occupancy unless the property/property owner is eligible for and receives an ADU owner occupancy exemption in compliance with RMC 4-9-030H, Conditional Use Permits. To be eligible for the owner-occupancy exemption, proposals must meet the following conditions of approval: 1. New Construction: Both the primary dwelling and ADU must be new construction. Building permit review for the primary dwelling and ADU shall be submitted simultaneously. 2. Maintenance Bond: The person or persons holding title to the property shall execute a maintenance bond to ensure the property owner remains responsible for continued maintenance of dwellings, on-site landscaping, and other site maintenance as determined by the Administrator. 3. Quantity: There shall be a minimum of two (2) lots each with a primary structure and an ADU. The two (2) lots shall be abutting unless otherwise approved as part of a plat application. AGENDA ITEM #8. a) Page 10 of 14 #D-236 Page 7 of 10 March 13, 2025 4. Affordability: Fifty percent (50%) of the total units shall be designated as and remain affordable at sixty percent (60%) of the area median income (AMI). 5. Contract: If the conditional use permit is approved, the applicant/owner shall enter a contract with the City, approved by the Administrator, regarding the terms and conditions of this project under this subsection H. The contract shall be executed and recorded against the subject real property at the applicant/owner’s expense before the issuance of the certificate of occupancy. If the applicant/owner fails to timely execute and record the contract the CUP shall be revoked, and onsite owner-occupancy shall be required. Proposed Recommendation: Amend Renton Municipal Code to remove the owner- occupancy requirement for ADUs in compliance with HB 1337. V. Parking Requirements HB 1337 prohibits cities from requiring off-street parking for ADUs when located within a a one-half (½) mile walking distance (“walkshed”) of a major transit stop. A major transit stop is defined as: • A stop on high-capacity transportation system funded or expanded under the provisions of chapter 81.104 RCW; • Commuter rail stops; • Stops on rail or fixed guideways systems, including transitways; • Stops on bus rapid transit routes or routes that run on high-occupancy vehicle lanes; or • Stops for a bus or other transit mode providing actual fixed route service at intervals of at least 15-minutes for at least five (5) hours during the peak hours of operations on weekdays. For areas outside of the one-half (½) mile walkshed, HB 1337 applies prescriptive regulations that restricts the amount of parking a city can impose for ADUs based on lot size. Refer to Table 4, Parking Requirements Applicable to ADU Development below. Table 4. Parking Requirements Applicable to ADU Development Lot size Maximum Parking That Can Be Required 6,000 sq. ft. or Less 1 parking space per dwelling unit 6,000 sq. ft. or Greater 2 parking spaces per dwelling unit Currently, Renton Municipal Code requires ADUs to provide a minimum of one (1) off-street parking space and allows for a maximum of two (2) ADU parking spaces, in addition to the parking requirements applicable to the principal dwelling. AGENDA ITEM #8. a) Page 11 of 14 #D-236 Page 8 of 10 March 13, 2025 Proposed Recommendation: Amend Renton Municipal Code to eliminate off-street parking requirements for ADUs when located within a one-half (½) mile walking distance of a major transit stop. Outside of the walkshed, staff proposes to continue to apply the existing requirement of one (1) parking space per ADU. VI. Building Conversions HB 1337 requires cities to allow ADUs to be converted from existing structures, including but not limited to detached garages, even if they violate current standards for setbacks and lot coverage. Renton Municipal Code provides flexibility for accessory building to ADU conversions, exempting accessory buildings from relevant development regulations (e.g., unit size, height, setbacks, etc.) if the structure was constructed prior to January 1, 2020, and has not been modified in a way that would increase nonconformance. Proposed Recommendation: Amend Renton Municipal Code to comply with the accessory building to ADU conversion requirements of HB 1337. Additionally, for internal ADUs, staff proposes allowing conversion units to occupy an entire floor area of the principal dwelling, up to 1,250 sq. ft., to efficiently use all the floor area. Conversions exceeding 1,250 sq. ft., including interior remodels, attached garages, and basement conversions are recommended to be classified as attached dwellings rather than ADUs. HB 1337 prohibits cities from imposing setback requirements for ADUs that are more restrictive than those applied to the principal dwelling. The existing ADU setback requirements in Renton Municipal Code are generally equivalent to or less restrictive than those imposed on single-family development. Refer to Table 5, Existing Setback Requirements Applicable to ADUs by Zoning Designation. See Table 5. Existing Setback Requirements Applicable to ADUs by Zoning Designation Minimum Setback Requirements by Zone Front Yard and Secondary Front Yard Setback – Applicable to All Zones The ADU shall be set back an additional 5 ft. parallel to and measured from the front facade of the primary structure and shall comply with the setbacks applied to the primary structure, as identified in RMC 4-2-110A, Development Standards for Residential Zoning Designations. ADUs shall not be permitted between the primary structure and the street unless approved in the Conditional Use Permit process. Side Yard Setback RC and R-1 25 ft. R-10 and R-14 5 ft. Greater than 9,000 sq. ft 4 ft. Rear Yard Setback Front Yard and Secondary Front Yard Setback – Applicable to All Zones 5 ft. When located within 10 ft. of the rear property line, at least 25% of the lineal length of the rear yard shall remain unoccupied from accessory dwellings, except when the rear property line abuts an alley. AGENDA ITEM #8. a) Page 12 of 14 #D-236 Page 9 of 10 March 13, 2025 Staff Recommendation: Amend Renton Municipal Code to comply with the setback requirements of HB 1337, which mandates that ADU setbacks must not be more restrictive than what is applied to principal dwellings. Staff recommends the following: • Attached ADUs shall comply with the principal dwelling setback requirements of the underlying zone. • When one (1) detached ADU is proposed, the ADU must comply with the front yard setback requirements of the underlying zone, as well as existing side yard and rear yard setback requirements. • When two (2) detached ADUs are proposed, one (1) ADU shall be eligible for the existing ADU side and rear yard setback requirements, while the second ADU must comply with the principal dwelling setback requirements of the underlying zone. VII. Building Height HB 1337 prohibits cities from establishing roof height restrictions on ADUs that are less than 24 ft. Under RMC 4-2-110C, ADUs are currently subject to the same maximum wall plate height as principal dwellings, as outlined in RMC 4-2-110A, Development Standards for Residential Zoning Designations (Primary Structures). For example, in the R-4 Zone, ADUs are allowed a maximum wall plate height of 32 feet (32’), which is the same height limit for principal dwellings in the same zone. Additionally, ADU height is regulated in relation to the height of the principal dwelling, preventing an ADU from exceeding the height of the principal dwelling, even when the development standards permit a greater height. This provision was introduced to preserve the subordinate relationship between the ADU and the principal dwelling, ensuring that ADUs do not overshadow principal dwellings or alter neighborhood character. Staff Recommendation: Amend Renton Municipal Code to comply with the provisions of HB 1337. Staff proposes establishing a maximum roof height limit of 24 feet (24’) for ADUs, measured to the highest point of a flat roof or the highest peak of a pitched roof. Principal dwelling height will continue to be measured to the wall plate. This proposal is intended to mitigate height disparities between ADUs and principal dwellings. PUBLIC ENGAGEMENT Given substantial changes associated with the pending legislative mandates, staff attended multiple public engagement events and coordinated other outreach efforts (e.g., announcements in This Week in Renton, social media posts, and informational counter cards distributed at local businesses). The objective was to inform the public about the required code amendments and, where feasible, gather feedback to incorporate into the local draft ordinance. Table 6. Public Engagement Summary Event Topic(s) Date Planning Commission HB 1110 3/20/24 Sustainability Fair HB 1110, HB 1337 4/20/24 AGENDA ITEM #8. a) Page 13 of 14 #D-236 Page 10 of 10 March 13, 2025 Rosie Rourke Home Show HB 1110, HB 1337 4/27/24 Neighborhood Event at Earlington Park HB 1110, HB 1337 5/11/24 Virtual Event – Online Open House #1 HB 1110 6/1/24 Renton Farmer’s Market HB 1110, HB 1337 6/4/24 Renton Farmer’s Market HB 1110, HB 1337 7/9/24 Renton Farmer’s Market HB 1110, HB 1337 8/13/24 Renton Farmer’s Market HB 1110, HB 1337 9/17/24 Renton Senior Expo at Don Persson Senior Center HB 1110, HB 1337 9/30/24 ADU Briefing: Current Requirements and Pending Amendments HB 1337 11/13/24 Virtual Event – Online Open House #2 HB 1110 3/1/25 Planning Commission Briefing HB 1110, HB 1337 3/19/25 Planning Commission Public Hearing HB 1110, HB 1337 4/2/25 Planning Commission Deliberations and Recommendation HB 1110, HB 1337 4/19/25 STAFF RECOMMENDATION Amend Renton Municipal Code, as described above, to comply with the requirements of HB 1110 and HB 1337. IMPACT ANALYSIS Effect on rate of growth, development, and conversion of land as envisioned in the Plan There are no anticipated effects on the rate of growth, development, and conversion of land envisioned in the Plan. Effect on the City’s capacity to provide adequate public facilities There are no anticipated effects on the City’s capacity to provide adequate public facilities. Effect on the rate of population and employment growth There are no anticipated effects on the rate of population and employment growth created by the proposed changes. Whether Plan objectives are being met as specified or remain valid and desirable Objectives of the Plan would remain valid and desirable. Effect on general land values or housing costs There are no anticipated effects on general land values or housing costs. Whether capital improvements or expenditures are being made or completed as expected There are no anticipated effects on capital improvements or expenditures created by the proposed changes. Consistency with GMA and Countywide Planning Policies The proposed amendments are consistent with the GMA and Countywide Policies. Effect on critical areas and natural resource lands There are no anticipated effects on critical areas and natural resource lands. AGENDA ITEM #8. a) Page 14 of 14