5C - Concept Review LUR2003-00028 at TargetCITY OF BOULDER
PLANNING BOARD AGENDA ITEM
MEETING DATE: May 22, 2003
(Agenda Item Preparation Date: May 8, 2003)
AGENDA TITLE:
Public hearing and consideration of a Concept Review #LUR2003-00028 to construct a 17,126
square foot addition to the front (west side) of the existing Target retail store, resulting in a total
of135,727 square feet. The concept plan includes redesigned drives, parking and ]andscaped
areas, and conceptual architectural elevations.
Applicant: CBI Engineering Assoc. Inc.
Owner: Target Corporation
REQUESTING DEPARTMENT:
Planning Department
Peter Pollock, Planning Director
Bob Cole, Land Use Review Manager
Elizabeth Hanson, Senior Planner
OVERVIEW:
The proposed expansion of Boulder's Target store requires completion of the concept review
process because the development exceeds the "Site Review Required" thresholds in Section 9-4-
11(b), B.R.C. 1981 for the RB-E zoning district (the site size exceeds three acres and the
building size exceeds 50,000 square feet of floor area). A site review amendment would be the
next step following the review of this concept plan.
STATISTICS:
Proposal: Construct a 17,126 square foot addition to the front (west side) of
the existing Target retail store, resulting in a total of 135,727
square feet. The concept plan includes redesigned drives, parking
and landscaped areas, and conceptual architectural elevations.
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Project Name:
Location:
Size of Tract:
Zoning:
Comprehensive Plan:
KEY ISSUES:
Target
2800 Peazl Street
10.29 acres
RB-E, Regional Business - Established
Regional Business and Open Space
Is the location and size of the proposed buildinti addition appropriate?
Does the proposed site plan generally meet the objectives of the Boulder Valley Regional
Center (BVRC) Transportation Connections Plan?
Do the conceptual architectural plans show a redesigned building fapade that would
improve the appearance of the building and be consistent with the surrounding area?
BACKGROUND:
The Target store at 2800 Pearl Street is one of Boulder's largest retailers and is located in the
Boulder Valley Regional Center (BVRC). Two additions have been made to the origina197,879
square foot store - a 12,485 square foot addition to the south in 1990 and a 7,622 square foot
addition to the north in 1993. Each of these additions were reviewed and approved as a PUD
amendment or site review amendment.
The site and building sizes exceed the site review threshold, thereby requiring a concept plan
review for this addition. There is a code exception that applies to "building permits for additions
to existing structures that do not exceed a cumulative total, over the life of the building, of 25%
percent of the size of the building on which the addition is proposed and that do not alter the
basic intent of an approved development." City records indicate that the cumulative previous
and proposed additions to the Target store exceed 25% percent of the size of the original building
(38% of the origina197,879 square foot store). Therefore, the exception ~~rovision does not
apply and this concept plan review is required.
SUMMARY:
The purpose of the concept plan review step is to determine a general development plan for the
site, including:
land uses and arrangement of uses
general circulation patterns and characteristics
methods of encouraging use of alternative transportation modes
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• areas of the site to be preserved
• general architectural characteristics
• special height and view corridor limitations
• envirorunental preservation and enhancement concepts
• other factors as needed to cany out the objectives of the land use regulations, adopted
plans, and other city requirements.
City staff s analysis of the concept plan objectives as they relate to this proposal is in
Attachment A. A copy of the Development Review Results and Comments are in
Attachment B. The Planning Board should note that the comments in Attachment B reflect an
analysis of TargeYs original concept plan submittal. Following issuance of staff comments,
Target submitted a revised concept plan for Planning Board review that responds to staff's
comments. This staff inemorandum references the revised concept plan included in the Board's
packet. A vicinity map is provided in Attachment C and the applicant's plans and written
statements are in Attachment D.
1. Is the location and size of the proposed building addition appropriate?
In two pre-application meetings, city staff discussed several options for a building
addition with TargeYs engineering consultants. The proposed expansion of the Target
store to the west results. in several site improvements. The addition results in a
realignment of the main north-south internal drive to the west. This new alignment
results in a relocation of the Pearl Street entry drive further west, allowing for additional
separation from the Crossroads Commons entry drive. The new north-south drive
alignment also is better aligned with the 29'~' Street alignment on the BVRC Connections
Plan and with the proposed "29`h Street" on the pre-application plans far the Crossroads
redevelopment. City staff has provided Target and Westcor with each other's contact
information and preliminary plans and coordination between the designers of these
adjacent projects has begun.
2. Does the proposed site plan generally meet the objectives of the Boulder Valley
Regional Center (BVRC) Transportation Connections Plan?
The BVRC Transportation Connections plan was adopted in 2002. The Target concept
plan is one of the first BVRC redevelopment plans to be reviewed since its adoption.
Given the level of proposed Target redevelopment (building addition), only the elements
internal to the site would be required to be constructed. However, accommodations must
be made for the external improvements.
Staff reviewed the Target concept pian for consistency with the BVRC Transportation
Connections plan (a complete staff analysis is included in Attachment B). Key concepts
in the connections plan and the applicanYs response include:
• 29`h Street alignment for pedestrian, bicycle, and vehicular access and
connectivity (along the west sides oF Crossroads Mall and Target)
The plan notes that coordination has begun with Westcor-Macerich to design the
29`n Street connection. The concept plan shows a 12 foot wide multi-use path
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consistent with the BVRC plan. Additional details and alignment will be resolved
al the time of site review.
• A regional transit "superstop" at the southeast corner of 28`" and Pearl
Streets
The concept plan reserves an area at the northwest corner of the site for a future
transit superstop.
• A multi-use path along Pearl and 28~h Streets
These paths are existing and no change is proposed or required.
• A multi-use path along the north side oF Walnut Street
No change is proposed to this existing path on the adjacent Crossroads property.
• Pedestrian connections to a future "transit village" (train and bus service,
housing) at t6e northeast corner of Pearl and 30~h Streets (possibly with a
pedestrian and bicycle connection along the ditch at the rear of the Target
store); and,
The concept plan includes a note acknowledging the BVRC plans for this off-site
connection.
• A north-south pedestrian and bicycle connection along the back of the
building
The concept plan acknowledges the BVRC plans for this connection by reserving
the availabiliry of this area in the future.
• An east-west pedestrian and bicycle connection through the parking area
and along the north side of the building
The concept plans shows a newll foot wide path through the parking area and an
eight foot wide multi-use path along the north side of building. The eight foot
wide section of the path may need to be designed at a 12 foot width on the site
review plans.
3. Do the conceptual architectural plans show a redesigned building fagade that would
improve the appearance of the building and be consistent with the surrounding
area?
The concept plan submittal includes a colored conceptual drawing of the west (front)
elevation of the expanded Target store. The building's color and style is generally
consistent with other large retailers in the BVRC, including Crossroads Mall anchors and
Crossroads Commons to the north. Target is developing a prototype architectural design
for several stores nationwide that will be renovated. The conceptual drawing shows an
updated style with more varied materials and colors than the existing building. The entry
area would include more glass and the faqade shows new roof lines and varied wall
planes. Staff has requested that the applicant provide more information about the
proposed planters, shopping cart storage, and signage at the time of site review
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application. Fapade articulation, materials detailing, and additional windows to help
create a pedestrian scale are also encouraged.
BOULDER URBAN RENEWAL AUTHORITY REVIEW:
The Boulder Urban Renewal Authority (BiJRA) Board is scheduled to review and comment on
this application on Wednesday, May 21, 2003. A report on the BURA Board's comnients will
be included in the presentation to the Planning Board at its May 22, 2003 meeting.
Approved By:
~
`~'~:~'." 1~-~-~=~ ~v~..
Pet r Pollock, Planning Director
ATTACHMENTS:
Attachment A: Concept Plan Objectives
Attachment B: Development Review Results and Comments, dated April
25, 2003
Attachment C: Vicinity Map
Attachment D: Applicant's written statement and plans
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ATTACHMENT A
CONCEPT PLAN REVIEW AND COMMENT
Guidelines for Review and Comment
The following guidelines will be used to guide the planning board's discussion regarding the site.
It is anticipated that issues other than those listed in this section will be identified as part of the
concept ptan review and comment process. The Planning Board may consider the following
guidelines when providing comments on a concept plan.
1) Characteristics of the site and surrounding areas, including, without limitation, its location,
surrounding neighborhoods, development and architecture, any known natural features of the
site including, without limitation, mature trees, watercourses, hills, depressions, steep slopes
and prominent views to and from the site;
The site is at the corner of 28th and Pearl Streets, a key intersection in the Boulder Valley Regional
Center (BVRC) and adjacent to Crossroads Mall. 28th Street will soon be a major regional transit
corridor, with RTD bus service to Denver/DIA and this site has been discussed as a potential transit
superstop. A 118,601 square foot retail building is on the site, and the parking area does not meet
current parking and landscape standards. There is a considerable grade difference between the
Target and Crossroads Mall sites. There are significant mountain views from the site.
2) Community policy considerations including, without limitation, the review process and likely
conformity of the proposed development with the Boulder Valley Comprehensive Plan and
other ordinances, goals, policies, and p~ans, including, without limitation, sub-community and
sub-area plans;
Development of this site must be consistent with the BVRC urban renewal plan, guidelines, and
Transportation Connections plan. Redevelopment of this property supports several of the city's
economic goals.
3) Applicable criteria, review procedures, and submission requirements for a site review;
A site review application must show compliance with applicable site review criteria, including criteria
for any requested code variations. A site review application also must demonstrate compliance with
BVRC guidelines and plans. The application may be reviewed by the BURA Board and, if required
based on the project, the Planning Board.
4) Permits that may need to be obtained and processes that may need to be completed prior to,
concurrent with, or subsequent to site review approval;
A Technical Document Review will be required for final architectural/sitellandscape plans, any final
engineering or utility plans, and right-of-way or easement dedications. A building permit application
wouid follow.
5) Opportunities and constraints in relation to the transportation system, including, without
limitation, access, linkage, signalization, signage, and circulation, existing transportation
system capacity problems serving the requirements of the transportation master plan,
possible trail links, and the possible need for a traffic or transportation study;
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The site review application should demonstrate vehicular and pedestrian/bicycle connections
between the site and adjacent properties. Significant opportunities will exist for connections to the
new 28th Street regionai transit corridor. The applicant is strongly encouraged to discuss providing
opportunities for a future transit "superstop" in this project with Public Works staff. A sign program
would be a ~ondition of site review approvai.
6) Environmental opportunities and constraints including, without limitation, the identification of
wetlands, important view corridors, fioodplains and other natural hazards, wildlife corridors,
endangered and protected species and habitats, the need for furthgr biological inventories of
the site and at what point in the process the info~mation will be necessary;
There are significant view corridors to the mountains from this site.
7) Appropriate ranges of land uses; and
The site, designated RB-E and Regional Business, is an appropriate site for a wide range of
commercial Iand uses, including retail, personal service, and o~ce uses. Expansion of a successful
large retailer in the BVRC is appropriate and encouraged.
8) The appropriateness of or necessity for housing.
This site has been considered an appropriate housing site (e.g. ~; ossroads Framework Plan) due to
its proximity to the proposed transit village at 30~h and Pearl and the adjacency to major bus routes.
However, these scenarios were looked at if the site redevelopea .,nd Target relocated from this
property. Given TargeYs interest to expand the existing store on-::ste, future phases of redevelopment
might be conducive to adding housing to the site (e.g. second floor residential).
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ATTACHMENT B
CITY OF BOULDER
LAND USE REVIEW RESULTS AND COMMENTS
DATE OF COMMENTS: April 25, 2003
CASE MANAGER: Liz Hanson
PROJECT NAME: TARGET
LOCATION: 2800 PEARL ST
COORDINATES: N03W04
REVIEW TYPE: Concept Plan Review & Comment
REVIEW NUMBER: LUR2003-00028
APPLICANT: K.K. YEOW
DESCRIPTION: CONCEPT PLAN REVIEW AND COMMENT: Construct a 17,126 s.f.
addltion to the front (west side) of the existing Target retail store,
resulting in a total of 135,727 s.f. The concept plan includes redesigned
drives, parking and landscaped areas and conceptual architectural
elevations.
I. REVIEW FINDINGS
Planning and Boulder Urban Renewal Authority (BURA) staff strongly supports TargeYs proposed
expansion of its Boulder store. The Boulder Target store has been an important part of the Boulder's
regional shopping area, meeting a wide variety of Bouider area shoppers' needs. The Target expansion
is part of a continuing trend of the redevelo~ment of other commercial sites in the city's urban renewal
area, particularly on the 28`h, Pearl, and 30 Street corridors. Expansion of the existing building and
redevelopment of the parking area opens new opportunities to improve vehicular, bicycle, and pedestrian
connections through and across the site. A redesigned building fapade allows for an updated look and
design. The staff comments below include suggestions for refining the Concept Plan and preparing for
the next step, a Land Use Application for a site review amendment. The application has been scheduled
for the May 22, 2003. Planning Board meeting.
CITY REQUIREMENTS
AccesslCirculation
As part of TargeYs plan materials for BURA and Planning Board review, please revise the Context Plan to
include the shopping area on the north side of Pearl between 28th and 30~h (Crossroads Common). The
Context Plan helps staff, the applicant, and City officials evaluate how the site relates to its surroundings,
particularly in regard to on-site and cross-site connections and adjacent street crossings. Marie Zuzack,
BURA, 303-441-4278
Off-site connections
As noted in the pre-application discussions with the applicant, staff reviewed the Target concept plans for
consistency with Boulder Valley Retail Center (BVRC) Transportation Connections Plan. Key concepts in
this plan include: the 29'h Street alignment for pedestrian, bicycle, and vehicular access and connectivity
(along the west sides of Crossroads Mall and Target); a multi-use path along Pearl and 28~h Streets; a
multi-use path along the north side of Walnut, pedestrian connections to a future "transit village" (train and
bus service, housing) at the northeast corner of Pearl and 30~^ Streets (possibly with a pedestrian and
bicycle connection along the ditch at the rear of the Target store); and a north-south pedestrian and
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bicycle connection along the back of the store. Only the elements internal to the site would be expected
to be constructed Y,vith this level of redevelopment, however accommodations must be made for the
external improvements. These external improvements, and strategies to plan for those, are:
• 28'" 8 Pearl Transi? ;"superstop: The corner will have a pedestrian refuge that will also
accommodate a bus stop and the curb line wili need to be moved back to creat~-: a right-turn
bypass lane. The curb and sidewalk along Pearl and 28'h would need to be maved back
cioser toward the parki»:~ 1ot. Target would not be responsible for this improvement but
instead wili need to pre : ve an area at the corner for a future city project. In general, the
area would be reserved rar improvements is the area outside of the existing parking lot up to
where the right-turn deceleration begins on Pearl and to where the sidewalk begins to curve
around the ditch on 28'" Street. City staf? Nill be available as needed to help the applicant
understand the design o~ ;s corner.
• The BVRC Connections Plan shows a multi-use path in the area behind Target. The
proposed level of development would not warrant a requirement for Target to construct this
improvement. In order to communicate this properly, a note should be added to the plan that
indicates that this general are: ; a potential connection. In the future the city may negotiate
with Target and other property owners in the area to obtain an easement based on the design
of this improvement.
• Along with any changes to the parking lot north of the building, the east-west multi-use path
shown on these plans would need to continue to the east side of the property. If no changes
are proposed in this location with this expansion, this path will not need to be constructed at
this time. The applicant should however be aware of this requirement for future planning.
Steve Durian, Transportation Engineer, 303-441-4943
29"' Street alianment and Crossroads Redeveiopment Plans
Pre-application meeting drawings for Crossroads submitted by Westcor-Macerich (see attached) to the
city on April 10, 2003 show a realigned "29th StreeY' that appears to closely align with the proposed new
Target driveway. Coordination of the circulation plans for these two important commercial sites is critical,
particularly since redevelopment of the two properties may be on somewhat different time schedules.
City staff is available to assist with coordination to find the best possible solution. Staff also encourages
the applicant to contac? Darrell Beach, Westcor, 602-953-6233 to discuss these circulation issues,
including 29~" StreeU cirive alignment, grade changes, possible future Walnut re-alignment, and bicycle
and pedestrian connections between the two sites.
The proposed realignment of the north-south driveway through the Target site better aligns the drive with
preliminary plans to realign the main north-south driveway on the adjacent Crossroads Mall site to the
south. The area where 29~" Street nnd the truck dock does not function well as shown and will need to be
given more thought. Staff's sugges.,on is to better emphasize the through movement with additional
curbs and have the truck dock inte -:-~r,t this alignment in a T-intersection alignment. Another option would
be to work with Crossroads to rel~, ..:e the connection between these two sites in line with the alignment
established on this plan rather than curving the road further to the west.
The BVRC connections plan specifies a multi-use path aligned north-south along the 29'h Street
alignment. An 8 foot width was identified in the pre-application meeting, however after further reviewing
the BVRC plan, the width is 12 fee:. In order to help achieve this, staff would recommend a separate
north-south parking lot circulation aisle further to the west and a stron~er bike/pedestrian path on the west
side of 29~h Street with fewer curb cuts between the parking lot and 29 h Street. An alignment on the east
side of 29`h Street may also be considered. Whether this path occurs on the east or the west side, the
alignment should be coordinated with the Crossroads development to the south that that the path would
not need to cross the roadway.
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Pearl Street access
The proposed new Pearl Street access appears to be at an acceptable location in terms of impacts to the
Pearl & 28`h intersection. Some restriping of the median area will be required. Left-turns exiting onto
Pearl will not be permitted, as is the case currently. The median shown on the plan will need to be
modified to resemble ihe median that exists today. Steve Durian, 303-441-4943
28'h Street access
The 28~h Street access could be modified to become more compact thereby creating more space for
expanding the parking toward 28~" Street. Steve Durian, 303-441-4943
On-site circulation
During the pre-application discussions, staff discussed several options to the proposed vehicular and
pedestrian circulation plan. These options included enhancing pedestrian/bicycle connections by the
proposed sidewalk from the store entry to 28'h Street. Landscaping added to this island would help to
meet city landscape standards while enhancing the major pedestrian connection. Converting some
standard parking spaces to compact size spaces would also open opportunities for more landscape
material. City staff also recommended adding a second or third pedestrian crossing area (with an
extended curb, paving treatment and signage) along the middle and south end of the west building
fa~ade. Steve Durian, 303-441-4943
The applicanPs Concept Plan shows a widened east-west pathway, but without landscape material. Also,
all of the spaces abutting this pathway are now either compact spaces or handicap accessible spaces.
Staff encourages the applicant to more widely distribute both types of parking spaces. This connection
also is not of consistent width. A consistent 12 foot width needs to carry all the way through the parking
lot. Steve Durian, 303-441-4943
Please reexamine the placement of the new second pedestrian crossing for the north-south driveway. It
appears that its placement near the entry drive from the south may result in conflicts. Also, please
provide additional information regarding the treatment of this pedestrian crossing (materials, grade,
signage) at the time of site review application. Steve Durian, 303-441-4943
The BVRC Connections Plan also shows a proposed multi-use path through the current parking lot
connecting a future underpass on 28`" Street to the existing Walnut multi-use path. Construction,
dedication or reservation for this path is not requested at this time, however future redevelopment may
need to accommodate this connection. Marie Zuzack, BURA, 303-441-4278
Transportation Demand Manaqement
With a Site Review, Transportation Demand Management (TDM) strategies must be identified. TDM is a
set of strategies to reduce the number of single passenger vehicle trips to the site. In the case of a retail
employer, these efforts should focus on employees. The applicant will need to provide information on
what TDM strategies will be provided at the time of Site Review. Several strategies are well suited for this
site:
. Providing an employee Eco-pass program would relate well to the ample transit opportunities in
the area. This cost approximately $50 per employee per year.
• Providing a parking cash-out program. This program would pay employees perhaps a dollar per
day not to drive.
• Becoming part of a Transportation Management Organization (TMO). A TMO would be an
organized group of businesses that would promote an enhance TDM efforts area-wide. Although
a TMO currently does not exist in this area, it could be started by Target and include many other
businesses in the Crossroads area. City staff are available to help plan and implement a TMO.
Steve Durian, 303-441-4943
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No concerns with access from Fire. Ron Mahan 303-441-4356
Building and Housing Codes
The City of Boulder currently follows the 1997 Uniform Building Code. The existing building has been
classified as a Type III-N building for construction purposes. Section 505.2 of the building code allows
unlimited floor area of an M occupancy as long as there is maintained a 60 foot distance from tMe building
to the property line and the building is fully sprinklered. The existing building on the south side is only 30
feet from the property line.
Pursuant to Section 104.2.7 of the 1997 building code, the city wouid be willing to except this condition
and allow the expansion of the existing building and continue to allow unlimited floor area as described in
Section 505.2 if the following is agreed upon and maintained:
1. For the new addition, the south side must be 60 foot minimum from the south property line.
2. The east side of the existing building must be 60 feet from the east property line and free of any
obstructions that would limit fire department access to the entire east side and meet the requirements
of Section 505.2 for yard and public way.
3. On the southwest corner of the existing building, provide an access door on the west wall.
4. No openings would be allowed on the south side of the existing structure.
If there are any questions, please call Steve Brown at 303-441-3172.
Building Design / Signage
At the February pre-application discussion, the applicant shared conceptual architectural plans for the
proposed Target west faqade. The updated new style includes more of a variety of materials than the
existing building and appears to incorporate more glass at the building entry. Issues to be addressed
during site review include more information about proposed planters and shopping cart storage, faqade
articulation and material detailing to create a pedestrian scale, and signage. Please note that the
conceptuai "bulis eye" Target logo cannot extend above the building roof line, as shown in the conceptual
plan (signs above the roof line are prohibited by the city sign code). The proposed building design will be
reviewed for compliance with the site review criteria and the BVRC Design Guidelines. Signage will be
reviewed for compliance with the city's sign code and the BVRC Sign Guidelines. City staff will work with
the applicant to ensure that Target's new design concept fits with city guidelines and standards.
Please note that the "by-righY' height limit on this site is 35 feet, as measured by the city code definition of
building height. A maximum 40 foot building height can be considered as an Administrative Review or
site review. Building heights between 40 and 55 feet must be considered as a site review by the Planning
Board.
See additional comments under Plan Documents below.
Drainage
Storm water quality enhancement and existing on-site detention ponding are issues that need to be
addressed during the Site Review Process. A Preliminary Storm Water Report and Plan in accordance
with the City of Boulder Design and Construction Standards must be provided by the applicant at time of
Site Review application. The required report and plan must also address the following issues:
• Water quality for surface runoff using UDFCD's "Best Management Practices"
• Treatment of storm water from new parking east of building prior to entering wetland area
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• Maintaining existing detention ponding facilities
• Groundwater discharge
. The Boulder Slough
. Erosion control during construction activities
Fees
A$2,900 Planning Board fee, in a check payable to the City of Boulder, is due at this time. Please pay
the cashier in the Services Center or send the check to the case manager no later than May 5, 2003.
Fire Protection
Addition must be provided with fire sprinkler system and approved U.L. monitoring. Ron Mahan,
303-441-4356
Land Uses
The existing and proposed land use, a major retailer, is consistent with the zoning and Boulder Valley
Comprehensive Plan (BVCP). Expansion of this use meets several concept plan guidelines (see below)
and BVCP policies.
Landscaping
1. Planning Board has made a recommendation to City Council on proposed changes to the landscape
standards that strengthen the city's xeriscape requirements on redevelopment and development
sites. Redevelopment of the Target site provides the opportunity for implementing those new
standards on a large site. Please note the proposed new standards and incorporate xeriscape
principles in the preliminary and final landscape plans. Bev Johnson, 303-4413272.
2. The concept plan shows an effort to improve the landscaping in the existing parking lot. However, it
is unclear at this point if the site plan meets the existing standards which require 15% of the parking
lot (including drive lands and loading areas) to be in interior lot ~andscaping. The standards also state.
that no more than three double loaded rows of parking may be situated consecutively without
providing a planting area, a minimum of eight feet in width along the center between rows for the full
length of each parking row. These iscues will be worked out in the site plan review. Bev Johnson,
303-441-3272.
3. As discussed in the pre-application meeting, landscaping along 28`h and Pearl streets should comply
with the BVRC Streetscape Guidelines for "C" streets. This includes a double row of street trees.
New street trees should be inter-planted with the existing trees, which should remain in place even
though their spacing differs from the current guidelines.
4. Removal of existing, healthy trees and shrubs should be minimized. Please explore whether the
design for proposed new access from 28`h Street can be adjusted to maintain the trees shown on the
Concept Plan for removal. Also, as the parking lot design is refined in the Site Review plan, please
look for opportunities to maintain existing mature trees within the parking lot.
5. Please note that parking lot screening along 28~h and Pearl streets will be needed, in compliance with
City landsca~ing standards and the BVRC Design Guidelines (Parking section). Additionally, the
corner of 28~ & Pearl is a"BVRC gateway' (Design Guideline 3.7.B.). Extra landscape treatment will
be encouraged here. These items can be addressed in the Site Review plan. Marie Zuzack, BURA,
303-441-4278.
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Legal Documents
No requirements at this time. Melissa Rickson, Office of the City Attorney, 303-441-3020.
Miscellaneous
Any easements necessary to be vacated for the proposed building expansion must be vacated
through the city's Land Use Review process prior to application for any building permit. Also, all
easements required to be dedicated to the city as part of the proposed construction must be reviewed
and approved through the city's Technical Document Review process cbncurrently with the proposed
public improvement engineering plans. Application materials are located on the 3rd Floor of the Park
Central Building, and can also be found on the city's web-site at;
httq•//www ci boulder co us/buildinaservices/aops htm#Attachments
2. The existing 48-inch storm sewer main to the east of the existing building does not appear to be
located within a recorded public Utility or Drainage Easement. If this is the case, the dedication of a
25-foot wide public Utility Easement for the existing line will be required as part of the Technical
Document Review. Scott Kuhna, 303-4413121
Parking
Any expansion of the existing Target building would be affected primarily by setback and parking
requirements, which can both be varied in a Site Review Amendment. The city's parking requirements in
this zoning district are one parking space required for each 400 square feet of gross building area. Based
on the concept plan, 475 parking spaces would be provided, where a minimum of 297 spar.es are
required by city code. While the proposal would meet and exceed the minimum parking requirement, the
applicant should note that there is a site review criterion that addresses providing the minimum amount of
land area devoted to parking. While staff understands that TargeYs parking requirements may exceed
the city's requirements, the applicant should understand that the significant discrepancy between these
two numbers may be an issue during site review. This may be particularly true given the balance needed
between parking, landscaping, and pedestrian/bicycle circulation on the site.
Plan Documents
The proposed concept plan meets and exceeds the level of detail required for this step in review. This
additional detail (e.g. specific number and types of parking spaces) allows staff to provide more detailed
feedback to help the applicant prepare a complete site review amendment application. However, staff is
concerned that the extra detail might lead the BURA and Planning Boards to comment on issues beyond
the intended scope of a concept plan review. Please consider removing some of the plan detail from the
final proposed concept plan. For example, rather than dimensioning and labeling parking aisles and
s;paces, indicate the estimated number of spaces per aisle.
Staff encourages the applicant to provide more architectural drawings to convey the architectural concept
being considered by Target. The drawings shown to city staff at the February 5, 2003 pre-application
meeting (including colored architectural sketches) wouid be helpful for Planning Board and BURA
members to understand the architecturai style. More detaifed architectural drawings would be required as
part of a site review amendment application.
Review Process
In the Concept Plan Review and Comment step, city staff and the community comment on the application
and then the project is scheduled for a public hearing with the Planning Board. This application has been
scheduled for the May 22, 2003 Pianning Board meeting. Also, it is recommended that the applicant
present the Concept Plan to the Boulder Urban Renewal Authority (BURA) Board for comment prior to the
Planning Board review. A BURA meeting is currently scheduled for May 21, 2003.
s:\plan\pb-items~memos\ehtargetconcept.pbm AGENDA ITEM # 5C Paee 13
The Planning Board (and BURA Board) comment on the concept plans; no decision is issued. The
applicant can then use the comments received during the concept plan process to prepare a site review
amendment application. (Please see the Next Steps section below.)
Site Design
The proposed addition to the west allows for the north-south driveway to move further west, thereby
better aligning with the adjacent drive on the Crossroads Mall site. Given the size of the parking area and
numerous drive aisles, the stronger the bicycle and pedestrian connections across the site, the better
Target will serve the Boulder population. Many Boulder Target shoppers (including college students,
young professionals, families, and seniors) reach this site by bus, bike or walking. This Target site is
served by a mid-block pedestrian crossing on Pearl Street and direct bus access. The proposed
expansion provides Target with an opportunity to redesign the site from "big box and parking IoY' to
"accessible commercial destination".
Utilities
1. A Preliminary Utility Plan in accordance with the City of Boulder Design and Construction Standards
(DCS) must be provided by the applicant at time of Site Review application. All proposed public
utilities for this project shall be designed in accordance with the DCS. Scott Kuhna, 303-441-3121
2. An additional fire hydrant will be required to the south of the entrance to the proposed expansion. Per
Section 5.10(A) of the City of Boulder Design and Construction Standards (DCS), no exterior portion
of any building shall be over 175 feet of fire access distance from the nearest hydrant. Additional
easement dedication (see miscellaneous comments) in accordance with the DCS will also be
required. The plan will need to be revised prior to submittal of the Site Review application. Scott
Kuhna, 303-4413121
3. The proposed Utility Plan shows a new location for the sanitary sewer service to the building. The
new private sewer service line is shown crossing the public water main and paralleling the public
water main to its connection with the public sanitary sewer main. This proposed service alignment
conflicts with Sections 4.06 and 6.08 of the City of Boulder Design and Construction Standards; which
specify a minimum of 10 feet of separation (outside of pipe to outside pipe) between water and sewer
lines, a minimum separation of 6 feet of separation between the outside edge of pipe and the property
line, and also prohibits private parallel service lines in public easements. The existing sanitary sewer
service to the east side of the building must be located and used to service the structure. The
applicant may contact city staff for information regarding the sanitary sewer service to the building.
The plan will need to be revised prior to submittal of the Site Review application. Scott Kuhna, 303-
441-3121
4. The existing storm sewer configuration at the southeast corner of the site does not match city
records. The applicant may contact city staff for information regarding the current storm sewer
alignment. The plan will need to be revised prior to submittal of the Site Review application. Scott
Kuhna,303-441-3121
Wetlands
The wetlands shown and labeled on the concept plan are not regulated by the city's wetlands protection
ordinance. Varda Blum, 303-441-3206
s:\plan\pb-items~nemos\ehtargetconcept.pbm AGENDA ITEM # 5C Pace 14
III. INFORMATIONAL COMMENTS
Drainage
Any discharge of groundwater to the public storm sewer system to accommodate construction and
operation of the proposed improvements wiil require city and/or state permits for this discharge. The
applicant is advised to contact the City of Bouider Storm Water Quality Office at 303-413-7350 regarding
permit requirements. All applicable permits must be in place prior to building permit application.
Additionally, speciai design considerations for the property to handle groundwater discharge as part of the
improvements wiil be necessary. Scott Kuhna, 303-441-3121
Miscellaneous
Plans look o.k. Greg Testa, Police Department.
Neighborhood Comments
Planning staff spoke with one of the owners of the neighboring property to the northeast. She raised
concerns about maintenance of an area between the properties and was unclear as to the current
ownership of this area.
Utilities
The applicant will need to provide accurate existing and proposed plumbing fixture counts at time of
building permit application to determine if the existing meters and services are adequate for the proposed
addition. The applicant may submit existing and proposed fixture count information to the city prior to
building permit application to verify that meter and service line sizings are correct. Scott Kuhna, 303-441-
3121
IV. NEXT STEPS
BURA Board Review: Please submit 12 copies (folded and collated) of the proposed concept plan,
including conceptual architectural drawings, to the Boulder Urban Renewal Authority, 1300 Canyon
Boulevard, Boulder, CO 80302, no later than 5 p.m. Thursday, May 15, 2003 for inclusion in the May 21,
2003 BURA Board packet. Staff encourages the applicant to also include a brief written statement which
describes the project concept and how it generally meets the BVRC Design Guidelines and BVRC
Transportation Connections Plan. Piease include 12 copies of this statement with the concept plans,
plus an additional 8 copies of the statement.
Planning Board Review: Please submit 17 copies (folded and collated) of the proposed concept plan,
including conceptual architectural drawings, no later than Wednesday, May 7, 2002 for inclusion in the
May 22, 2003 Planning Board packet. Staff also encourages the applicant to prepare a revised written
statement which addresses or acknowledges these city staff comments. Please include 17 copies of this
revised statement with the concept plans by May 8, 2002. (Please note that the application will be
removed from the May 22, 2003 Planning Board agenda if the $2,900 Planning Board fee is not paid as
noted above.)
Site Review Amendment: Following completion of the Concept Plan review, file a Land Use Review
application for a Site Review Amendment (Complex). For a Site Review Amendment, the applicant must
demonstrate compliance with the city's site review criteria and the area's urban renewal plan, which
includes the BVRC Design Guidelines and BVRC Transportation Connections Plan. This process allows
requests for variations from certain land use regulations such as building setbacks and parking and
landscape requirements. During the review process, any requested variations are balanced with the
quality of the project's site and architectural design.
s:\plan\pb-items\memos\ehtargetconcept.pbm AGENDA ITEM # 5C Paee 15
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Agenda Ite m # ~~ ~- Page # %(c
CEI ENGINEE1tING ASSOCIATES, INC. ATTACHMENT D
Proposed Expansion to Target Store T-0064
28`h Street & Pearl Street, Boulder, Colorado
May 6, 2003
CITY OF BOULDER
PLANNING AND DEVELOPMENT SERVICES
LAND USE REVIEW RESULTS AND COMMENTS
L CITY REQUIREMENTS:
ACCESS/CIRCULATION (AC-#)
AC-1 29~h Sfreet realignment along the west side of Target accommodating pedestrian, bicycle, and
vehicular access and connectivity is a key concept in the BVRC transportation plan. We are
beginning coardination efforts with Westcor-Macerich to ensure design is consistent throughout
the Target site, Crossroads Mall site, and the BVRC Transportation Connections Plan.
AG2 The existing 10' multi-use paths along 28~h and Pearl Streets shall remain unchanged with the Target
expansion except for necessary modifications due to the movement of Target's new access isles.
AC-3 The existing 10' multi-use path along the north side of Walnut shall remain unchanged except for
necessary modifications related to the proposed realignment of 29~~' Street .
AC-4 A note has been added to the concept plan indicating a possible future connection to the proposed
`Transit Village' located at the northeast corner of Pearl and 30th Streets.
AC-5 A note has been added to the concept plan indicating the potential for a future north-south
connection between the Pearl Street and Walnut Street multi-use paths. Understood is that the city
may negotiate with Target and other property owners in the area to obtain an easement based on the
future design of this improvement.
AC-6 Target has preserved and area at the corner of 28°i and Pearl Streets for a future Transit Superstop.
The reservation area exists from the outside of the existing parking lot up to where the right-turn
deceleration begins on Pearl and to where the sidewalk begins to curve around the ditch on 28`h
Street and has been indicated on the concept plan by a hatched area.
AC-7 A note has been added to the concept plan indicating the potential for a future north-south
connection between the Pearl Street and Walnut Street multi-use paths. Understood is that the city
may negotiate with Target and other property owners in the area to obtain an easement based on the
design of this improvement. Target has designed a 5' concrete path to be used for store access.
AC-8 Along with the proposed changes to the parking lot north of the Target building, the east-west multi-
use path has been extended along the north side of the Target toward the east side of the property.
AC-9 Coordination has begun with Westcor-Macerich to best adapt vehicular, pedestrian, and bicycle
circulation paths between the two properties. 29~h Street drive alignment, grade changes, possible
future Walnut re-alignment, and bicycle and pedestrian connections between the two sites have
been discussed with Darrell Beach, Westcar, (602) 953-6233 and shall continue. Input from city
staff will be appreeiaYed
Agenda Item # J L Page #~
CEI ENGINEERING ASSOCIATES, INC.
Proposed Expansion to Target Store T-0064
28~h Street & Pearl Street, Boulder, Colorado
May 6, 2003
AC-10 The intersection of 29`h Street and the truck dock access lane has been updated to show the more
prefened, perpendicular alignment of 29`h Street that does not curve toward the west. We are
working with Westcor to propose changing the alignment of 29~h Street so that it does not curve
toward the west as is the case presently.
AC-11 A 12' wide multi-use path has been proposed along the east side of 29`h Street allowing pedestrian
access on the Target building side of the street, thus minimizing pedestrian/traffic conflicts.
Further coordination with Crossroads Mall will be needed as their plans do not currently indicate a
proposed location of the 29`h Street multi-use path.
AC-12 The concept pian has been updated showing a proposed restriping of the Pearl Street median
allowing similar access that exists today. Left-turns are prohibited onto Pearl Street. The egress
median onto Pearl Street has been modified allowing for right-tum merging only and better
resembles the median that exists today.
AC-13 The 28`h Street access has been modified slightly, thus expanding the parking field toward 28`h
Street.
AG14 The 12' multi-use path connecting the Target entry to 28°i Street has been enhanced by the
addition of two 3.5' landscaping islands. Parking along the multi-use path have been converted to
standard spaces and the accessible parking spaces have been modified to both better distribute the
accessible spaces and to decrease the distance between the accessible spaces and the front doors.
AC-15 The current concept plan calls for a total of four at grade pedestrian crossing areas. The pedestrian
crossing area located directly in front of the store entry is constructed of stamped concrete
(proposed pattern similar to what is shown on the plan). The other three pedestrian crossings shall
be indicated by asphalt pavement striping. All pedestrian crossings shall have appropriate
pavement markings and pole-mounted signs. The new curb along the Tazget expansion calls for a
`rolled curb' which is a mountable curb along the entire length of the front sidewalk
AC-16 The multi-use path connecting the Target entry to 28`h Street has been widened from 8' to a
consistent 12' width running the entire length. Further, the path has been enhanced by the
addition of two 3.5' landscaping islands. Parking along the multi-use path have been converted to
standard spaces and the accessible parking has been modified to both decrease the distance
between the accessible spaces and the front doors and to better distribute the accessible spaces.
AC-17 The proposed re-alignment of 29`h Street that removes the westward curve in the drive isle
resolves the potential for conflict with the southemmost pedestrian crossing. This southernmost
pedestrian crossing will be at grade and indicated by asphalt pavement striping with appropriate
pavement markings and two pole-mounted signs.
AC-18 A note has been added that indicates a proposed connection to the future 28`" Street underpass.
Construction, dedication or reservation far the direct connection between 28`h and Walnut Streets
is not requested by the city at this time.
Agenda Item # ._~r C: Page # /~
CEI ENGINEERING ASSOCIATES, INC.
Proposed Expansion to Target Store T-0064
28`h Street & Pearl Street, Boulder, Colorado
May 6, 2003
AC-19 With a site review, Target must identify Transportation Management Demand Strategies (TDM)
Strategies suggested for this site include:
1) Providing an employee Eco-pass program.
2) Providing a parking cash-out program.
3) Becoming part of a Transportation Management Organization (TMO).
II. BUILDING AND HOUSING CODES (BH-#)
The 1997 Uniform Building Code ciassifies the existing Target as a Type III-N building for
construction purposes. Section 505.2 of the building code allows unlimited floor area of an M occupancy as
long as a 60 foot distance from the building is maintained and the building is fully sprinklered. The existing
building on the south side is currently 30 feet from the southem property line.
The city of Boulder is willing to except this condition and allow the expansion of the existing building
and continue to allow unlimited floor area as described in Section 505.2 if the following is agreed upon and
maintained:
BH-1 For the expansion of the existing building, two new fire hydrants are proposed along the southern
side of tl~e Target building. The southernmost wall shall be 4-hour fire rated.
BH-2 The existing access area on the east side is maintained unobstructed. It should be free of any
obstructions that would limit fire department access to the entire east side and meet the
requirements of Section 505.2 for yard and public way.
BH-3 An access door is to be provided on the southwest corner of the existing building.
BH-4 No openings would be allowed on the south side of the existing structure.
BUILDING DESIGN / SIGNAGE (BDS-#)
BDS-1 The architect has been contacted the architect concerning conceptual architectural plans for the
proposed Target west fapade. For site review, more information will be provided about proposed
planters and shopping cart storage, fapade articulation and material detailing. It has been
understood that the Target "bulls eye" logo shall not extend above the building roof line.
BDS-2 The "by-righY' height limit on this site is 35 feet, as measured by the city code definition of building
height. A maximum 40 foot building height can be considered as an Administrative Review or site
review. Building heights between 40 and 55 feet must be considered as a site review by the
Planning Board.
Agenda Item # `~ (~ Page # r'
CEI ENGINEERING ASSOCIATES, INC.
Proposed Expansion to Target Store T-0064
28~n Street & Pearl Street, Boulder, Colorado
May 6, 2003
DRAINAGE (D-#)
D-1 At the time of site review, storm water quality enhancement and existing on-site detention ponding
will be addressed. A preliminary storm water report and plan in accordance with the City of
Boulder Design and Construction Standards will be provided at the time of site review application.
The required report and plan must also address the following:
1) Water quality for surface runoff using UDFCD's "Best Management Practices"
2) Treatment of storm water from new parking east of building prior to entering wetland area.
3) Maint~ ~ning existing detention ponding facilities.
4) The Buuider Slough
5) Erosion control during construction activities
FIRE PROTECTION (FP-#)
FP-1 The proposed addition to the Target store shal] be provided with fire sprinkler systems and
approved U.L. monitoring.
LAND USES (LU-#)
LU-1 The existing and proposed land use (RB-E) is consistent with both the City of Boulder zoning and
the Boulder Valley Comprehensive Plan. Expansion of this use meets several concept plan
guidelines and BVCP guidelines.
LANDSCAPING (L-#)
L-1 Redevelopment of the Target site provides opportunity for implementing new changes to the
landscape standards especially in regards to the city's xeriscape requirements. Changes shall be
seen in the preliminary and final landscape plans.
L-2 The concept plan has been revised to retain several mature trees now existing on site. The
minimum amount of interi;;~ landscaping - including drive lanes and loading areas - is 15%.
L-3 No more than three double rows of parking exist without a planting area.
L-4 28`h and Pearl Streets shall comply with the BVRC Streetscape Guidelines for "C" streets.
Including a double row of street trees. Understood is that new street trees should be interplanted
with existing trees.
L-5 An attempt has been made to keep to a minimum the removal of existing healthy trees and shrubs.
Were feasiblc. healthy trees and shrubs will be relocated on-site. The redesign ofthe 28th Street
access drive allows the preservation of several mature trees in tl~e front of the Target store.
L-6 Parking lo: screening along 28~h and Pearl Streets shall be provided using either shrubs, lower
Agenda Item # _5 G Page # 0?0
CEI ENGINEERING ASSOCIATES, INC.
Proposed Expansion to Target Store T-0064
28`h Street & Pearl Street, Boulder, Colorado
May 6, 2003
canopy trees, or a combination thereof.
L-7 Understood is that the corner of 28`" Street and Pearl Street is a`BVRC gateway". Extra
landscape treatment will be encouraged. Coordination with the city's design of the "Transit
Superstop" will be helpful in obtaining a desired result.
EASEMENTS
Easements necessary to be vacated for the building expansion shall be vacated through the city's
Land Use Review process prior to building permit application. All easements to be dedicated to the city
shall be reviewed and approved through the city's Technical Document Review process concurrently with
the proposed public improvement engineering plans.
The existing 48" storm sewer to the east oFthe existing building is not shown to be located within a
public utility or drainage easement. The dedication of a 25' public utility easement for the existing line shall
be required as part of the Technical Document Review.
PARICING
The proposed expansion plan currently meets and exceeds the minimum parking requirement.
Understood is that there is a site review criterion that addresses providing the minimum amount of land area
devoted to parking. Also understood is that the significant discrepancy between the parking requirements of
Target and the city may be an issue during site review. The concept plan seeks to find a balance between
parking, landscaping, and pedestrian/bicycle circulation on the site.
SITE DESIGN
With a large parking lot containing numerous drive isles, the pedestrian and bicycle connections
need to be well planned. Wider paths, both connecting and aligning with major pedestrian magnets (Target
store, transit stops, Crossroads Mall site, etc) allows for stronger and safer access for non-motorized modes
of transportation.
UTILITIES (U-1)
U-1 At the time of the site review application, a preliminary utility plan in accordance with the City of
Boulder Dasign and Construction Standards shall be provided.
U-2 No exterior portion of the building shall be over 175' of fire access distance from the nearest
hydrant. Therefore, an additional fire hydrant will be required to the south of the entrance to the
proposed expansion.
U3 Minimum of 10' separation (outside of pipe to outside of pipe) between water and sewer lines, a
minimum separation of 6' separation between the outside edge of pipe and the property line. Private
parallel service lines in public easements are also prohibited. The existing sanitary sewer service to
the east side of the building must be located and used to service the structure.
Agenda Item # _'~ C_ Page # ~? /
CEI ENGINEERING ASSOCIATES, INC.
Proposed Expansion to Target Store T-0064
28`h Street & Pearl Street, Boulder, Colorado
May 6, 2003
U-4 Noted is that the existing storm sewer configuration at the southeast comer of the site does not
match city records. City staff shall be contacted for information regarding the current storm sewer
alignment. The plan shall be revised prior to submittal of the site review application.
WETLANDS
The wetlands shown and labeled on the original concept plan are not regulated by the city's
wetlands protection ordinance.
III. INFORMATIONAL COMMENTS
DRAINAGE
Understood is that any discharge of groundwater to the public storm sewer system to accommodate
construction and operation of the proposed improvements will require city and/or state permits for this
dischuge. The City of Boulder Storm Water Quality Office shall be contacted regarding permit
requirements. All applicable permits must be in place prior to building permit application. Additionally,
special design considerations for the property to handle groundwater discharge as part of the improvements
will be necessary.
NEIGHBORHOOD COMMENTS
One of the property owners to the northeast raised concerns about the maintenance of an area
between the properties and was unclear as to the ownership of the area.
UTILITIES
Accurate existing and proposed plumbing fixture counts at the time of the building permit
application shall be provided as to determine if the existing meters and services and adequate for the
proposed addition.
SIGNIFICANT VIEW CORRIDORS TO THE MOUNTAINS FROM THE SITE TOWARD THE
WEST ARE MAINTAINED WITH THE PROPOSED REDEVELOPMENT.
Agenda Item # ~ C= Page # ~70?
MEETING TH& TITLE 9, "LAND USG REGULATION," B.2C. 1981 - ETC.
City of Boulder
Planning and Development Services
1739 Broadway, Third Floor
P.O. Box 791
Doulder, Colorado 80306-0791
(303)441-1880
(303) 4413241 faz
plandevelop~a ci.boulder.co.us
K.K. Yeow
CEI Engineering Associates, Inc.
P.O. Box 1408
aentonville, AR 72712
(479) 273-9472 ext. 420
(479) 464-4329 fax
kveow(iil.ceiene.com
~p~rl 1, Zo 0 3
TARGET T-64, 2800 Pearl Street, Boulder, Colorado 80301; Acreage: 10.29AC; Zone:R6-C;
Development Proposal:
I3uilding addition (17,200 sq.ft.) ~t front, re-align driveway and curb cut to Pearl Street, milling, paving
and re-striping of parking lot, reconfiguration of landscape.
On-site Circulation:
Improvements to the vehicular and pedestrian circulation plan include I)Re-alignmenC of Pearl Street
entrence and the enclosing of the first ~arking isles on either side per city recommendation. 2) Addition of a
9' sidewalk from the store entry to 28" street with 2' landscape planters on either side allows for an
enhanced major pedestrian connection. Convertinfi standard parking spaces into compact spaees allows for
increased landscape materials. 3) Re-design of 28~' Street entry allows for safer entry transition onto Target
site. 4) Addition of a second pedestrian crossing (with signage and paving treatment) along the south end of
the wesC building faQade as well as expanding the existing front pedestrian entrance witli similar signage
1nd paving treatments.
Parking & Open Space:
W ith the re-configuration of the Target parking lot, we are able to dramatically increase the amount of open
space available for landscaping while maintaining our required parking counts- thus providing much
nceded pervious space for the overall decrease of stormwater runoff from the existing parking lot. The
advantageous view to the western mountains has not been affected by the Target expansion. The addition
of Colorado native species that exhibit tolerances toward local conditions witl be to our mutual advantage.
Arch itecture/S i enaae:
The updated Target fa~ade includes updated styles that include a greater variety of materials than the
existing building and incorporates more glass at the building entry. The issue of the conceptual `bullseye'
extending above the roofline has been addressed with an architectural modification that lowers the signage
into compliance with site review criteria and BVRC Design Guidelines.
2)°i Street Improvements:
With the resurfacing ofthe existing parking lot, the future 29°i Street corridor running in front ofthe Target
expansion ~rea has been modified so that the cross slope is maintained at less than three percent. Further,
the associated drainage has been modified with the addition of two extra grated inlets that provide for
adequate drainage in and around the front of the sCOre.
Circulation has been designed especially for the future incorporation of 29°i Street. Temporary access will
continue in its present location on the south side of the site aod will be transitioned into parking once 29°i
Street is constructed - adding to both greenspace and parking counts.
Wetlands;
The existing wetlands located on the northeastern side of the site will remain untouched during tlte
proposed renovation. A 5' pedestrian sidewalk provides for both a pedestrian connection to the Target
store, transit bus stop, and other amenities all while providing mitigated access through these protected and
unique lands. ~
Agenda Item # 5 (_ Page #,~ ,