HomeMy WebLinkAboutSummary_Preapp_Mtg_PRE12-000014CITY OF RENTON
Department of Community & Economic Development
MEMORANDUM
DATE: February 23, 2012
TO: Pre-Application File No. PRE 12-014
FROM: Vanessa Dolbee, Senior Planner
SUBJECT: Additions & Alterations to Ace Aviation (289 E Perimeter Rd.)
General: We have completed a preliminary review of the pre-application for the above-
referenced development proposal. The following comments on development and permitting
issues are based on the pre-application submittals made to the City of Renton by the applicant and
the codes in effect on the date of review. The applicant is cautioned that information contained in
this summary may be subject to modification and/or concurrence by official decision-makers (e.g.,
Hearing Examiner, Planning Director, Public Works Administrator, Development Services Director
and City Council). Review comments may also need to be revised based on site planning and
other design changes required by City staff or made by the applicant. The applicant is encouraged
to review all applicable sections of the Renton Municipal Code. The Development Regulations are
available for purchase for $50.00 plus tax, from the Finance Division on the first floor of City Hall
or online at www.rentonwa.gov
Project Proposal
The subject property is at 289 East Perimeter Road at the Renton Municipal Airport. The applicant
has proposed to expand their existing multi-purpose aircraft hanger & corporate center for
general aviation customers. More specifically, the applicant is proposing to demolish all of the
existing facility with the exception of the 9,000 square foot hangar. The new structure would have
a footprint of 11,400 square feet for aircraft hanger and light maintenance activities associated
with general aviation. Also included in the new structure would be an avionics shop, machine
shop, area for light fabrication, general administrative offices, lobby, paint booth, two mezzanines
for parts storage, conference room and small apartment for temporary lodging. The new
corporate center is proposed to be a two story structure. However, the applicant may chose to
build a third story for additional parts storage or other uses. In addition to the re-constructed
building, the applicant has proposed a new detached storage building of approximately 3,500
square feet in size for temporary storage of floats. No changes are proposed to the site access,
which would remain off of E Perimeter Road.
Current Use: Currently the subject site is an operating Municipal Airport and the location of the
corporate center for Ace Aviation. A portion of the existing Ace Aviation building is proposed to
be demolished.
Additions & Alterations to Ace Aviation
February 23, 2012
Page 2 of 7
Development Standards: The project would be subject to RMC 4-2-130A, “Development
Standards for Industrial Zoning Designations” and the City of Renton’s Shoreline Master Program
(SMP) because the subject project is located near the Cedar River.
Zoning: The subject site is located within the Medium Industrial (IM) zoning designation. The site
is also located within the Employment Area Industrial Comprehensive Plan designation. The
proposed use would be an aviation-related use and would be considered accessory to the principal
use (Airport) which is a permitted use in the IM zone. The subject site is located within the
Shoreline High Intensity environment of Cedar River reach A.
Development Standards: The project would be subject to RMC 4-2-130A, “Development
Standards for Industrial Zoning Designations” (noted as “IM standards” herein). A copy of these
standards is included herewith.
Minimum Lot Size, Width and Depth – There are no minimum requirements for lot width or depth
within the IM zone, however, there is a minimum lot size requirement of 35,000 square feet. The
minimum lot size requirement is not applicable to the proposal, as the applicant is not proposing
land division.
Lot Coverage – There is no minimum lot coverage requirement within the IM zone, except for the
limitations imposed by the City’s landscaping requirements.
Setbacks – Setbacks are the distance between the building and the property line or any private
access easement. The required setbacks in the IM zone are as follows: 15 feet for the front yard
except a 50-foot setback is required if adjacent to a residential zone; 15 feet for the side yard
along a street; zero for the rear yard; and zero for the interior side yard. For the proposed project,
the front yard would be oriented towards East Perimeter Road. The proposal appears to comply
with all required setbacks.
Building Height – There is no maximum building height requirement within the IM zone. Although
the subject site is located within the Airport influence area, Safety Zone 5 and/or 6 “Sideline
Approach/Departure Zone” and/or “Traffic Pattern Zone” respectively. Height is restricted in
this area by the FAR Part 77 surface area, as such the applicant shall verify at time of land use
application and building permit that the height of the proposed structure does not penetrate the
FAR Part 77 surface area.
Parking – Street parking, loading areas and driveways shall be provided in accordance with the
provisions of the current parking regulations (enclosed).
The following ratios would be applicable to the site:
Use Square Footage of
Use
Ratio Required
Spaces
Airplane hangars,
tie-down areas
11,400 Parking is not required. Hanger
space or tie-down areas are to be
utilized for necessary parking.
N/A
Parking for offices
associated with
hangers
4,436 1 per 200 square feet of net floor
area
Min/Max:
22
Additions & Alterations to Ace Aviation
February 23, 2012
Page 3 of 7
Bicycle Parking Min/Max parking
spaces: 22
The number of bicycle parking
spaces shall be ten percent (10%)
of the number of required off-
street parking spaces.
Minimum -
2
The applicant is proposing to provide 12 parking spaces which is less than the minimum
requirement for parking. The applicant should be aware that the parking ratio is based on net
square footage; the total of all floor area of a building, excluding stairwells, elevator shafts,
mechanical equipment rooms, interior vehicular parking or loading, and all floors below the
ground floor, except when used for human habitation or service to the public. The applicant will
be required at the time of building permit application to provide a parking analysis of the subject
site.
If the proposal provides more or less parking than required by code, a request for a parking
modification would need to be applied for and granted. This detailed written request should be
submitted by the applicant along with or prior to the application for land use application.
It should be noted that the parking regulations specify standard stall dimensions of 9 feet x 20
feet, compact dimensions of 8½ feet x 16 feet, and parallel stall dimensions of 9 feet x 23 feet.
ADA accessible stalls must be a minimum of 8 feet in width by 20 feet in length, with an adjacent
access aisle of 8 feet in width for van accessible spaces. The appropriate amount of ADA
accessible stalls based on the total number of spaces must be provided. As proposed, the parking
lot on the west of the proposed building would have angled parking and one-way traffic. For 45
degree angle parking, the aisle width for one-way traffic shall be 12-feet wide and the parking
“area” shall be 20-feet wide for standard stalls and 17-feet wide for compact stalls measured from
the edge of the aisle to the curb.
All parking lots shall have perimeter landscaping and interior landscaping at a minimum ratio for
15 square feet per space. Please refer to landscape regulations (RMC 4-4-070F.6) for further
general and specific landscape requirements for parking areas (enclosed). The applicant will be
required at the time of building permit application to provide a landscaping analysis of the
subject site.
Refuse and Recycling Areas – Refuse and recycling areas need to meet the requirements of RMC 4-
4-090, “Refuse and Recyclables Standards” (enclosed).
Landscaping – Except for critical areas, all portions of the development area not covered by
structures, required parking, access, circulation or service areas, must be landscaped with native,
drought-resistant vegetative cover. Ten feet (10') of on-site landscaping is required along all
public street frontages, with the exception of areas for required walkways and driveways and
those zones with building setbacks less than ten feet (10'). Please refer to landscape regulations
(RMC 4-4-070 and RMC 4-4-080F.7) for further general and specific landscape requirements
(enclosed). A conceptual landscape plan and landscape analysis meeting the requirements in
RMC 4-8-120D.12, shall be submitted at the time of land use application.
Fences – If the applicant intends to install any fences as part of this project, the location must be
designated on the landscape plan. A fence detail should also be included on the landscape plan as
well.
Additions & Alterations to Ace Aviation
February 23, 2012
Page 4 of 7
Critical Areas: The City of Renton’s Critical Areas Maps indicate that the subject site is within the
vicinity of seismic hazards, flood hazards, and the Cedar River a Shoreline of the State.
The seismic hazard is related to potential liquefaction of soils during an earthquake event. A
geotechnical analysis for the site is required. The analysis needs to assess soil conditions and
detail construction measures to assure building stability.
A Flood Hazard Area; pursuant to the FEMA Flood Insurance Rate Maps (FIRM) the subject site
contains a Special Flood Zone AE (base flood elevation determined) which is classified as a 100-
year flood plain. The FIRM maps indicate the base flood elevation to be 26 feet Mean Sea Level
(MSL). Flood Hazard Data shall be submitted with formal land use application pursuant to RMC
4-8-120D. In addition, new industrial structures shall have the lowest floor, including basement,
elevated a minimum of one foot above the level of the base flood elevation. See RMC 4-3-050I for
further flood hazard information and requirements.
Because development is proposed within the floodplain, the applicant should address the issues
raised in the Final Biological Opinion And Magnuson-Stevens Fishery Conservation and
Management Act Essential Fish Habitat Consultation and propose mitigation for any anticipated
impacts as it would relate to the referenced publication, in the SEPA review for the project. The
SEPA checklist should be provided to the National Marine Fisheries Service (NMFS) and the
Federal Emergency Management Agency (FEMA) for their review and comment. In addition, a
Floodplain Biological Assessment shall be provided.
Shoreline Regulations: The objective of the High Intensity Overlay is to provide opportunities for
large-scale office and commercial employment centers as well as multi-family residential use and
public services. This district provides opportunities for water-dependent and water-oriented uses
while protecting existing ecological functions and restoring ecological functions in areas that have
been previously degraded. Development may also provide for public use and/or community use,
especially access to and along the water's edge.
RMC 4-3-090E.10.f addresses Aviation in the SMP, see regulations below:
ii. Airports:
(a) A new airport shall not be allowed to locate within the shoreline; however, an airport
already located within a shoreline shall be permitted.
(b) Upgrades of facilities to meet FAA requirements or improvements in technology shall be
permitted.
(c) Facilities to serve seaplanes may be included as an accessory use in any existing airport.
(d) Helipads may be included as an accessory use in any existing airport.
(e) Aviation-related manufacturing shall be permitted in an airport.
(f) New or upgraded airport facilities shall be designed and operated such that:
(1) All facilities that are non-water-dependent shall be located outside of shoreline
jurisdiction, if feasible. When sited within shoreline jurisdiction, uses and/or
developments such as parking, hangars, service buildings or areas, access roads,
utilities, signs, and storage of materials shall be located as far from the land/water
interface as feasible. The minimum setback shall be twenty feet (20') from the
Additions & Alterations to Ace Aviation
February 23, 2012
Page 5 of 7
OHWM of the shoreline and shall be designed and spaced to allow viewing of
airport activities from the area along the water’s edge.
(2) New or upgraded airport facilities shall minimize impacts on shoreline
ecological functions, including control of pollutant discharge. The standards for
water quality and criteria for application shall be those in current stormwater
control regulations.
(3) New facilities dispensing fuel or facilities associated with use of hazardous
materials shall require a Shoreline Conditional Use Permit.
Development Standards within Shoreline Jurisdiction:
For non-water oriented uses, the minimum structure setback from the Ordinary High
Water Mark (OHWM) is 100 feet; however, this setback can be reduced to 75 feet.
Height: For buildings allowed waterward of one hundred feet (100') from OHWM through a
modified setback, the maximum building height shall be as follows:
i. Between the modified setback line and the line lying parallel to and one
hundred feet (100') from OHWM, the maximum building height shall be defined by
a maximum allowable building height envelope that shall:
(a) Begin at a height of thirty five feet (35') along the line of the modified
setback; and
(b) Have an upward, landward transition at a slope of one vertical to one
horizontal from the beginning height either until the line at which the
maximum height allowed in the underlying zoning in chapter 4-2 RMC is
reached (from which line the height envelope shall extend landward at the
maximum height allowed in the underlying zoning) or to the line lying
parallel to and one hundred feet (100') from OHWM, whichever comes first;
and
ii. Landward of one hundred feet (100') from OHWM, the applicant shall have the
option of choosing the maximum building height defined by either:
(a) Using the maximum allowable building height envelope described in
Table 4-3-090D7a, Table Note 8.a; or
(b) Having the maximum allowable building height envelope described in
above, continue an upward, landward transition at a slope of one vertical to
one horizontal from the envelope’s height along a line lying parallel to and
one hundred feet (100') from OHWM either until the line at which the
maximum height allowed in the underlying zoning in chapter 4-2 RMC is
reached (from which line the height envelope shall extend landward at the
Additions & Alterations to Ace Aviation
February 23, 2012
Page 6 of 7
maximum height allowed in the underlying zoning), or to the end of
shoreline jurisdiction, whichever comes first.
Vegetation Conservation Buffer: Exemption Criteria, As determined by the Administrator of
the Department of Community and Economic Development or designee, for development
proposed on sites separated from the shoreline by intervening, and lawfully created,
public roads, railroads, other off-site substantial existing improvements, or an intervening
parcel under separate ownership, the requirements of this Code for a vegetation buffer
may be waived. For the purposes of this Section, the intervening lots/parcels, roads, or
other substantial improvements shall be found to:
i. Separate the subject upland property from the water body due to their
height or width; and
ii. ii. Substantially prevent or impair delivery of most ecological functions from
the subject upland property to the water body.
Based on the criteria above, it appears the subject site would be exempt from the Vegetation
Conservation Buffer.
Environmental Review: SEPA review will be required, because the size of the proposed
development exceeds 4,000 square feet and 20 parking spaces.
Permit Requirements: The proposal would require Shoreline Substantial Development Permit
(SSDP) and Environmental Review SEPA. This permit would be reviewed in an estimated
timeframe of 6 - 8 weeks with an additional 21-day review period for the SSDP with the
Washington State Department of Ecology. The fee for the SSDP is $2,000.00 and $1,000.00 for the
Environmental Review. Please note that each of these land use permits has an additional 3
percent Technology Surcharge Fee.
In addition to the required land use permit, separate construction, building and sign permits
would be required. The review of these permits may occur concurrently with the review of the
SSDP and SEPA, but cannot be issued prior to the completion of any appeal periods.
Impact/Mitigation Fees: In addition to the applicable building and construction fees, the following
mitigation fees would be required prior to the issuance of building permits. Impact fees, which
would replace mitigation fees, may be adopted prior to building permit approval for which an
applicant may vest to impact/mitigation fees. Those fees have yet to be determined. Currently fees
are the following:
A Transportation Mitigation Fee based on $75.00 per new daily trip attributed to the
development; and
A Fire Mitigation Fee based on $0.52 per new building square foot for commercial uses.
A handout listing all of the City’s Development related fees in attached for your review.
Additions & Alterations to Ace Aviation
February 23, 2012
Page 7 of 7
*Once the application materials are complete, the applicant is strongly encouraged to
have one copy of the application materials pre-screened at the 6th floor front counter prior to
submitting the complete application package. Please call for an appointment.
cc: Jennifer Henning
FIRE & EMERGENCY SERVICES DEPARTMENT
M E M O R A N D U M
DATE:February 15, 2012
TO:Vanessa Dolbee, Senior Planner
FROM:Corey Thomas, Plans Review Inspector
SUBJECT:Ace Aviation Additions and Alterations
1. The preliminary fire flow requirement is 3,750 gpm based on a fully fire
sprinklered building including all existing areas that are retained. A
minimum of four fire hydrants are required. One fire hydrant is required
within 150-feet of the proposed building and three hydrants are required
within 300-feet. One hydrant is required within 50-feet of the fire
department connections. Existing hydrants can be counted toward the
requirements as long as they meet current code. Looped fire mains are
required all around the building when fire flows exceed 2,500 gpm.
2. The fire mitigation impact fees are currently applicable at the rate of
$0.52 per square foot of commercial area. Credit will be granted for the
existing buildings to be removed.
3. An approved fire alarm, fire sprinkler system and dry standpipe system
are required throughout the buildings both new and existing. Separate
plans and permits are required to be submitted to the Renton Fire
Department for review and permitting. Fire alarm system shall be fully
addressable and full detection is required. A fire alarm system shall also
be required in the proposed float storage building. A direct outside door
is required to the fire sprinkler riser control room.
4. Fire department apparatus access roads are required to be a
minimum of 20-feet wide with 25-feet inside and 45-feet
outside turning radius.
5. All buildings equipped with an elevator in the City of Renton are required
to have at least one elevator meet the size requirements for a bariatric
size stretcher. Car size shall accommodate a minimum of a 40-inch by
84-inch stretcher and car width shall be a minimum of 80-inches wide
with a center opening door.
6. Applicant shall submit a completed Hazardous Material Inventory
Statement prior to building permit issuance. Use of city form or approved
equivalent is required.
h:\3000 crr\3200 tech svcs\plans review-inspector\preapps\ace.doc
7. An electronic site plan is required to be submitted to the Renton Fire
Department for pre-fire planning purposes prior to occupancy of the
building. See below for the format in which to submit your plans.
In an effort to streamline our pre-fire process, we are requesting that you submit a site
plan of your construction project in one of the following formats which we can then
convert to VISIO.vsd. This is required to be submitted prior to occupancy.
ABC Flowcharter.af3
ABC Flowcharter.af2
Adobe Illustrator File.ai
AutoCad Drawing.dwg
AutoCad Drawing.dgn
Computer Graphics Metafile.cgm
Corel Clipart Format.cmx
Corel DRAW! Drawing File Format.edr
Corel Flow.cfl
Encapsulated Postscript File.eps
Enhanced Metafile.emf
IGES Drawing File Format.igs
Graphics Interchange Format.gif
Macintosh PICT Format.pct
Micrografx Designer Ver 3.1.drw
Micrografx Designer Ver 6.0.dsf
Microstation Drawing.dgn
Portable Network Graphics Format.pnf
Postscript File.ps
Tag Image File Format.tif
Text.txt
Text.csv
VISIO.vsd
Windows Bitmap.bmp
Windows Bitmap.dib
Windows Metafile.wmf
Zsoft PC Paintbrush Bitmap.pcx
`
DEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
M E M O R A N D U M
DATE:February 22, 2012
TO:Vanessa Dolbee, Planner
FROM:Arneta Henninger, Plan Review
SUBJECT:ACE AVIATION ADDITIONS & ALTERATIONS
289 E. PERIMETER ROAD
PRE 12-014
NOTE: The applicant is cautioned that information contained in this summary is preliminary and non-
binding and may be subject to modification and/or concurrence by official city decision-makers. Review
comments may also need to be revised based on site planning and other design changes required by
City staff or made by the applicant.
I have completed a preliminary review for the Ace Aviation proposal to expand their existing multi-
purpose aircraft hanger & corporate center multi-story building, located in Sect. 7 Twp. 23N, Rng 5 E.
The following comments are based on the pre-application submittal made to the City of Renton by the
applicant.
Water
This site is located in the City of Renton water service area.
The site is not located in the Aquifer Protection Zone.
There is an existing 8-inch DI water main and a 12-inch DI water main located in the vicinity. See
City of Renton drawing number W 0455 and W 0804 and W 2087.
The site is located in the 196 water pressure zone.
Per the City of Renton Fire Marshal, the preliminary fire flow requirement is 3,750 gpm based on a
fully fire sprinklered building including all existing areas that are retained.
The maximum available capacity from the existing city water system in vicinity of the development
site is 2,500 gpm from the existing 8-inch and 12-inch water mains in E. Perimeter Road, and from
the existing 8-inch water main along the northwesterly side of the existing building. The static water
pressure is approximately 68 psi at finished grade elevation 30 feet.
The existing system cannot deliver the preliminary required fire flow for the redevelopment project.
The City of Renton Water Utility has provided the following information on what is required to serve
the proposed project:
1. In order to increase the flow capacity of the above existing 12-inch water line in E. Perimeter Rd.
to deliver the required fire flow, a section of approximately 120 feet of the existing 8-inch water
main in the roadway must be replaced with a larger 12-inch pipe and be connected to the existing
12-inch water line in Logan Ave N.
ACE AVIATION– PRE 12-014
Page 2 of 2
February 22, 2012
H:\CED\Planning\Current Planning\PREAPPS\12-014.Vanessa\Plan Review Comments PRE 12-014.doc
2. Additional fire hydrants may required, one hydrant for every 1,000 gpm of fire flow demand. The
number and final location of the hydrants shall be determined based on the final site plan and
access. Existing fire hydrants need to be brought up to current code if not existing.
3. There is an existing 8-inch backflow prevention assembly (DDCVA) for the existing fire sprinkler
system. The applicant shall verify with a fire sprinkler designer to confirm if the existing assembly
can remain at its current place or if a new and/or larger assembly is required at a different
location.
4. There is an existing 3/4-inch domestic water meter to the existing building. The applicant shall
verify the size for the required domestic meter for the new building based on the Uniform
Plumbing Code meter sizing criteria.
5. A reduced backflow prevention assembly (RPBA) will be required for the domestic water meter.
The RPBA shall be installed inside a “hot-box” per City standard details.
6. The water System Development Charges are based on the size of any and all water meters if a new
meter is required or an existing meter is upsized. These fees are collected at the time a
construction permit is issued then prior to the issuance of the building permit. Credit will be given
for the existing meter.
Sanitary Sewer
There is an existing 24” sanitary sewer main in the vicinity of this project proposal site.
The project will need to show the location of the existing sidesewer connection from the buildings to
the main.
The project needs to show the location of the oil separator. If one does not exist, the project will be
required to install a new oil water separator.
Wastewater system development charges are based on the size of the domestic water meters.
Storm Drainage
There are existing storm drainage conveyance pipes and facilities on site.
A storm drainage report will be required. All storm drainage shall be in compliance with the City of
Renton amendments to the 2009 King County Surface Water Drainage Manual.
The project will need to show how the new addition and new paving will handle the storm runoff.
Stormwater System developments are 0.405 per square foot of new impervious surface area but not
less than $1,012.
Street Improvements
Additional street improvements will not be required.
Traffic Mitigation fees may apply.
General Comments
All required utility, drainage, and street improvements will require separate plan submittals
prepared according to City of Renton drafting standards by a licensed Civil Engineer.
All plans shall be tied to a minimum of two of the City of Renton Horizontal and Vertical Control
Network.
Permit application must include an itemized cost estimate for these improvements. Half of the fee
must be paid upon application for building and construction permits, and the remainder when the
permits are issued. There may be additional fees for water service related expenses. See Drafting
Standards.
H:\File Sys\WTR - Drinking Water Utility\WTR-17 - Water Availability-Pre-Application-Building Permits
review\WTR-17-2011-Water Availability\pre-appl-11-014-Heritage-Hills-Apts.doc\AG
PLANNING/BUILDING/
PUBLIC WORKS DEPARTMENT
M E M O R A N D U M
DATE:February 20, 2012
TO:Arneta Henninger, Development Services Project Manager
FROM:Abdoul Gafour, Water Utility Engineering Supervisor
SUBJECT:Pre-application No. 12-014 – Alterations and Addition to
ACE Aviation at 289 E. Perimeter Road within Renton Municipal
Airport
The preliminary fire flow demand for the proposed project as determined by Renton
Fire Marshal is 3,750 gallons per minute (gpm) based on a fully fire sprinklered building.
The maximum available capacity from the existing City’s water system in vicinity of the
development site is 2,500 gpm from the existing 8-inch and 12-inch water mains in E.
Perimeter Road and from the existing 8-inch water main along the northwesterly side of
the existing building. The static water pressure is approximately 68 psi at finished grade
elevation 30 feet.
As such the existing system cannot deliver the preliminary required fireflow for the
redevelopment project.
1. In order to increase the flow capacity of the above existing 12-inch water line in E.
Perimeter Rd. to deliver the required fireflow, a section of approximately 120 feet of
the existing 8-inch water main in the roadway must be replaced with a larger 12-inch
pipe and be connected to the existing 12-inch water line in Logan Ave N.
2. Additional fire hydrants may required, one hydrant for every 1,000 gpm of fire flow
demand. The number and final location of the hydrants shall be determined based
on the final site plan and access.
3. There is an existing 8-inch backflow prevention assembly (DDCVA) for the existing fire
sprinkler system. The applicant shall verify with a fire sprinkler designer to confirm if
the existing assembly can remain at its current place or if a new and/or larger
assembly is required at a different location.
4. There is an existing 3/4-inch domestic water meter to the existing building. The
applicant shall verify the size for the required domestic meter for the new building
based on the Uniform Plumbing Code meter sizing criteria.
5. A reduced backflow prevention assembly (RPBA) will be required for the domestic
water meter. The RPBA shall be installed inside a “hot-box” per City standard details.
6. A separate water meter and backflow prevention assembly (DCVA) is required for the
landscape irrigation system.
7. The development is subject to the City’s water system development charges per
Renton Municipal Code (RMC4-1-180C), if additional or larger size meters are
needed.
8. The development is subject to applicable City’s plan review and inspection fees.
H:\File Sys\WTR - Drinking Water Utility\WTR-17 - Water Availability-Pre-Application-Building Permits
review\WTR-17-2012-Water Availability and Pre-Application Reviews\Pre-Application 2012\pre-appl-12-
014-ACE Aviation.doc\AG
9. Civil plans for the water main improvements shall be prepared by a professional
engineer registered in the State of Washington and shall meet the City’s standards.
CC: Vanessa Dolbee