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HomeMy WebLinkAboutSP-24-08 - Supplemental - 0870 Williston Road (19) MEMORANDUM To: Derick Read, Krebs and Lansing From: Marla Keene, Development Review Planner Date: March 22, 2024 Design Team Responses 6/17/2024 P&Z Review 7/22/2024 Design Team Responses 8/16/2024 Re: SP-24-08 870 Williston Road – Doubletree Hotel Addition Review Comments This memo can be used to provide back-and-forth as the project is reviewed. As of March 22, 2024, this memo includes comments on the LDR except for the BES Table, 3.18 and 3.19 pertaining to energy efficiency and solar readiness, and improvements within the Williston Road ROW. Also forthcoming are comments of the Director of Public Works and City Stormwater Section. Where information is needed to address multiple standards, it is only mentioned once. Appendix E (Application Completeness) The following was sent on 2/20/2024. Only partial responses have been received to date. All required items must be submitted prior to being eligible to schedule the required neighborhood meeting. Application Requirement Project Specific Notes Boundaries and area of existing subject property(ies), proposed property lines, continues properties, boundaries of all zoning districts, transects, and overlay districts, and all designations on the City's Official Map, and lots within the proposed subdivision numbered. "Slope rights" callout is unclear. To what is it pointing? Applicant Response 6/17: This application requirement has been addressed. P&Z Follow-up 7/22: OK Zoning district boundary not shown. What is red line on OSP? Applicant Response 6/17: This application requirement has been addressed. P&Z Follow-up 7/22: OK Lot area in square feet and acres, and lot coverage calculations including building, overall, and front yard coverage and the location and layout of any off-street parking or Missing existing building area Missing lot coverage (for stormwater reporting purposes) Applicant Response 6/17: The requested lot 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV loading areas, traffic circulation areas, pedestrian walkways, and fire lanes. and building area calculations are provided on plan CH101 P&Z Follow-up 7/22: OK Point-by-point lighting plan and cut sheets for all proposed outdoor lighting within the site Omitted Applicant Response 6/17: The light poles area shown on the site and landscape plans and a photometric lighting plan and cut sheets are included with this submission. P&Z Follow-up 7/22: See new comments on 13.07 below The location of any outdoor storage for equipment and materials if any, and the location, type and design of all solid waste- related facilities, including dumpsters and recycling bins. Existing or proposed dumpsters not shown Applicant Response 6/17: The hotel addition will rely on the existing hotel’s trash compactor which is located near the northeast corner of the building, hidden from public view. The trash compactor is shown on CH100 and CH200. P&Z Follow-up 7/22: OK Existing water courses & buffers, wetlands & buffers, base flood elevations if located in an area of special flood hazard, wooded areas, ledge outcrops, and other natural features. River corridor not shown Applicant Response 6/17: The River Corridor has been added to the plan. The only impact is related to the installation of the new storm pipe which is located under the existing pavement. P&Z Follow-up 7/22: OK but it is not shown on any but sheet CH100, though the callout is shown on other sheets. Please add to at minimum EPSC plans & stormwater plans. Applicant Response 8/16: The missing River Corridor line has been added to the stormwater and EPSC plans. The existing wet pond at the northeast corner of the site is being converted to a Gravel Wetland. The east edge of the pond is located within the delineated Class II wetland buffer so we met on site with Tina Heath on June 11th to review the encroachment. Tina indicated that the impacts are within the previous stormwater pond footprint and because we are not proposing to expand the wetland impacts beyond the previous footprint, the disturbance is not jurisdictional. P&Z Follow-up 7/22: See follow up stormwater comments under 13.06 below Applicant Response 8/16: See attached revisions to the narrative, modeling, plans, and worksheet that we believe address the stormwater comments 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV Existing and proposed open space Please show specific boundaries and computations demonstrating requirements are met. Applicant Response 6/17: Please see plan sheet LH-004 P&Z Follow-up 7/22: See follow up comments on 8.08 below. Applicant Response 8/16: See response below Detailed specifications and locations of planting, landscaping, screening, and/or buffering materials. Partial. Narrative indicates more forthcoming Applicant Response 6/17: Please see the Landscape Plan, sheet LH-001 P&Z Follow-up 7/22: See follow up comments under 13.04 below Applicant Response 8/16: Additional information provided and described below. A list of existing vegetation, with the location, type, and size of existing trees of six inches or greater in caliper. Omitted Applicant Response 6/17: Please see the Existing Tree Plan, Sheet LH-003 P&Z Follow-up 7/22: See follow up comments under 13.04I below. Applicant Response 8/16: Additional information provided and described below. Detailed landscaping plan, specification of materials, costs, and phasing plan, including vegetation to remain, types of new plant materials, identified by common name and botanical name, sizes of all new plant materials by height and/or diameter at time of planting and at maturity, quantities of each of the planting materials, and treatment of the ground surface (paving, seeding, or groundcover) for all plantings, screening, buffering, and stormwater infiltration. Costs omitted Applicant Response 6/17: Please see the attached Landscape Plan, sheet LH-001and accompanying Landscape Budget document. P&Z Follow-up 7/22: See comments pertaining to landscaping budget computations below. Applicant Response 8/16: The Building Only project costs are estimated to be $14,896,545 Solar ready roof analysis report Omitted Applicant Response 6/17: Solar panels are proposed on the roof of the hotel addition. P&Z Follow-up 7/22: OK Plans showing the location, size and invert elevations of existing and planned sanitary sewers, storm water drains, and fire hydrants and location and size of water, gas, electricity and any other utilities or structures. It is unclear what the proposed remediation is for underground utilities that will be disrupted by proposed project. Applicant Response 6/17: An existing electrical transformer located northwest of the proposed addition will be replaced with a new transformer. The new transformer will be placed on the east side of the new addition so it is more hidden from the public view. There 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV is an electrical conduit for site lighting that passes through the new building footprint. It will be re-routed and re-fed during construction. The existing waterline that feeds the hotel will remain active but a new service for domestic water and fire protection will be extended to the hotel addition. A portion of the existing natural gas service that feeds the existing hotel will need to be re-routed and reconnected to allow for the construction of Gravel Wetland #2. P&Z Follow-up 7/22: OK Existing and proposed water and wastewater usage Omitted Applicant Response 6/17: The calculations for the existing and proposed water and wastewater usage is included in the attached Preliminary allocations from the Department of Public Works and South Burlington Water Department. P&Z Follow-up 7/22: OK Location and design of all utility distribution facilities This includes telecommunication cabinets, additional of which may be needed depending on rerouting of aforementioned underground power Applicant Response 6/17: A new transformer and a pad for air heat pumps and condensers will be sited on the east side of the new addition. The area will be screened with a metal barrier screen wall as shown on the site plans and detailed on the landscape details. P&Z Follow-up 7/22: OK Article 8: Form Based Code 8.04B(2) Public Facilities on the Official Map: Please provide a draft irrevocable offer for the planned public street. Applicant Response 6/17: The driveway is no longer proposed to be a public street. P&Z Follow-up 7/22: OK 8.04F Alleys: Should there be a raised crosswalk at the west crosswalk? Applicant Response 6/17: The grading design needs this crosswalk to be flush. We have designed the crosswalks to be constructed of pavers or concrete so the material change clearly delineates the crosswalk. P&Z Follow-up 7/22: OK 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV 8.05B(3) Parking: While you may keep existing parking, you may not propose new parking within 140-ft of Williston Road or the planned public street. There does not appear to be an exception for ADA parking in this section. Applicant Response 6/17: It is our understanding that staff agrees that the parking is considered existing as long as we are not increasing pavement or number of spaces. The lot will largely be improved to increase landscaping within and around it. The existing spaces closest to Williston Road will be removed and replaced with landscaping. The existing 37 spaces will be reduced to 30 and over 1,900 s.f. of impervious will be converted to vegetation. P&Z Follow-up 7/22: The ADA spaces may remain but the one new space that is not ADA that is to the front of the proposed building must be removed. Applicant Response 8/16: The additional, non ADA space, has been removed from the plans. The updated plans reflect this change. 8.06G Rooftop Elements: How is the view of roof access shaft and mechanical shaft minimized? Screening, sheathing in consistent architectural materials, other? Applicant Response 6/17: The mechanical shafts, mechanical equipment, and the elevator overrun will be clad in, or screened by, metal panels (solid or louvered as appropriate) – color to match the facade. The roof access is via exterior wall-mounted ladder from the lower roof. The lower roof is accessed by a standard door. P&Z Follow-up 7/22: Please clarify. No revised architectural plans showing this modification have been provided. The ladder would need to be on a non-street façade (ie the north) and screened from view of the street. Applicant Response 8/16: Here is the roof access ladder location in the image below. It's on the unregulated North façade and is not visible from the street. 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV What is height & area of roof access hatch? Applicant Response 6/17: There is no longer a hatch proposed P&Z Follow-up 7/22: OK What is height of elevator shaft? Applicant Response 6/17: Elevator shaft height is 4 ft above the roof surface. P&Z Follow-up 7/22: OK 8.06G(4) Utility Features: Electric service is located on interstate façade. Will there be a meter? On which side is gas service? Applicant Response 6/17: There will be an electric meter and refrigerant piping on the east side (interstate façade) of the building. There will not be a gas service to the new building. P&Z Follow-up 7/22: OK 8.07 Prohibited Materials: You have provided an exterior materials sheet but it does not appear to address all of the provided materials, Applicant Response 6/17: The exterior materials sheet is intended to show sample images of the major facade materials. It is not intended to provide a sample image for every material. For example, a finish identified on elevation sheet Z21, but not identified on the exterior materials sheet Z26 is the precast sill, which will be a standard grey/buff precast sill. P&Z Follow-up 7/22: OK nor do the plans indicate which exterior materials will be provided where. Applicant Response 6/17: The South Elevation sheet Z21 contains notes indicating the typical locations of the materials. The material labels match the materials indicated on the exterior materials sheet Z26. The other elevation sheets do not contain labels, but the color scheme indicates the corresponding materials. We are happy to provide clarification if the labeling of the locations of materials is unclear. P&Z Follow-up 7/22: OK 8.08 Open Space: When the area required for bicycle parking is removed, the parklet does not meet the minimum area requirements. The pocket park does provide adequate area, however, it is designed as more of a pocket plaza. Will you accept the revised designation? Applicant Response 6/17: The Civic Space requirement for the hotel addition is met in the proposed Pocket Park on the west side of the entrance drive so we removed the open space designation from the area at the bicycle parking. P&Z Follow-up 7/22: Please clarify what is meant by the double fence line to the west and the notation “fence w/ pedestrian gap.” Applicant Response 8/16: We are proposing the addition of a low but sturdy fence (see LH-002, Detail #13) within the Doubletree parcel that will delineate the property line and prevent cars from (inadvertently) driving into the Pocket Plaza from the adjacent property’s gravel parking lot, which currently abuts the proposed stone dust seating area; however a pedestrian (4’) gap – no gate – would allow the public to access the Plaza from that parking lot on foot. 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV 8.11F Open Space for Nonconforming buildings: Please review this section. You must provide a total area of existing building, and designate the required qualifiable open space. Please also provide imperviousness of qualifiable open space. Applicant Response 6/17: The gross square footage of the existing building is 210,000 s.f. The North Champlain Wing represents 28,230 s.f. of that total, which will reduce the existing building gross square footage to 181,770 s.f. The gross square footage of the new addition is 47,012 s.f. for a total of 228,782 s.f. after construction is complete. The 6% Open Space requirement of gross floor area is calculated to be 13,727 s.f. This is provided in a 13,800 s.f. Pocket Park civic space/site amenity on the west side of the entrance drive as shown on the Open Space Plan, sheet LH-004. The impervious cover in the open space is 2,455 s.f. or approximately 18% coverage. P&Z Follow-up 7/22: OK Article 14: Site Plan 14.06B Relationship of Proposed Structures to Site: Please provide a statement of how you believe the proposed structure responds architecturally to the existing structure to which it is adjacent & connected. Applicant Response 6/17: The new structure responds to the existing structure in a few ways: 1. The new structure uses similar materials and colors 2. The new structure steps its height down adjacent to the existing building 3. While the new building must address the build-to zone at Williston Rd, it also consistently extends the approximate building line of the West side of the main hotel building P&Z Follow-up 7/22: OK 14.06H Utility Service: Comments of the South Burlington Water Department were provided on February 23, 2024. Most of the comments are boilerplate. Plan specific comments are as follows. Sheet CH401 Details. All water related details must conform to the Champlain Water District Specifications and Detail for the Installation of Water Lines and Appurtenances. This condition will be met and is noted on the waterline detail sheets. Sheet CH104- Site Utility Profiles, Water and Sewer. 1. There is an existing abandoned water main on the north side of Williston Road, parallel with the edge of road, that may be uncapped. This information is provided to inform the developer/engineer/contractor during any work planned along Williston Road including where the new pavers are proposed. A note has been added to plan sheet CH101 addressing this comment. 2. The proposed 10”x8” tapping sleeve shall comply with the CWD Specifications. This condition will be met. 3. We suggest additional in-line valves be installed on the 10” existing water main to be able to isolate it in the event of an emergency. The valves could be placed on the west side at the proposed new tap location for the new addition, and the east side of the 4” DI water line, thus enabling the isolation of that section of existing water main between the proposed new building and existing building and still keep water supply to each building. Three valves at each location are suggested. Please contact the SBWD if you have any questions. This has been discussed with the South 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV Burlington Water Department. A new water valve will be cut-in on the existing line to allow for isolation of the existing waterline for repairs, while maintaining water to the buildings. This valve is shown on CH102, east of the bridge connector, but may be subject to field adjustments. 4. All the proposed work is being connected to existing, aged private water infrastructure. Condition assessments of the infrastructure where it becomes exposed should be performed to aid the engineer and owner in determining life expectancy and conditions prior to project completion. The condition of the existing waterline will be evaluated during construction. P&Z Follow-up 7/22: As of today, I have not yet received updated comments from the SBWD. The SBWD indicated on 7/23 they had no additional comments on the revised plans. Article 3: General Provisions 3.19 On-Site Solar Photovoltaic Systems: Pursuant to 3.19(B)(4), please show the alternative system and demonstrate it is adequate to meet the expected building usage. Applicant Response 6/17: The hotel roof area is approximately 10,500 s.f. after subtracting the exempt areas. 40% coverage of the roof area is 4,156 s.f. A Roof Solar Sketch is included that shows the area needed to meet the 40% coverage requirement. Due to vents and mechanical risers, the panels may have to shift a bit but there is sufficient room to meet this requirement. P&Z Follow-up 7/22: OK Article 13: Supplemental Regulations 13.02 Off Street Parking and Loading: The City Fire Marshall provided the following comments. There is an inconsistency in the submittals regarding the skybridge. Elevations show the connection at 3rd floor of the new bldg.. while floor plan layout indicates the connection at the second level. Please confirm and correct the plans. Applicant Response 6/17: The drawings are correct: The floor level of the skybridge is at Level 2 of the new building. The elevation drawings Z22, Z23, and Z24 all show the bridge at Level 2 of the new building consistent with the floor plans. Sheet Z110, Z112, and Z120 also depict the skybridge, And these drawings also show the floor levels of the existing building. The skybridge connects to Level 3 of the existing building. Sheet Z120 “Section at Skybridge” provides the clearest view of this relationship, including the absolute elevations of the floor levels of the existing and new buildings. You can see that Level 2 of the new building and Level 3 of the existing building are at the same absolute elevation of 354’-7 15/16” P&Z Follow-up 7/22: OK 13.03 Bicycle Parking and Storage: Please provide the total area of existing building and demonstrate the short term bicycle parking are met for the site as a whole and that the long term bicycle parking requirements for the area of the addition. Applicant Response 6/17: The gross square footage of the existing building is 210,000 s.f. The North Champlain Wing represents 28,230 s.f. of that total, which will reduce the existing building 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV gross square footage to 181,770 s.f. The gross square footage of the new addition is 47,012 s.f. for a total of 228,782 s.f. after construction is complete. At 1 short term space per 5,000 gsf, 23 short term bike racks for 46 bicycle parking spaces are required. Long-term bike parking is only required for the 47,012 s.f. of the addition. At 50% of 1 long-term space per 5,000 gsf, 5 long term spaces are required. These spaces will be provided in three dual bike lockers that are sited adjacent to the parking lot that is proposed to replace the demolished North Champlain hotel wing. P&Z Follow-up 7/22: OK. Please update other plans to reflect long-term bike parking as shown on sheet CH-104. This may be addressed as a condition of approval if desired. Applicant Response 8/16: The plan revisions for the long-term bike parking are included with this submittal. 13.04 Landscaping: The City Arborist provided the following comment Tree Protection measures should be specified and shown on the plans for existing trees that are being retained. Also, it looks like they may be treating the Ash trees at the entrance and around the parking lot for Emerald Ash Borer, and it will be necessary to continue treatments for the life of the trees to provide adequate protection. Please revise plans to include tree protection for City Arborist review. Applicant Response 6/17: Please refer to the Existing Tree Plan, sheet LH-005 P&Z Follow-up 7/22: As of today, I have not yet received updated comments from the City arborist. The City Arborist reviewed the revised plans on 7/23 and indicated there were no concerns. 13.04B(1) Parking Lot Perimeter Landscaping: There is no screening provided where parking abuts the future public street. Though this parking aisle is not modified, the landscaping is. Can instead the lilacs be pushed farther from the edge of curb and snow storage be located there? Applicant Response 6/17: Shrubs have been added to completely screen the parking from both Williston Road and the driveway. P&Z Follow-up 7/22: With this application you are proposing to modify parking lot & stormwater on adjoining site. Site plan application for adjoining site must be submitted. Applicant Response 8/16: A Site Plan application for the portion of the project located on UVM property was submitted on 8/8/2024. We are very hopeful that review and approval can be approved independently of this Form Based Code project. 13.04B(2) Parking Lot Interior Landscaping: Compliance with this criterion will be reviewed when non-complying parking spaces are removed. Applicant Response 6/17: We meet the interior island landscape requirement of 10% for both the reconfigured parking lot and the new parking lot in the footprint of the demolished hotel wing. P&Z Follow-up 7/22: Please demonstrate compliance with a figure. The 10% must be met either for the parking area as a whole or for the new area by itself. As an area by itself, the 10% is not provided. See screen shot. Applicant Response 8/16: Please see attached diagrams in the pdf exhibit “Parking_Islands Study_08.15.24” 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV 13.04B(4)(c) Tree Caliper: “JVE” are proposed to be 6’ – 7’ caliper. Presumably this is an error, otherwise I’m excited for these trees. Applicant Response 6/17: This should read “height” P&Z Follow-up 7/22: OK 13.04B(7) Snow Storage: An additional snow storage for the long east-west driveway should be provided. Applicant Response 6/17: An additional snow storage area at the east end of the driveway has been provided. Refer to plan CH101. P&Z Follow-up 7/22: OK 13.04D Front Yards of Non-Residential Uses: As in 13.04B(1) above, please provide plantings along the planned public street in the parking area proposed to be modified. Applicant Response 6/17: Please see plan sheet LH-001. P&Z Follow-up 7/22: OK 13.04G(3) Landscaping Budget: There is a note in the application form that the building cost of $15,000,000 includes site improvements. Please provide a building cost only for the purpose of required minimum landscape budget calculation. Applicant Response 6/17: The hard costs for the project, which include sitework, but not landscaping, is $18,132,200. The landscaping budget requirement is therefore calculated to be $188,822 based on 3% for the first $250,000, 2% for the second $250,000 and 1% based on the remaining $17,632,200 of the construction costs. The attached estimated Landscape Budget shows that the minimum requirement is exceeded ($217,720.00). 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV P&Z Follow-up 7/22: Please provide a cost for the BUILDING ONLY, excluding site work. Please also note that while you must provide a cost for landscaping within parking lots, the value of required parking lot shade trees must be excluded from computation of the minimum landscaping budget requirements Applicant Response 8/16: Please see revised landscape cost estimate, which addresses both issues, and please see comments below for 13.04. 13.04I Landscaping Maintenance: New Comment 7/22 Please describe how you are proposing to address the trees that are proposed to be removed. I spoke with Jeff relatively extensively about this & would like to know their proposal before reviewing in detail. Applicant Response 8/16: No previously-permitted plant material will be removed as part of this project in its current form. The only plant material that will be removed either pre-dated recorded permits or was planted voluntarily by previous management companies in the course of normal operations, not as part of permitted work. We have accounted for all plant material that is missing from the original permitted plan (ca. 1989) and all plant material that has been installed outside of permits that will be retained by this project and can, we believe, be credited towards it in the diagrams included with this submission (PDFs ‘Previously_Permitted_Planting’ and ‘Additional_Planting_Credits’) The project is proposing to add $273,709 in landscape value (including special paving and site furnishings). $156,466 is required according to the City formula (based on building-only cost). $130,176 would be required to replace all missing plant material shown in the 1989 permit site- wide. (We do not have any way of knowing when and under what circumstances that planting was altered, died, etc. – we just tallied up what remains and backed that quantity out of the total 1989 plant schedule value.) We also tallied up the plant material that has been added above and beyond any permits over time, which we believe totals $26,100, so our total budget owed combining new work and the replacement of old work would be $286,642, and we are providing $299,809 between proposed site improvements and credits for additional planting that will remain. 13.05 Stormwater Management New Comment 7/22: The City Stormwater Section provided updated comments on July 11, as follows. Please address. 1. Please provide an updated stormwater narrative reflecting the changes made since the pre- vious iteration of this design. Applicant Response 8/16: An updated stormwater narrative and associated stormwater plans are attached. 2. The drainage area plans provided still reflect the old design, which includes the infiltration chambers for the rooftop runoff and the smaller footprint for gravel wetland 1. The Hydro- CAD also includes the infiltration chambers for rooftop runoff, which I assume this area will flow to gravel wetland 1 now that it will be parking and not rooftop. Applicant Response 8/16: The stormwater plans and HydroCAD model have been updated to remove the Catamount Woods and garage structure projects. The revised plans and model are attached. 180 MARKET STREET, SOUTH BURLINGTON, VERMONT | (802) 846-4107 | WWW.SOUTHBURLINGTONVT.GOV 3. The provided drainage areas indicate that the new sidewalk to the west of the site is pro- posed to be captured and conveyed to gravel wetland #1, however, based on the grading of the site, this impervious will flow toward the treatment practice near the UVM rugby field. Please revise or provide information on the rugby field treatment practice if this is in- tended to capture the new sidewalk. Applicant Response 8/16: The new sidewalk along the west side of the driveway is no longer included in the project. The updated stormwater plans and narrative clarify the project limits and stormwater treatment. 4. Contractor should utilize straw wattles for erosion control as opposed to compost filter socks to prevent leaching of phosphorus into site runoff. Applicant Response 8/16: The reference to using SiltSoxx compost filled sediment filters has been replaced with straw wattles. The revised EPSC plans are attached. 13.07 Exterior Lighting New comment 7/22: The illumination levels from the parking lot fixture nearest the proposed building to the west are higher than those resulting from adjacent identical fixtures. Please check calculations. Furthermore, illumination levels must be reduced to 0.3 footcandles maximum at the property line Applicant Response 8/16: Photometric plan re-run by Apex Lighting and is correct – see revised LH-003. Light levels exceed 0.3 footcandles in three locations along the Williston Road portion of the property line only. The three locations consist of the intersection of the main drive and Williston Rd., where it seems useful to us to ensure adequate light levels for pedestrians at the bus stop and parklet; and in front of the two new doors on Williston Rd., to illuminate the new connecting walkways, which we believe is necessary for street-facing entrances to the building. Does the standard apply in the case of the streetscape property line as well? If we remove or relocate the three fixtures in question, Is the public ROW currently lit well for increased pedestrian activity?