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05-24-93 PC Agenda I/1tl AGE N D A GOLDEN VALLEY PLANNING COMMISSION Regular Meeting Golden Valley City Hall 7800 Golden Valley Road Council Chamber May 24, 1993 7:00 PM I . APPROVAL OF MINUTES -May ae, 1993 II. INFORMAL PUBLIC HEARING - CONDITIONAL USE PERMIT Applicant: Address: Request: u.S. West Communications, Inc. 710 Mendelssohn Avenue North, Golden Valley, Minnesota To Operate a Truck/Van Terminal in the Industrial Zoning Di stri ct III. INFORMAL PUBLIC HEARING - REZONING - AMENDMENT TO ZONING MAP Applicant: Address: Request: Golden Valley Housing and Redevelopment Authority Southwest Corner of Golden Valley Road and Rhode Island A venue, Golden Vall ey, Mi nnesota Amendment to Zoning Map for Assisted Housing Site from Residential and Commercial to M-l (Multiple Family) IV. REPORTS ON MEETINGS OF THE HOUSING AND REDEVELOPMENT AUTHORITY, CITY COUNCIL AND BOARD OF ZONING APPEALS V. OTHER BUSINESS VI. ADJOURNMENT ~~, . . . ~ MINUTES OF THE GOLDEN VALLEY PLANNING COMMISSION May 10, 1993 A regular meeting of the Planning Commission was held at the Golden Valley City Hall, Council Chamber, 7800 Golden Valley Road, Golden Valley, Minnesota. The meeting was called to order by Chair McAleese at 7:05 PM. Those present were Commissioners Groger, Kapsner, Lewis, McAleese, Pentel and Prazak; absent was Johnson. Also present were Mark Grimes, Director of Planning and Development; Beth Knoblauch, City Planner; and Mary Dold, Secretary. I. Approval of Minutes - April 12, 1993 MOVED by Lewis, seconded by Pentel and motion carried unanimously to approve the April 12, 1993 minutes as submitted. II. Informal Public Hearing - Preliminary Plat Applicant: Golden Valley Housing and Redevelopment Authority (HRA) Address: Valley Square Redevelopment Area C (Bounded by Winnetka A venue, Golden Vall ey Road, Rhode Island A venue and 01 son Memorial Highway Request: Subdivide the block into two lots III. Informal Public Hearing - Planned Unit Development Applicant: Craig C. Avery Company (CCAC) Address: Approximately three acres at the northeast corner of Area C (Golden Valley Road and Rhode Island Avenue) Request: Construct a 72-80 unit assisted-senior living facility Mark Grimes, Director of Planning and Development, told the Commission that the two pUblic hearings go hand-in-hand and he would be reporting on the Preliminary Plat and Planned Unit Development (PUD) as one but the Commission should vote separately on each request. He briefly related to the Commission that the HRA now owns all of Area C and continues to lease properties on a short term basis. Mr. Grimes commented that the preliminary plat would create two lots (one for the an assisted senior living facility and the remainder of the block for retail uses). Mr. Grimes talked about the designation of Craig C. Avery Company as developer for the approximate three acres at the northeast corner of the block for an assisted senior living facility for which he will need to obtain a P.U.D. Permit. He talked about five significant points regarding the preliminary plat which are outlined in his memo to the Planning Commission dated April 30th. Chair McAleese asked if the overhead utilities along Country Club Drive and Rhode Island would be buried. Mr. Grimes stated that the utilities would be buried or relocated along Golden Valley Road but this would have to be negotiated with the Utility Company. ,. . ' Minutes of the Golden Valley Planning Commission May 10, 1993 Page Two . Commissioner Prazak was concerned if the City was cutting off other development opportunities by making this area only two lots. Mr. Grimes commented that the larger portion of Area C is approximately 8 acres which is adequate for development. Mr. Gri mes continued hi s revi ew for the P.U.O. and commented that thi s appl i cati on would be for a 72-80 unit assisted senior living facility which would be developed by the Craig C. Avery Company and they would be working with the proposed partner, Walker Methodist, who would own and maintain the site. There would be 28 parking spaces available which the developer feels is sufficient. Walker has a similar facility at 7400 which as 1/2 space or less per unit. Staff recommends approval of the Preliminary Plat and the P.U.O. which is consistent with the redevelopment plan and the HRA's housing goals. Chair McAleese asked staff why CCAC was seeking a PUO Permit. within a redevelopment district, a developer may choose to go process. This process allows some flexibility in the planning benefit to both the developer and the City. Commissioner Groger voiced his concern about the expected loading docks to the west of the assisted living facility when the area is redeveloped for commercial uses. He said 10 feet on the west side of the lot was not much of a buffer. Mr. Grimes said there is some concern about where loading docks would be located. Staff will be addressing this issue when the commercial area is developed. Commissioner Pentel was concerned with the orientation of the building setting north' and south rather than east to west like the 7400 York Avenue building in Edina. Mr. Grimes stated through the P.U.O. process which is a Arvid Elness, architect on this project, reviewed several drawings of the building. Mr. Elness asked the Planning Commission that whoever would be the developer for the remainder of the block take into consideration the small setback on the west side of the building and require the area to be landscape appropriately. He said an enclosed drive-thru was not planned in this building because of the limiting factor of floor height with emergency vehicles. He said that because of the underground utilities in the County Club Orive right-of-way it may be difficult to erect a front covered drive-thru. The building may have to be shifted slighting to allow for such a covered entry. Commissioner Pentel asked Mr. Elness about the area size of the porches along the dining area in the rear of the building and if these could be made larger. Mr. Elness said he would review the area size at the Edina facility and survey how much this space is used. Crai g C. Avery, desi gnated developer, bri efly commented on what assi sted 1 i vi ng housing is and how it would fit into the Valley Square area. Chair Prazak opened the informal pUblic hearing. Mr. John Paulson, owner of the Valley Square Office Building, questioned the widening of Rhode Island Avenue and Golden Valley Road. Once he was informed that no right. of-way would be taken from the east side of Rhode Island Avenue Mr. Paulson fel comfortable with the proposed use of this area. Ms. Bev Kottas, H&I Enterprises and owner of the gas station at the corner of Golden Valley Road and Winnetka Avenue asked the Commission to keep in mind the need for a gas/service station for this area and is in favor of the development. , . . . .. Minutes of the Golden Valley Planning Commission May 10, 1993 Page Three Chair McAleese closed the informal pUblic hearing. Chair Prazak asked what the cost is to the City for this development. Mr. Grimes commented that the HRA has been buying property within this development and along Winnetka Avenue for the redevelopment process. CCAC is proposing to buy the lot from the HRA for about $300,000 ($4,000 per unit constructed). Commissioner Prazak asked if the CCAC property would generate taxes. Mr. Grimes stated that taxes will be paid on this property. Commissioner Pentel questioned the adequacy of parking. Mr. Grimes commented that a condition would be added to the PUD Permit stating that if the Director of Zoning and Inspections says there is inadequate parking, the green space to rear of the building could be converted to parking spaces. CCAC said they would review the parking at the 7400 York Avenue facility in Edina, and if they have errored in the amount of parking needed, they will add more parking spaces to the site. MOVED by Pentel, seconded by Kapsner and motion carried unanimously to recommend to the City Council approval for the Preliminary Plat of Valley Square 5th Addition which would create two lots, of which the northeast corner lot would be acquired by CCAC to be used for an assisted senior living facility. MOVED by Prazak, seconded by Groger and moti on carried unanimously to recommend to the City Council approval for the Planned Unit Development Permit with the added con- dition that if the Director of Zoning and Inspections feels more parking is required that CCAC provide parking at the rear of the building and a report supplied reviewing the southerly orientation of the porches. IV. Acknowledgement of the Oasis Mental Health Program Annual Report Chair McAleese acknowledged the Annual Report submitted by the Oasis Mental Health organization. V. Resorts on meetings of the Housing and Redevelopment Authority, City Council an Board of Zoning Appeals Mark Grimes and Warren Kapsner reported on the meetings they attended. VI. Other Business Beth Knoblauch, City Planner, told the Commission that the final two houses of Habitat for Humanity would be built in 1992. The sponsors of these two houses are General Mills and Pillsbury. VII. Adjournment Chair McAleese adjourned the meeting at 8:40 PM. Jean Lewis, Secretary . e e ". M E M 0 RAN DUM --------- DATE: May 19, 1993 TO: Golden Valley Planning Commission FROM: Elizabeth A. Knoblauch, City Planner SUBJECT: INFORMAL PUBLIC HEARING -- APPLICATION FOR A CONDITIONAL USE PERMIT TO OPERATE A TRUCK/VAN TERMINAL IN THE INDUSTRIAL ZONING DISTRICT U.S. WEST COMMUNICATIONS, APPLICANT The application is to add this proposed conditional use to an existing, par- tially occupied building and parking lot at 710 Mendelssohn Ave. North. An applicant's narrative is attached to this memo, as well as a site survey, floor plans showing existing and proposed building use areas and a plan of the pro- posed parking area. The requested terminal capacity is relatively small: 38 vans compact enough to fit in a standard 9'x 20' parking space. The vans would initially be stored in the open, though the applicant is asking that permission be included in the permit to build a shelter over the designated terminal spaces at an unspecified future date. The shelter would not be a fully enclosed garage. It would consist primarily of a canopy-like roof, similar to those at some vi ntage dri ve-i n restaurants. Engi ne heater attachments woul d be wi red from the canopy to serve each van space. This structure, whenever built, would have to meet all of the City's construction standards. Because of the way the building is used now, and because the proposed terminal use is not part of a separate lease, it is difficult to evaluate exactly how much space within the building will be associated with the terminal. However, an area of approximately 1500 sq.ft. on the building's lower level is proposed for remodelling to accommodate two "crew quarters" and a conference room for van drivers. Entryways, restrooms, and other building areas will obviously be shared with existing occupants. For many years the subject site has been owned and operated by U.S. West (or its predecessor) as a telephone switching facility. The building was expanded sev- eral times in earlier years of its existence, in order to accommodate increas- ing telecommunication demand. More recently, however, the electronic revolution and other new technologies have resulted in greater telecommunication capacity with reduced space needs. Today, a good portion of the building is unused or underused. To protect against accidental or deliberate tampering, the building is maintained as a secure facility, so leasing out any portion of it for non- telecommunication-related use is not practical. The overall building construction also would not lend itself easily to partial conversion for general office or industrial uses. The several structural addi- tions have resulted in a somewhat mazelike layout. There is no loading dock suitable for large scale warehousing and there are few windows or other internal amenities for office workers. Not only are the outside doors secure, but several interior areas are also kept locked. The delicate equipment requires specialized climate controls to maintain proper temperature, humidity, and air- borne particle levels. Special fireproofing materials are used to seal off each area where there is a potential for electrical fires. The building is not han- dicapped accessible. . '. . e e The biggest problem faced by staff in reviewing the truck/van terminal request was how to evaluate site parking needs. City code specifies that when multiple uses occur on the same site, all such uses must be counted separately for park- ing purposes. Since only a portion of the building was proposed for use asso- ciated with the terminal, some other parking requirement had to be applied to the rest of the building. Given the highly specialized nature of what goes on there, neither "industrial/warehouse" nor "office" seemed to be appropriate. It has fi na lly been determi ned that the best categori zati on of use is as a cl ass III essential service, which was added to the code in 1991 as a permitted use in either industrial zoning district. Unfortunately, no associated parking requirement was provided for essential ser- vices. In such cases, city code gives the City Council the authority to establish how much parking is necessary. A standard practice in the past has been to review similar uses already covered in the code. All "manned" facili- ties in the Radio and Television zoning district (which also qualify as essen- tial services in many cases) require at least one parking space for each two employees. Staff decided to go with a similarly personnel-based recommendation, but felt that one space for each employee would be a more realistic assumption than one space for two employees. Giving an additional cushion to the calcula- tion of overall site parking requirements, staff looked at employment for all shifts in a 24 hour day, though code providec that the daily peak employment is sufficient. Finally, staff felt it prudent to account for corporate vehicles other than the proposed service fleet being stored on the site. Site visitors and deliveries also were considered. As already indicated, this building is not open to the general pUblic. However, it is reasonable to assume that supervisors, inspectors, or other occasional corporate visitors will turn up on-site. Additionally, this and all U.S. West facilities are under court order to provide access to competitors where there is capacity to do so; at the time staff toured the building, one area was indicated as an installation in progress by a competing vendor. Such installations do not appear to have regu- lar staffing requirements, but presumably require their own periodic inspection, and certainly entail occasional deliveries of equipment for the installation itself. U.S. West also has its own occasional deliveries to accommodate. It is possible that supplies for the service vans will be stored on-site in the future, generating another source of deliveries. As already mentioned, there is no loading dock at the site. There is an area of the parking lot reserved for deliveries. Small to mid-sized trucks can be accommodated in this area fairly well. When large trucks need to be maneuvered into place, employees sometimes have to move their own vehicles out of the way. However, since there is no dock for direct off loading of materials from the trucks, there appears to be little value to be gained from permanently reserving enough pavement area to serve as a tractor-trailer parking space. With all of these factors in mind, staff set out to establish whether the available parking area is sufficient for the truck/van terminal and the existing site use. The parking lot today is nonconforming in setback along the east side and a porti on of the south si de, but has a more-than-adequate setback on the north. The appl i cant has been tol d by the Di rector of Zoni ng and Community Servi ces that the nonconformi ng areas of pavement do not have to be torn up until building permits are sought, but those areas cannot be counted for parking purposes. All parking spaces must be 91x 201, and driving aisles must be a minimum width of 201. For a public parking lot, the City would require wider aisles, and the applicant would prefer them, but 20' is workable and allows for an area of overflow parking at the east end of the lot. Staff originally -2- . . . required provision of handicapped parking, but the Director of Zoning and Community Services later determined that this would be unrealistic under the circumstances; ADA regulations provide for some exceptions and this site would appear to qualify. Cars currently park in the driveway alongside the building at times, but on recommendation of the City's Fire Marshal this will be desig- nated a fire lane with no parking permitted. The Fire Marshal would also prefer a complete driveway loop through the parking lot. Again, if this lot were open to the public, staff would agree, but under the circumstances it is not felt to be essential for safe circulation. According to city code, the proposed truck/van terminal will require 82 parking spaces. This includes six spaces for associated office use, though the appli- cant expects no additional office personnel to support the terminal and no customers will be visiting the site. The existing essential service use requires thirteen spaces, assuming eleven employees and two miscellaneous cor- porate vehicles. That comes to a total site requirement of 95 parking spaces. Exactly 95 spaces are provided in one single and two double rows of right-angle parking spaces on the applicant1s parking plan. Another nine spaces of poorly accessible but still serviceable parallel parking can be provided at the far east end of the lot for overflow needs. e Despite the current employment expectations of the applicant, staff recommends that at least four of the six spaces counted for terminal-related office uses be assumed for employment growth. That woul d allow up to two site vi sitors to be present at any given time without requiring use of the overflow parking area. The applicant appears quite comfortable in stating that the overflow area is unnecessary. Since the van storage spaces would theoretically be available for overflow parking while the vans are on the road, staff is inclined to agree that the overflow spaces may be a case of over kill. If the Planning Commission and City Council feel that the minimum requirement of 95 spaces as calculated above is adequate for the site, then the optional overflow parking can be deleted from the parking plan and the access aisles for the right-angle parking can be widened accordingly. Factors of Consideration In addition to the many parking issues specific to this site in particular, there are ten factors that must be consi dered in any appl i cati on for a con- ditional use permit. Staff evaluation of those factors is as follows: 1. Demonstrated Need - The proposal meets the City's general rule of thumb, which is that the applicant feels a need exists. 2. Consistency With Comprehensive Plan - The plan identifies the site as appropriate for general industrial, terminal warehouse, and radio uses. A truck/van terminal for the dispatching of telephone service vehicles would appear to be consistent with those types of uses. 3. Effect Upon Property Values - The terminal area will not be particularly vi si b 1 e from the street and the vehi cl es to be stored there wi 11 be limited in number and size. As there are general industrial uses around the site on all sides, no particular impact on property values is antici- pated. e -3- Flies, Rats, Animals, Vermin - Not expected to increase. Visual APfearance - The existing building is relatively attractive for an industria area. The potential vehicle shelter will not be particularly visible except from the immediately adjacent sites, and will not have much structure to it; through the building permit process, safeguards are available to regulate the quality of construction. 10. Other Effects - As indicated earlier in the staff memo, several aspects of this proposal would not be acceptable for a building that was open to the general pUblic or where multiple leases exist. However, the site is a secured facility with no access by the general pUblic. There is basically a si ngl e owner-occupant with good site control, despite the court order requi ri ng access for competi ng compani es. No other major effects have been identified. Through the conditional use permit, the zoning code, and building permit requirements, the City has ample opportunity to inter- vene if unforeseen problems come up at a later date. . . , e e 4. Effect on Traffic/Congestion - Mendelssohn Avenue is not presently con- sidered to be a congested street. Because the terminal area will replace parking spaces that could alternatively be used by office workers or other employees routinely found at industrial sites, the expected traffic impacts would not be unreasonable for the site. One employee has indi- cated concerns about overflow parking that might occur on the street and thus impede traffic. Because this building is not open to the public, staff feels that U.S. West has the ability to prevent or sharply restrict any such potential occurrences, and the conditions proposed for the permit give the City a measure of control as well. If a problem should develop, the City also has the authority to prohibit parking on the street. If all else fails, there is some space at the front of the site where an overflow parking lot could be accommodated. 5. Effect of Increases in Population or Density - The daytime population at the site will increase with the addition of the service crews. However, the site is underused now and another 35 or 40 employees is not expected to have a significant impact on the surrounding area. Even if the service vehicle shelter is constructed, total lot coverage by structures will remain less than the 50% permitted by code. 6. Increase in Noi se Levels - Added noi se due to the servi ce vehi cl es and additional employees is not expected to be unreasonable for an industrial area. 7. Odors, Dust, Smoke, Gas, or Vibration - Again, any potential increases are not expected to be unreasonable. 8. 9. Recommendation Staff recommends that the application for a Conditional Use Permit to operate a Truck/Van Terminal be approved, subject to the following conditions: 1. The regular, daily employment population at the site based on a 24 hour day, shall not exceed 53 (fifty-three) persons. This shall include all service vehicle drivers whose vehicles are stored at the site as well as all employees who regularly work within the building. . -4- , . , . e . It shall not include temporary workers or occasional site visitors, but at no time shall the presence of such persons at the site result in the parking of any vehicle in a setback area, in a designated fire lane, or in any other area where parking is prohibited. 2. The truck/van terminal area shall be limited to storage of a maximum of 38 (thirty-eight) service vehicles, each of which must be of a size that can be accommodated in a standard g'x 20' parking space. In additi on, there may be a maximum of 2 (two) mi scell aneous company vehicles that are driven to and from the site by employees who do not also have a personal vehicle there. 3. A service vehicle canopy or similar, doorless shelter may be erected in the location indicated on the attached parking lot plan provided that: a) before any such construction takes place, existing parking lot nonconformities shall be corrected, and b) the canopy or similar she 1 ter shall meet all construction and safety requi rements estab- lished by the Director of Zoning and Inspections. 4. No parki ng shall be permitted in the dri veway area adjacent to the bui 1 di ng on the south si de; that dri veway shall be desi gnated as an official fire lane. 5. Because the acceptable usage and layout of the parking lot area as a truck/van terminal has been based on the consideration of the build- ing as an essential service facility with minimal customer contact or other general, outside traffic, any change to the uses within the bui 1 di ng other than those contemplated in the attached floor plans shall require a review of the conditional use permit. 6. The floor plans and parking lot plan shall be attached to this permit with the understanding that the proposed outside canopy and interior alterations are permitted as shown but that the permit will not be rendered void if construction does not take place. 7. All other applicable city, state and federal requirements must be met. 8. Failure to observe any of the conditions of this permit may be grounds for its revocation. EAK:mkd attachments: Applicant narrative Site Survey Floor Plans (two floors) Parking Lot Plan Site Location Map ) ) Attached ) -5- . . . . . e . U S WEST Business Resources. Inc. 2800 Wayzala Boulevard. Room 370 Minneapolis. Minnesota 55405 Facsimile 612 344-5313 IIJ.-YEST May 3, 1993 city of Golden Valley Council & Planning commission 7800 Golden Valley Road Golden Valley, MN. 55427 Dear Representatives: U S WEST requests a conditional use permi t to provide a truck/van terminal at 710 Mendelssohn Road. This facility serves the local community as a telephone exchange building. The facility houses telephone equipment on the first floor and associated power equipment in the basement. A portion of the basement level is finished for administrative use, which is currently vacant. We propose to renovate this area for two crew quarters, one conference room specifically for crew meetings and one copy/printer room. CUrrent tenants include 8 telephone equipment maintenance personnel on the first floor and 2 cable technicians and 1 safety supervisor in the basement. Typical work hours are 8: 00 a . m. - 5: 00 p. m. One technician works an evening shift of 4: 00 p.m. - 12:00 a.m. The building occupancy with the addition of the 2 installation crews will be (49) employees. We are proposing to provide overnight parking for (38) 3/4 ton vans used for telephone installation crews. The crews would have typical daily hours of 7:00 a.m. to 5:00 p.m. This facility has the parking capacity to meet our needs. At (1) vehicle space per (500) square feet of facility, the calculated capacity is 87. The existing parking lot has 104 stalls. The total parking requirements will be for (38) company vehicles, (38) personal vehicles and the (13) existing tenant vehicles. A total of (91) parking stalls will be utilized on a daily basis. Copies of the building floor plans and site plan have been submitted for your review. Thank you for your cooperation and support. Sincerely, J}.~ J.L. Krieger U S WEST Representative 612/344-2484 ..- ... . . ,. .- .. .... e . en .=i '"'-8 '4N D4RD r.l8.tJo 'lJES"'J\E~ C~l:3 ..J ~ lei -0 ... . ';If, ~ \0 Ze . " .:. ~o, t~' ~4() "~.' - :ii. - ;iH ',: ~, .' .....,. f..s ~ .... ., ~ '" ,. i m (.0 . . . - ,'" U26 : :.% I' ! I".. ,01' ~ ,.... '" 93/0 011... " P,fOA vs~.() slr~ Ce.""e.R 640 ... 4 ,..:.. .. ~ .; ~ . ".Z'.I'I','7 .. (".. 1"".' Jr.J.70 ..' _' til~ ..".. "'l. ill" 't.'" to,~. :.,C;~:- - .'-'- ,o_nc..t"' ., ~ 1- ~ .. ~ ., .; D( '.... 8 ..~.:- "(;J. 0. ... ,,' 4. t ~"., ." :r ~ ::> o ::lE >- --l Cl. U. ,.., --- " -, I ~.~. H /73.18 3rd 80 S21.5' '. ~Jh - . 680 BUS\NE I . 7"'~~tJ ..... 924r> . 5111:' ;S8LDEN 2 S',." 71J ';/I.~r.. S.,.;f~':;''';.34 .. ,. ..0- &d. ":""0:' 2"i4 . _. _ ~5 e 9/J? 9?20 .:J'/z' 4_./.<58.';4 ., -;r I ()O'l' . :J.".. ~ I;;b.;!. .1' ~'nfl'" ...... ' , ~ ... e e e '" M.E M 0 RAN DUM ---------- DATE: May 19, 1993 TO: Golden Valley Planning Commission FROM: Mark W. Grimes, Director of Planning and Development SUBJECT: AMENDMENT TO ZONING MAP FOR ASSISTED HOUSING SITE _ SOUTHWEST CORNER OF GOLDEN VALLEY ROAD AND RHODE ISLAND AVENUE, GOLDEN VALLEY HOUSING AND REDEVELOPMENT AUTHORITY (HRA), APPLICANT At the May 10, 1993 Planning Commission meeting, the Commission recommended approval of a preliminary plat for Area C in the Valley Square Redevelopment District and the Preliminary Design Plan (PUD) for the development of a 72-80 unit assisted living building. The preliminary plat indicates the block (Area C) is divided into two lots; one lot is about three acres in size where the assisted living building would be constructed and the other lot about eight acres in size consisting of the remainder of the block. The underlying zoning of the lot proposed for assisted housing is both residential (s-f) and Commercial (see attached zoning map). It is the policy of the City to amend the zoning map if a proposed PUD use is not consistent with underlying zoning. Because of this pOlicy, the staff is recommending that the zoning map for the assisted housing lot be changed from Residential and Commercial to M-1 (multiple family housing less than three stories). The remain- der of the block will remain zoned a combination of Commercial and and Light Industrial until a redevelopment proposal is developed. Recommendation The staff recommends approval of a change in the Zoni ng Map from Residential and Commercial to M-l (multiple family) for the proposed assisted housing site on Area C. MWG:mkd Attachment: Zoning Map Section Preliminary Plat Indicating Zoning Boundaries ......... .......~.. . . . .. . . . . . . . . . . . _,_~J.i. · · OPEN DEVELOPMENt '''..' 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