To:
Planning Commission
From:
Jenn Ooton, Community Development Specialist/Planner
Date:
June 21, 2016
Subject:
Lafayette Tech Center Filing No. 3, Replat K
Applicant/Owner:
Location:
Legal Description:
Current Zoning:
Clinica Family Health Services
On the southwest corner of Public Road and Coal Creek Drive. The properties
are bounded on the north by Coal Creek Drive, on the west by Cherokee Trail,
on the east by Public Road and on the south by Old Laramie Trail
Lots 5, 6 and 9, Lafayette Tech Center Filing No. 3
C1 PUD (Regional Commercial / Planned Unit Development)
Vicinity Map
South Boulder Road
Subject
property
S. Public Road
Background
The applicant is proposing to combine Lots 5,6 and 9 into a single 6.945 acre lot to accommodate a
65,316 sq ft two-story medical office building (Clinica Family Health) that is 35’ in height. The
building is proposed to be constructed with fiber cement panels that look like wood, stucco, brick
and precast concrete, and to include a standing seam metal roof. The property is zoned C-1 PUD,
and is located within Lafayette Tech Center Filing No. 3. Within the Tech Center, medical
office/clinics require a Special Use Review.
Public Notification: Per the requirements of Section 26-16-3(c) of the Municipal Code, a
neighborhood meeting to present the Minor Subdivision and Special Use Review to neighbors who
live or own property within 750 ft of the project was held on April 25, 2016. One person attended
the neighborhood meeting. His comments are summarized within the project narrative.
The public hearing has been noticed in accordance with Section 26-16-9. Letters were mailed to
surrounding property owners within 750 feet and the property has been posted with signs indicating
the date and time of the public hearing at least 10 days prior to this hearing. To date, staff has
received no comments regarding the application.
Procedure: When considering a request for a Minor Subdivision, Easement Vacations, and Site
Plan/Architectural Review, the Planning Commission is charged with making a recommendation to
City Council. The Planning Commission may recommend approval as submitted, approval with
modifications, or may recommend denial of the application based upon applicable code criteria.
When considering a Special Use Review, the Planning Commission may approve the special use,
approve with conditions or deny the application based upon applicable code criteria.
MINOR SUBDIVISION
The Minor Subdivision is a realignment of lots, intended to combine Lots 5,6 and 9 of Lafayette Tech
Center Filing No. 3 into a single 6.945 acre parcel. With the Minor Subdivision, the applicant is
proposing new drainage and utility easements: a 25’ drainage and utility easement along the
eastern side of the property adjacent to the Public Road Right-of-Way, a 25’ utility easement along
the northern side of the property, a 20’ to 28’ utility easement through the middle of Lot 9 and on
the southern property line of what is today Lot 6.
The original development agreement for Lafayette Tech Center Filing No. 3 anticipates the future
construction of a signal at the intersection of South Public Road and Old Laramie Trail, and the
applicant’s traffic report indicates that a signal may be warranted at that intersection by 2018. Staff
recommends that prior to the submittal of the final plan to City Council, the applicant provide plans
for all public improvements, including widening of Public Road and traffic signal design.
The preliminary plat also includes a few clerical errors. Staff recommends that the applicant work
with staff to revise the plat to correct clerical errors prior to submittal of the final plan.
Xcel Energy has indicated that the utility easements through which existing natural gas and electric
distribution facilities are located need to be retained until such time that the facilities are
abandoned, removed or relocated. The applicant has indicated that they are currently working with
Xcel to relocate gas and electric into new easements, and staff recommends a condition that prior to
submittal of the final plan that the applicant supply proof that Xcel has agreed to the location of the
new easements and the vacation of the existing utility easements.
Staff has reviewed the Minor Subdivision and finds that the Minor Subdivision, with recommended
conditions of approval, meets the requirements of Section 26-17-6.
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Vacation
The applicant is requesting the vacation of two easements within the project site. A 30’
ingress/egress and utility easement runs along the eastern side of Lot 9 and the adjacent western
edge of Lots 5 and 6, and a 15’x20’ utility easement is located along the eastern side of Lot 9. The
applicant is proposing to relocate the utility easement along the southern property line of Lot 6, and
to create new easements along the eastern and northern property lines for utilities and drainage.
Per Section 26-14-20 (c) of the Development and Zoning Code, the Planning Commission must find
that a vacation is in compliance with two findings, if applicable:
1.
That no land adjoining any roadway to be vacated is left without an established
public road connecting said land with another established road; and
2.
That the land to be vacated is no longer necessary for the public use and
convenience.
Xcel Energy has indicated that the utility easements through which existing natural gas and electric
distribution facilities are located need to be retained until such time that the facilities are
abandoned, removed or relocated. Staff recommends a condition that prior to submittal of the final
plan that the applicant supply proof that Xcel has agreed to the location of the new easements and
the vacation of the existing utility easements.
The application includes a request to vacate the existing access easement from Coal Creek Drive,
but retain access to the site through the existing curb cut. The existing access easements on the
northern portion of Lot 7 and between Lots 7-8 and Lot 9 will remain in place. Staff finds that the
easement vacation request is in compliance with Section 26-24-20(c) in that Lots 7 and 8 will not be
affected by the change, and subject to the condition, that the land to be vacated is no longer
necessary for the public use and convenience.
SPECIAL USE REVIEW
Uses designated as special uses are those that may be appropriate in a particular location
depending on the nature of the proposed use, its relationship to surrounding land uses, its impact
on traffic capacities, and potential environmental effects. It is the intent of the special use review to
provide an analysis of such uses so that the community is assured that the uses are compatible with
their locations and surrounding land uses.
The Lafayette Tech Center PUD requires a special use review for medical and dental clinics. This is a
request for Special Use Review approval for a medical office facility that provides primary care
(family practice) medical services, including minor surgical procedures such as cryosurgery, castes,
splints, suturing, colposcopies, vasectomies, and ultrasounds; behavioral health services; dental
care and a satellite pharmacy. Boulder County Public Health will co-locate within the clinic to provide
Woman, Infant and Children (WIC), Genesis, and Nurse Family Partnership (NFP) services in the
facility.
The applicant currently operates two facilities in Lafayette. This facility will consolidate its offices
and medical facilities in one building. The applicant notes in the project narrative that the location is
proximal to the Kaiser Permanente Rock Creek Medical Offices and the Good Samaritan Medical
Center and is located along a transit corridor. There are currently four (4) RTD stops adjacent to the
Clinica site:
1. S. Bound on southwest corner of S. Public Road and Coal Creek Drive
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2. N. Bound on northeast corner of S. Public Road and Coal Creek Drive
3. S. Bound on the southwest corner of S. Public Road and Old Laramie Trail
4. N. Bound on northwest corner of S. Public Road/Old Laramie Trail
The Lafayette Park-n-Ride is located approximately .4 miles to the north of the subject property, on
Public Road. Currently, the regional ‘L’ route providing service to Denver via the park-n-ride has a
stop adjacent to the site, as does Route 225, which provides service within Lafayette as well as to
Boulder and the new BRT improvements on US 36 in Broomfield.
The applicant has highlighted the importance of this transit corridor for the access of Clinica
patients and visitors. As part of this plan, the applicant is proposing to construct an RTD-approved
bus shelter along S. Public Road. Staff recommends the applicant also provide bicycle racks, a
bench and trash receptacle at this location. The property owner shall be responsible for
maintenance of the shelter and amenities until such time as RTD takes over maintenance
responsibility.
Special Use Review Criteria:
The following criteria apply to all special use reviews:
1. Compliance with Municipal Code.
Medical office is a permitted use within the C-1 zone. Within the Lafayette Tech Center,
medical office requires a special use review. The intent was to encourage a mix of office types
and light manufacturing uses.
2. The compatibility of the proposal with the character of the surrounding area.
Adjacent and nearby uses include the Creekside Cancer Care, Colorado CyberKnife, Coal
Creek Plastic Surgery, Xtreme Altitude Gymnastics, Ponderosa Associates, and Rocky
Mountain Instruments. The uses in the immediate neighborhood are primarily office and light
manufacturing uses, and staff believes that medical office use is compatible with the
character of the surrounding neighborhood.
3. The desirability and need for the proposed use in the specific area of the community.
The applicant is consolidating two administrative and medical office facilities that are already
into the community into one building, located within the Lafayette Tech Center, and along a
transit corridor. Staff believes that the use is desirable and there is a need for the proposed
use in the specific area of the community.
4. The potential for adverse environmental influences that might result from the proposed use.
Adverse environmental influences such as noise and lighting have been addressed with site
design. The property has been zoned commercial and the potential traffic for the site has
been anticipated in design and in the future construction of a signal at the intersection of
South Public Road and Old Laramie Trail.
5. Compatibility of the proposed use and the site plan with the Comprehensive Plan.
The Comprehensive Plan Land Use Map designates the subject property as
Commercial/Commercial-Industrial. With Special Use Review approval and proposed
conditions, staff believes the proposed use is compatible with that designation. The
proposed use and site plan meets several Comprehensive Plan goals and policies some of
which are listed below:
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Goal D.1:
Ensure that new development and redevelopment is integrated and
compatible with existing and planned adjacent development, and that it provides quality
design that contributes to Lafayette’s community image and character.
Policy D.1.1: Ensure that both the scale and appearance of proposed development and
redevelopment responds appropriately to adjacent development and provides a compatible
transition to existing neighborhoods.
Policy F.1.3: Maintain and retain existing businesses and encourage the expansion of
existing businesses that have the potential to grow within Lafayette.
Policy F.4.3: Ensure that new development provides safe, pedestrian-friendly, barrier free,
streetscape design.
Policy G.3.2: Require proposed development and redevelopment to construct bus stops
(including shelter, seating, etc.) when located along transit corridors.
Policy G.3.3: Ensure that proposed development and redevelopment provides an
adequate system of sidewalks and trail facilities that meet City standards to promote
walking and bicycling throughout the City. Connect new sidewalks and trails to existing
sidewalks and trails.
Staff recommends approval of the Special Use Review, subject to Site/Architectural Review approval
by City Council and to the condition regarding RTD bus stop amenities.
SITE PLAN/ARCHITECTURAL REVIEW
The applicant is proposing to construct a 65,316 sq ft two-story medical office building that is 35 ft
in height. The building’s entrance is designed to face south and toward the interior of the lot.
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Architecture: The building is proposed to be constructed with fiber cement panels that look like
wood, stucco, brick and precast concrete and to include a standing seam metal roof. The applicant
selected materials and design elements intended to make connections to the city’s local mining and
agrarian history and to be energy efficient.
The material sample board provided indicates that the stucco color on the building will be off-white,
the brick color will be a dark gray/plum and will be used as a building accent near the windows on
the west elevation and in the middle of the building on the southern elevation. The brick blend will
be two colors of tan and beige and used on the western side of the building’s main elevation
(southern elevation), and the standing seam metal roof will be light gray. The tallest elements of the
building will be vertical cement panels that are designed to look like dark brown wooden siding.
The plans for the project include a courtyard area with seating, shade trees, grasses, and a mix of
paving designs, and a walking path around the building site (including mile markers embedded into
the sidewalk). The application does not include architectural details for the seat walls and benches
within the outdoor courtyard area. Staff recommends that the applicant provide details of the
benches and seat walls prior to the building permit submittal.
Staff finds that the architecture and materials are in character with the surrounding uses and that
the architectural treatments are integrated into the overall architecture and the site. Staff finds the
proposed building elements are visually attractive, harmonious and compatible to the site and
surrounding buildings. Staff finds that the varied materials, rooflines, varied window size, and the
entry features (including windows and beams) break up the mass of the building and provide for
visual interest.
Dimensional Standards: The following table illustrates the existing bulk and area requirements and
those proposed by the applicant:
Lot Coverage:
Area for Landscaping:
Building Setback:
Front Yard
Side Yard
Rear Yard
Building Height:
Proposed
12.8%
33.5%
35’
97’
235’
35’
C-1/PUD
N/A
15%
20’
N/A
N/A
35’
Streets and Access: The subject property is bounded on the north by Coal Creek Drive, on the west
by Cherokee Trail, on the east by Public Road and on the south by Old Laramie Trail. The main
entrance to the site will be from Public Road through a right-in, right-out entrance. The site from the
north will be accessed from Coal Creek Drive, through an existing curb cut, on the west from
Cherokee Trail through an existing curb cut, and from the south from Old Laramie Trail, through an
existing curb cut. The applicant is proposing to close one other existing entrance to the site from
Cherokee Trail and to make changes to the median, removing the southbound turn lane into that
curb cut. The plans show one stop sign along the drive aisle from Public Road. Staff believes this will
not be sufficient, and recommends the applicant work with staff to indentify additional locations for
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stop signs to control traffic through the site and help avoid potential pedestrian, bicycle and
vehicular conflicts.
The Fire Marshal also indicated the need for no parking signs along the drive aisle from Public Road
into the site. Staff recommends a condition that the applicant work with staff to identify the number
and location of no parking signs along the drive aisle from Public Road into the site.
Pedestrian Access: The plan shows sidewalks around the entire site and internal paths, including
mile markers embedded into the sidewalk to encourage walking around the site. The sidewalk
connects the site to the RTD bus shelter being proposed as part of this application. The plans show
two crosswalk areas near the building entrance, delineated with different paving. Staff believes that,
as designed, the area will encourage people to walk diagonally from the parking lot to the front
entrance, and recommends that the applicant work with staff to reconfigure that area, including the
patient drop-off area for additional pedestrian safety.
Bicycle Circulation and Parking: The C-1 Design Guidelines indicate that bicycle parking should be
located convenient to building entrances, at public plazas and should be furnished to encourage use
of alternative transportation modes. Plans for the project do not show bicycle parking either near the
building or at the RTD bus stop. Staff recommends the applicant amend the site plan to include
bicycle parking near the building entrances (patient and employee entrances) and at the bus stop.
Loading Areas: Section 26-20-6(a) of the Code requires a loading area for all commercial buildings
larger than 2,000 square feet in size. The plans indicate a loading area for ambulances off of the
parking lot accessible from Coal Creek Drive, to the north of the building.
Trash Enclosure: The proposal shows a trash enclosure on the north of the building, but
architectural details were not provided for the dumpster enclosure. Staff recommends that prior to
the issuance of the building permit, the applicant provide a detailed drawing of the trash enclosure
for review and approval by staff.
Mechanical Screening: The plans indicate an enclosure for a transformer near the trash enclosure,
but do not indicate the location of either roof or ground-mounted mechanical equipment. Staff
recommends the applicant submit details for mechanical equipment screening for review and
approval of staff. Staff recommends that the wall-mounted mechanical equipment be painted to
match the building.
Parking: The applicant is proposing 356 parking stalls, eight (8) of which will be accessible stalls.
Section 26-20-16 requires medical office uses to provide one parking stall per 200 square feet of
floor area. The code requires 327 parking stalls, of which eight (8) must be designated as accessible
spaces. The development agreement for Lafayette Tech Center Filing No. 3 states that more than
50% of the parking on Lots 5 and 6 shall be located in the side or rear yards of the property. The
proposal shows the majority of the parking on the southwestern portion of the site and only 17
parking stalls along Public Road.
It is unclear whether there is curbing at the front of the accessible parking stalls; staff recommends
a condition that the accessible stalls and sidewalk be at the same grade to allow access from the
stalls to the sidewalk and building.
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Section 26-19-5(6)(dd) requires a 20’ landscaping setback to parking lots from arterial street rights
of way and 15’ landscaping setbacks from other street rights-of-way. The parking lots shown on the
plans are screened by bushes including Russian Sage, Compact European Cranberrybush and Blue
Mist Spirea. The applicant has requested flexibility to modify the landscape screening to include for
the addition of berms to reduce the number of shrubs. Staff supports this, with the caveat that the
required number of shrubs meet the minimum landscaping requirement.
Engineering: The City Engineer has written a letter with comments regarding engineering, dated June
23, 2016. Staff recommends the applicant address the concerns identified in the engineering letter,
prior to building permit submittal.
Landscaping: The applicant is proposing 101,295 sq ft of irrigated landscaping, the majority of
which is identified as being in a moderate or low water zone. The hydrozone map indicates an
average water usage of 10 gallons/season.
Percent Landscaped Area
Square Footage (15% of site, parking area)
Proposed
33.5%
108,345 sf
Code
15%
48,178.63 sf
Site Landscaping
Trees
Shrubs
Parking Lot Landscaping (356 spaces)
Trees
Shrubs
Street Trees
53
321
48
321
24
401
30
24
356
46
Total Trees
Total Shrubs
107
722
118
677
The application meets the minimum landscape requirement for site landscaping, but does not also
separately break out street trees and parking lot landscaping requirements. A review of the plans
shows that there are 30 trees that could be counted toward the street tree requirement. Staff
recommends that prior to the issuance of the building permit, the applicant submit a reconfigured
landscape plan to show the minimum number of required street trees and any proposed changes to
the parking lot landscaping screening for review and approval by staff.
Lighting: The lighting plan indicates zero or near zero foot candle readings at the exterior property
lines. The C-1 design guidelines state that lighting levels in parking and service areas shall not
exceed 8-foot candles when measured at the ground. The applicant has provided a photometric
plan, which shows the maximum foot candles at the ground to be 6-foot and zero or near zero at the
property lines.
Misc.: In visiting the site, prairie dogs were observed on the property. Staff recommends a condition
that the applicant follow the city’s prairie dog mitigation plan prior to submitting a building permit
application.
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Through the special use review analysis, staff identified that there is a dental office portion of the
medical office, which could produce amalgam waste. Staff recommends a condition that the
applicant show an amalgam separator with the building permit application.
Summary
The project under consideration is for the Vacation of Easements, a Minor Subdivision to combine
three lots within Lafayette Tech Center Filing No. 3, Special Use Review and Site Plan/Architectural
Review to accommodate a 65,316 sq ft two-story medical office building. The property is zoned C1
PUD. Staff believes that the site plan complies with the requirements of the Code.
Subject to the conditions as recommended by staff, the site and architecture plans will comply with
Code requirements. Staff believes this is a high-quality, attractive building design that will
complement the existing commercial buildings in the area. The scale is appropriate to the site and
function of the project; monotony of design will be avoided by providing variation of detail and form.
The design minimizes interference with access and circulation on the public street, and staff
believes that there is adequate pedestrian and bicycle access.
Findings and Recommendations
1) Minor Subdivision
Staff finds that, subject to the recommended conditions, the proposed Minor Subdivision complies
with the review criteria of 26-17-6, and recommends approval.
2) Vacation
Staff recommends approval of the vacation of the easements, finding that the request complies with
Code section 26-14-20(c) in that Lots 7 and 8 of the subdivision will not be affected by the change,
and subject to the condition, that the land to be vacated is no longer necessary for the public use
and convenience.
3) Special Use Review
Staff finds that the proposed facility meets the Special Use Review criteria in Section 26-15-4, and
recommends approval.
4) Site Plan/Architectural Review
Staff finds that, subject to the recommended conditions, the proposed site plan/architectural review
complies with the review criteria of Section 26-16-7.1 and the submittal requirements of Section 2617-9 and recommends approval, and finds that the design is compatible with the location and
proposed use.
RECOMMENDED CONDITIONS OF APPROVAL
Minor Subdivision
1. Prior to the submittal of the final plan to City Council that the applicant shall provide plans
for all public improvements, including widening of Public Road and traffic signal design.
2. The applicant shall, prior to submittal of the Final Plan for City Council approval, revise the
plat to correct clerical errors prior to submittal of the final plan.
3. Prior to submittal of the Final Plan, the applicant shall supply proof that Xcel has agreed to
the location of the new easements and the vacation of the existing utility easements.
Vacation
1. Prior to submittal of the Final Plan that the applicant shall supply proof that Xcel has agreed
to the location of the new easements and the vacation of the existing utility easements.
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Special Use Review
1. The approval of the Special Use Review shall be subject to approval of the Site
Plan/Architectural Review by City Council.
2. The applicant shall provide bicycle racks, a bench and trash receptacle at the RTD-approved
bus shelter. The property owner shall be responsible for maintenance of the shelter and
amenities until such time as RTD takes over maintenance responsibility.
Site Plan/Architectural Review
1. Prior to submittal of a building permit, the following must be met, subject to staff review and
approval.
a.
The applicant shall provide details of the benches and seat walls prior to issuance of
the building permit.
b.
The applicant shall work with staff to identify additional locations for stop signs to
control traffic through the site and help avoid potential pedestrian, bicycle and vehicular
conflicts.
c.
The applicant shall work with staff to identify the number and location of no parking
signs along the drive aisle from Public Road into the site.
d.
The applicant shall work with staff to reconfigure the crosswalks and patient drop-off
area for additional pedestrian safety.
e.
The accessible parking stalls and sidewalk shall be at the same grade.
f.
The applicant shall provide a detailed drawing of the trash enclosure for review and
approval by staff.
g.
The applicant shall submit details for mechanical equipment screening for review
and approval of staff.
h.
All wall-mounted mechanical equipment shall be painted to match the building.
i.
The applicant shall submit a new landscape plan to show the minimum number of
required street trees and any proposed changes to the parking lot landscaping screening
for review and approval by staff.
j.
The applicant shall amend the site plan to include bicycle parking near the building
entrances and at the bus stop.
k.
The applicant shall follow the city’s prairie dog mitigation plan prior to submitting a
building permit application.
l.
The applicant shall show an amalgam separator with the building permit application.
m.
The applicant shall address the concerns identified in the City Engineer’s letter,
dated June 23, 2016.
MOTIONS
1. Minor Subdivision
Proposed Motion for Minor Subdivision Approval:
The Planning Commission recommends approval of the Minor Subdivision, subject to the
recommended conditions, finding the proposed Minor Subdivision complies with the review
criteria of 26-17-6.
Proposed Motion for Denial:
The Planning Commission recommends denial of the Minor Subdivision, subject to the
recommended conditions, finding the proposed Minor Subdivision does not comply with the
review criteria of 26-17-6.
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2. Vacation
Proposed Motion for Approval:
The Planning Commission recommends the City Council approve the requested vacation of
the easements, subject to the recommended condition, finding that the request complies
with Section 26-14-20(c) of the Development and Zoning Code in that Lots 7 and 8 of the
subdivision will not be affected by the change and that the land to be vacated is no longer
necessary for the public use and convenience.
Proposed Motion for Denial:
The Planning Commission recommends the City Council deny the requested vacation of the
easements finding that the request does not comply with Section 26-14-20.
3. Special Use Review
Proposed Motion for Approval
The Planning Commission approves the Special Use Review, subject to the recommended
conditions, finding that the proposed facility meets the Special Use Review criteria in Section
26-15-4.
Proposed Motion for Denial
The Planning Commission denies the Special Use Review, finding that the proposed facility
does not meet the Special Use Review criteria in Section 26-15-4.
4. Site and Architectural Approval
Proposed Motion for Site Plan/Architectural Approval:
The Planning Commission recommends approval of the Site Plan/Architectural Review for
Lafayette Tech Center Filing No. 3, Replat K, subject to the recommended conditions, finding
that the proposal complies with Sec. 26-16-7.1, and the submittal requirements of Section
26-17-9 of the City of Lafayette Code of Ordinances, and that the design is compatible with
the location and proposed use.
Proposed Motion Denial:
The Planning Commission recommends denial of the Site Plan/Architectural Review for
Lafayette Tech Center Filing No. 3, Replat K finding that the plan does not comply with the
criteria of Section 26-16-7.1, the submittal requirements of Section 26-17-9 have not been
met, and the design is incompatible with the location and proposed use.
Attachments: Project narrative
Plans (Minor Subdivision, Vacation Easement and Dedication, Site Plan/Architectural
Review, Color Elevation)
Engineering Letter, dated June 23, 2016
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To:
Jenn Ooton, Planner I
From:
Kenneth J. Kelgard, P.E., City Engineer
Date:
June 23, 2016
Subject:
Southwest corner of Public Road and Coal Creek Drive (Clinica Lafayette) - Engineering Plan
Review Comments
We have completed a review of the documents provided dated May 26 and 27 and have the following
comments:
General:
1. Before a Building Permit is issued the following items needs to be submitted and approved by
the City Engineer:
a. Final engineering plans for the project site including Construction Details and a phased
Soil Erosion and Sedimentation Control plans.
b. Offsite Public Road widening plans
c. Offsite Cherokee Trail Improvement Plans.
d. Traffic Signal design for the intersection of Old Laramie Trail and S. Public Road.
2. All existing utilities will be required to be potholed prior to construction to verify invert
information provided in the plans.
3. A new manhole shall be used to make the sewer connection from the building to the new
sewer service for the building.
4. Before the existing easement can be vacated as proposed Xcel Gas needs to sign off on the
vacation and the utility relocated outside of the Cities easements.
Traffic:
1. The developments traffic report identifies that a traffic signal will be required to meet the 2018
traffic volumes at Old Laramie Trail. As the building is scheduled for a late 2017 or early 2018
opening the development will be required to provide the traffic signal as part of its
improvements.