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AGENDA REPORT 2022 1122 REG PC ITEM 08A
CITY OF MOORPARK, CALIFORNIA Planning Commission Meeting of November 22, 2022 Item: 8.A. ACTION: Approved Staff Recommendation, Including Adoption of Resolution No. PC-2022-685 with Modified Conditions of Approval. BY: J. Lugo A.Consider Resolution No. PC-2022-685, Recommending to the City Council Conditional Approval of Tentative Parcel Map No. 2022-01 to Subdivide an Approximately 41-Acre Lot into Two Parcels, Located at 14370 White Sage Road, and Making a Determination of Exemption Pursuant to the California Environmental Quality Act in Connection Therewith, on the Application of Tanner Shelton on Behalf of Ensign Bickford Aerospace & Defense. Staff Recommendation: 1) Open the public hearing, accept public testimony, and close the public hearing; and 2) Adopt Resolution No. PC-2022-685 recommending to the City Council conditional approval of Tentative Parcel Map No. 2022-01, and finding the project Exempt from the California Environmental Quality Act (CEQA). (Staff: Philip Neumann) MOORPARK PLANNING COMMISSION AGENDA REPORT TO: Honorable Planning Commission FROM: Philip Neumann, Associate Planner I DATE: 11/22/22 Regular Meeting SUBJECT: Consider Resolution No. PC-2022-685, Recommending to the City Council Conditional Approval of Tentative Parcel Map No. 2022-01 to Subdivide an Approximately 41-Acre Lot into Two Parcels, Located at 14370 White Sage Road, and Making a Determination of Exemption Pursuant to the California Environmental Quality Act in Connection Therewith, on the Application of Tanner Shelton on Behalf of Ensign Bickford Aerospace & Defense STAFF RECOMMENDATION 1.Open the public hearing, accept public testimony, and close the public hearing; and, 2.Adopt Resolution No. PC-2022-685 recommending to the City Council conditional approval of Tentative Parcel Map No. 2022-01, and finding the project Exempt from the California Environmental Quality Act (CEQA). PROJECT DESCRIPTION AND BACKGROUND On June 1, 2022, Tanner Shelton on behalf of Ensign Bickford Aerospace and Defense submitted an application for a Tentative Parcel Map, subdividing an approximately 41-acre lot into two parcels, located at 14370 White Sage Road (Attachment 1). A Tentative Parcel Map (TPM) is required when subdividing a property under common ownership into four or fewer parcels. This permit requires a decision by the City Council, following a recommendation by the Planning Commission. Item: 8.A. 2 Image of Proposed Parcel Map EXISTING AND SURROUNDING LAND USES Tentative Parcel Map No. 2022-01 is proposed to subdivide an approximately 41-acre parcel into two parcels of approximately 30 acres and 11 acres (Attachment 2 – Exhibit B). Currently, the parcel is occupied by an existing Ensign Bickford Aerospace & Defense Moorpark Facility, which operates approximately 145,549 square feet of industrial space on a 30-acre campus. The proposed 11-acre site is vacant, except for an access roadway approximately 2,026 feet in length (Attachment 2 – Exhibit B). Development of the property was approved by City Council on August 21, 1996 by Resolution No. 96-1222 through General Plan Amendment No. 95-1, Zone Change No. 95-3, Vesting Tentative Map No. 5004, and Industrial Planned Development Permit No. 95-2 for Special Devices, Inc. On September 22, 1997, Minor Modification No. 1 to IPD 95-2 was approved by City Council to modify the site plan and elevations through Resolution No. 97-1383. -- 11!) _________ ,.._ ~ =::!-l,~~""!.":,~. IJlJ S.W':-i:...-~&:.-=:.-r..-- lEI ;';..,':':""'-~----J:rz:-• liJ ::=:."'="..:.=:----::::.;-=..~ :.-.:---:.::.-;::.:,::-... .., --00 __ ,. _______ .. _ llll S::::.':fl:'.:-,;:t-•--.. IE =:'='-":.':"-.':"'..:--..,--• fil :::...:=(-.... ___ ...., l!I ~-=-!"':":':::::-.. ~•.::.;- 1-------I --------u--...-•--s-••-- ll1lli1I..flltt ""'-"LO!l4 -'5'!'"::;;-==:=~ =~ ··-· -- ...... !t -c::::J-•-· c:::::J •----., □--- 3 Table 1 below summarizes the existing General Plan and zoning designations, and existing land use on the Project site and adjacent properties. The proposed tentative parcel map has been designed to comply with the requirements of the City’s General Plan in providing separate industrial parcels, including one for potential future development to encourage a diversity of industrial uses. Additionally, the proposed lots comply with the applicable Municipal Code standards for lot size requirements in the limited industrial (M- 2) zone. Table 1 – Existing and Surrounding Land Use Direction General Plan Zoning / Specific Plan Existing Land Use Site Limited Industrial (M-2) Light Industrial (I-1) Ensign Bickford Aerospace & Defense Moorpark Facility and vacant land North Open Space (OS) & Commercial Planned Development (CPD) Open Space 1 (1 DU/40 AC) (OS-1) & Floodway (FLDWY) & General Commercial (C-2) Open Space & Floodway & Warehouse Discount Center South Open Space (OS-40AC) Open Space 2 (1 DU/10-40AC) (OS-2) Open Space East Open Space (OS-40AC) Open Space 2 (1 DU/10-40AC) (OS-2) Open Space West Open Space (OS-40AC) & SR-23 FWY Open Space 2 (1 DU/10-40AC) (OS-2) & SR-23 FWY Open Space & Hotel & California State Route 23 ANALYSIS The proposed subdivision of the approximately 41-acre parcel would result in the creation of two parcels, one measuring at approximately 30 acres and the other measuring at approximately 11 acres. The proposed subdivision would not affect or change the architecture, setbacks, building height, or the main access of proposed Parcel 1 as approved under IPD 95-2. The existing development on Parcel 1 maintains adequate fire protection, water, sanitation and routine waste management, all of which would have been analyzed previously. The primary intent of this proposed subdivision is to create two parcels without any proposed development (Attachment 2 – Exhibit B) at this time. A condition of approval has been added (Attachment 2 – Exhibit A), highlighting that no development or site improvements are proposed with this tentative parcel map. Any proposed development would occur under its own industrial planned development (IPD) permit. The main access to both parcels is via White Sage Road. However, future 4 improvements, including roadway and infrastructure, would be reviewed with a request for development. While the main access is via White Sage Road, an initial easement would be required for access to Parcel 2 as one of the conditions of approval (Attachment 2 – Exhibit A) prior to the approval of a Final Map. All other existing access easements will remain in place with the proposed tentative parcel map. During review of the application, the map was provided to selected City staff and outside agencies for review and the opportunity to provide conditions. This included the City of Moorpark Public Works Department, Ventura County Fire Department, Moorpark Police Department, County of Ventura Waterworks District No. 1, County of Ventura Water and Sanitation, County of Ventura Air Pollution Control District, California Department of Transportation, Southern California Edison, and Ventura County Watershed Protection District. The City of Moorpark Public Works Department has provided conditions of approval, which have been incorporated within Attachment 2 – Exhibit A. All other departments as noted above considered the proposed map and no additional concerns or conditions of approval have been provided at this time. Pursuant to a condition of approval, the applicant will need to coordinate with all outside agencies confirmation of any required easements (Attachment 2 – Exhibit A). The parcel is located within the Very High Fire Hazard Severity Zone. The resulting two parcels with the subdivision would not change any current access the Ventura County Fire Department (VCFD) has to the land. Fire access would be re-examined when an application for a proposed development is received. The land would continue to have fire protection and suppression services. VCFD has reviewed the request and does not have any conditions of approval for the proposed TPM. PROCESSING TIME LIMITS Time limits have been established for the processing of development projects under the Permit Streamlining Act (Government Code Title 7, Division 1, Chapter 4.5), the Subdivision Map Act (Government Code Title 7, Division 2), and the California Environmental Quality Act Statutes and Guidelines (Public Resources Code Division 13, and California Code of Regulations, Title 14, Chapter 3). Under the applicable provisions of these regulations, the following timelines have been established for action on this project: Date Application Filed: June 1, 2022 Date Application Determined Complete: July 1, 2022 Planning Commission Deadline: August 30, 2022 Planning Commission Extended Deadline 1: November 28, 2022 City Council Action Deadline: 30 Days from Receipt of Planning Commission Report 1 The applicant requested a 90-day extension due to addressing City and outside agency comments. 5 ENVIRONMENTAL DETERMINATION In accordance with the City’s environmental review procedures adopted by resolution, the Community Development Director or designee determines the level of review necessary for a project to comply with the California Environmental Quality Act (CEQA). Some projects may be exempt from review based upon a specific category listed in CEQA. Other projects may be exempt under a general rule that environmental review is not necessary where it can be determined that there would be no possibility of a significant effect upon the environment. A project which does not qualify for an exemption requires the preparation of an Initial Study to assess the level of potential environmental impacts. The Director has reviewed this project and found it to be Categorically Exempt in accordance with Section 15315 (Class 15: Minor Land Divisions) of the CEQA Guidelines because the applicant is proposing a division of property that would result in the creation of two parcels, does not require a variance or exception, services and access to the proposed parcels would be required through any future planned development permits, the parcel was not involved in a division of a larger parcel within the previous two years, and the parcel in its existing state has an average slope of less than 20% at 10.98%. Additionally, no development or improvements are proposed with this request that could result in additional impacts. Therefore, pursuant to CEQA, no further environmental review is required. NOTICING Public Notice for this meeting was given consistent with Chapter 17.44.070 of the Zoning Ordinance as follows: 1. Publication. The notice of the public hearing was published in the Ventura County Star on November 11, 2022. 2. Mailing. The notice of the public hearing was mailed on November 10, 2022, to owners of real property, as identified on the latest adjusted Ventura County Tax Assessor Roles, within 1,000 feet of the exterior boundaries of the assessor’s parcel(s) subject to the hearing. 3. Sign. One 32 square-foot sign was placed on the street frontage on November 10, 2022. ATTACHMENTS 1. Location and Aerial Maps 2. Draft Resolution with Conditions of Approval and Tentative Parcel Map No. 2022-01 6 Location Map - 14370 White Sage Road PC ATTACHMENT 1 \ \ 1" = 899 ft Tentat i ve Pa r cel M ap 11 /02/2022 .; No. 2022~01 ; . This map may f E:firesems a visua l dispiay of rel o~d g eograp hlc in fo rmation , Data pro'Vlded f'lere-cm is 001 g uaramee of arutual fte!d conditlons. To be .s.u re of complete accu,acy. pl ea.s e contact t he re~por,sibl estaf for most up-to-d ate 1nfo1mauon. 7 Aerial Map - 14370 White Sage Road 1" = 809 ft Tentative Parcel Map 11/02/2022 .; No. 2022~01 ; . This map may 1e-:1iresem.s-a visuaJ display of rel o~d geograp hlc information , Data pro'Vl ded f'lere-cm is 001 g uaramee of arutual fte!d conditlons . To be .s.u re of complete accu,acy. pl ea.se contact t he re~por,si"bl estaf for most up-to-date 1nfo1mauon. 8 jn ne1 Ċϳ ϳ Ģ5,ϳ524 % ſȹϳté5ŹŲϨϳ ŀäÐϭϳ ¬ϳ +ϳ¬Ƒϳ¬ϳ ƔϳxΖ¹ϳnĞϳă%ϳrvϳ%Wϳ ϳoϳ¦ϳ%ěëϳ ϳoϳA,% -$/:54-)1=.=2?, A"&! 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PROPOSED PARCEL 2 PLAN TENTATIVE PARCEL MAP 2022-01 WHITE SAGE ROAD ENSIGN-BICKFORD AEROSPACE UIT.J<FllfM:TMl--l/1HEQTf<F-fXU/Tf<F1f11'1!-""MttaaffR •-t.».Mlffl111)10l-M-»lr-ttaaffRII_.HliMtlr1 ll)lll«HHl/1HEomt:E:<F1HEIXU/1'f-<FSMI/X/U/Tf; SHEET 3 DK NAMC:~112-11'11-t»-O.J.., OF J 11 RESOLUTION NO. PC-2022-685 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF MOORPARK, CALIFORNIA, RECOMMENDING TO THE CITY COUNCIL APPROVAL OF TENTATIVE PARCEL MAP NO. 2022-01 TO SUBDIVIDE AN APPROXIMATELY 41-ACRE LOT INTO TWO PARCELS, LOCATED AT 14370 WHITE SAGE ROAD, AND MAKING A DETERMINATION OF EXEMPTION PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT IN CONNECTION THEREWITH, ON THE APPLICATION OF TANNER SHELTON ON BEHALF OF ENSIGN BICKFORD AEROSPACE & DEFENSE WHEREAS, on June 1, 2022, an application was filed for a Tentative Parcel Map (TPM) No. 2022-01, to subdivide an approximately 41-acre lot into two parcels, located at 14370 White Sage Road; and WHEREAS, at a duly noticed public hearing on November 22, 2022, for TPM No. 2022-01, the Planning Commission considered TPM No. 2022-01, including the agenda report and any supplements thereto and written public comments; opened the public hearing and took and considered public testimony both for and against the proposal; and WHEREAS, the Community Development Director has determined that TPM No. 2022-01 is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Sections 15315 (Class 15: Minor Land Divisions) of the CEQA Guidelines. NOW, THEREFORE, THE PLANNING COMMISSION OF THE CITY OF MOORPARK, DOES HEREBY RESOLVE AS FOLLOWS: SECTION 1. ENVIRONMENTAL DOCUMENTATION: The Planning Commission, based on its own independent analysis and judgment, concurs with the Community Development Director’s determination that the project is categorically exempt from the requirements of the CEQA pursuant to Section 15315 (Class 15: Minor Land Divisions) of the CEQA Guidelines because the applicant is proposing a division of property that would result in the creation of two parcels, does not require a variance or exception, services and access to the proposed parcels would be required through any future planned development permits, the parcel was not involved in a division of a larger parcel within the previous two years, and the initial parcel has an average slope of less than 20% at 10.98%. No further environmental documentation is required pursuant to CEQA. SECTION 2. TENTATIVE PARCEL MAP FINDINGS: Based upon the information set forth in the staff report(s), accompanying studies, and oral and written 12 public testimony, the Planning Commission makes the following findings in accordance with City of Moorpark, Municipal Code Section 17.44.040: A. As outlined in the project record, including the agenda report, the proposed map depicted in Exhibit B, including its design, is consistent with the City’s General Plan and Zoning Ordinance as proposed, and conditioned, in that the map has been designed to comply with the requirements of the City’s General Plan in providing separate industrial parcels, including one for potential future development to encourage a diversity of industrial uses, and that the proposed lots comply with the applicable Municipal Code standards for lot size requirements in the limited industrial (M-2) zone. B. As outlined in the project record, including the agenda report, the Project Site, as depicted in Exhibit B, is physically suitable for the type and intensity of development proposed in that there would be a future potential industrial development located at that site, which corresponds to the industrial zoning, but no development proposed with this subdivision on proposed Parcel 2. Additionally, proposed Parcel 1 contains an existing development that would not be altered, including access and setbacks, with the approval of this tentative parcel map. Therefore, as no development is proposed, the Project is consistent with this finding. C. As outlined in the project record, including the agenda report, the design of the subdivision, as depicted in Exhibit B, would not conflict with easements acquired by the public at-large for access, including streets and trails, through or use of the property within the proposed subdivision because existing access easements will remain in place with the proposed tentative parcel map. D. As outlined in the project record, including the agenda report, the design of the subdivision and the proposed improvements, as depicted in Exhibit B, are not likely to cause substantial environmental effects in that there are no proposed improvements with this subdivision and the proposed lot boundaries are zoned for industrial development. Proposed Parcel 1 includes an existing development and proposed Parcel 2 would available for future industrial development and subject to environmental review at that time depending on the proposal. E. As outlined in the project record, including the agenda report, the design of the subdivision, as depicted in Exhibit B, is not likely to cause serious public health problems, in that adequate fire protection, water, sanitation and routine waste management exist to serve the existing development on proposed Parcel 1 and there is no development proposed on Parcel 2 that would alter existing conditions of the site. F. As outlined in the project record, including the agenda report, there would be no discharge of waste from the proposed subdivision, as depicted in Exhibit B, into an 13 existing community sewer system in a manner that violates existing water quality control requirements pursuant to Water Code Section 13000 et seq in that the site on proposed Parcel 1 has already been developed, and there is no proposed development on Parcel 2. G. As outlined in the project record, including the agenda report, adequate water supplies exist to meet existing demands, anticipated demands from approved projects and tentative maps, and the anticipated demands of the proposed Project, as depicted in Exhibit B, in that Parcel 1 includes an existing development with existing water service that would have been analyzed previously, and that there is no proposed development on Parcel 2 with this proposed subdivision. Any future development would be subject to the California Environmental Quality Act standards at the time of review. H. As outlined in the project record, including the agenda report, the proposed map, as depicted in Exhibit B, is consistent with regulations adopted by the State Board of Forestry and Fire Protection pursuant to Sections 4290 and 4291 of the Public Resources Code and with the requirements of the Ventura County Fire Protection District Ordinance regulating fire land life safety for new developments, in that that the development on proposed Parcel 1 is existing and there is no proposed development on Parcel 2. The Ventura County Fire Protection District has reviewed the request and does not require any conditions of approval for the proposed Tentative Parcel Map. I. As outlined in the project record, including the agenda report, the proposed map, as depicted in Exhibit B, would continue to have structural fire protection and suppression services provided by the Ventura County Fire Department. SECTION 3. PLANNING COMMISSION RECOMMENDATION: The Planning Commission herby recommends to the City Council approval of TPM 2022-01 subject to the Standard and Special Conditions of Approval found in Exhibit A attached. 14 SECTION 4. FILING OF RESOLUTION: The Community Development Director shall cause a certified resolution to be filed in the book of original resolutions. The action of the foregoing direction was approved by the following vote: AYES: NOES: ABSENT: ABSTAIN: PASSED, AND ADOPTED this 22nd day of November 2022. Kipp Landis Chair Carlene Saxton Community Development Director Exhibit A – Conditions of Approval Exhibit B – Tentative Parcel Map No. 2022-01 15 EXHIBIT A CITY OF MOORPARK CONDITIONS OF APPROVAL Project Approval Date: Expiration Date: Location: 14370 White Sage Road Entitlements: Tentative Parcel Map No. 2022-01 Project Description: Subdivide an approximately 41-acre lot into two parcels. The applicant/permittee is responsible for the fulfillment of all conditions and standard development requirements, unless specifically stated otherwise. General Conditions In addition to complying with all applicable City, County, State and Federal Statutes, Codes, Ordinances, Resolutions and Regulations, Development Agreements, Permittee expressly accepts and agrees to comply with the following Conditions of Approval and Standard Development Requirements of this Permit: 1. Within thirty (30) calendar days of approval of this entitlement, the applicant shall sign and return to the Planning Division an Affidavit of Agreement and Notice of Entitlement Permit Conditions of Approval, indicating that the applicant has read and agrees to meet all Conditions of Approval of this entitlement. The Affidavit of Agreement/Notice shall include a legal description of the subject property and have the appropriate notary acknowledgement suitable for recordation. [CDD] 2. This Tentative Parcel Map expires two (2) years from the date of its City Council approval unless the Final Parcel Map has been approved. The Community Development Director may, at his/her discretion, grant up to two (2) additional one- year extensions for use inauguration of the conditional use permit if there have been no changes in the adjacent areas and if the applicant can document that he/she has diligently worked towards use inauguration during the initial period of time. The request for extension of this Tentative Parcel Map must be made in writing, at least thirty (30) days prior to the expiration date of the permit and must be accompanied by applicable entitlement processing deposits. [CDD] 3. The Conditions of Approval of this entitlement and all provisions of the Subdivision Map Act, City of Moorpark Municipal Code and adopted City policies at the time of the entitlement approval, supersede all conflicting notations, specifications, 16 dimensions, typical sections and the like which may be shown on said Map and/or plans or on the entitlement application. This language shall be added as a notation to the Final Map and/or to the final plans for the planned development. [CDD] 4. Conditions of this entitlement may not be interpreted as permitting or requiring any violation of law or any unlawful rules or regulations or orders of an authorized governmental agency. [CDD] 5. Should continued compliance with these Conditions of Approval not be met, the Community Development Director may modify the conditions in accordance with Municipal Code Section 17.44.100 and sections amendatory or supplementary thereto, declare the project to be out of compliance, or the Director may declare, for some other just cause, the project to be a public nuisance. The applicant shall be liable to the City for any and all costs and expenses to the City involved in thereafter abating the nuisance and in obtaining compliance with the Conditions of Approval or applicable codes. If the applicant fails to pay all City costs related to this action, the City may enact special assessment proceedings against the parcel of land upon which the nuisance existed (Municipal Code Section 1.12.170). [CDD] 6. The applicant shall defend, indemnify and hold harmless the City and its agents, officers and employees from any claim, action or proceeding against the City or its agents, officers or employees to attack, set aside, void, or annul any approval by the City or any of its agencies, departments, commissions, agents, officers, or employees concerning this entitlement approval, which claim, action or proceeding is brought within the time period provided therefore in Government Code Section 66499.37 or other sections of state law as applicable and any provision amendatory or supplementary thereto. The City will promptly notify the applicant of any such claim, action or proceeding, and, if the City should fail to do so or should fail to cooperate fully in the defense, the applicant shall not thereafter be responsible to defend, indemnify and hold harmless the City or its agents, officers and employees pursuant to this condition. a. The City may, within its unlimited discretion, participate in the defense of any such claim, action or proceeding if both of the following occur: i. The City bears its own attorney fees and costs; ii. The City defends the claim, action or proceeding in good faith. b. The applicant shall not be required to pay or perform any settlement of such claim, action or proceeding unless the settlement is approved by the applicant. The applicant's obligations under this condition shall apply regardless of whether a Final Map is ultimately recorded with respect to the subdivision or a building permit is issued pursuant to the planned development permit. [CDD] 7. If any of the conditions or limitations of this approval are held to be invalid, that holding does not invalidate any of the remaining conditions or limitations set forth. [CDD] 8. All facilities and uses, other than those existing on-site at the time of this permit, are prohibited unless otherwise permitted through a planned development permit, or other required permit application, consistent with the requirements of the zone and 17 any other adopted ordinances, specific plans, landscape guidelines, or design guidelines. [CDD] 9. Entitlement Processing: The applicant shall submit to the Community Development Department all outstanding entitlement case processing fees, including all applicable City legal service fees. This payment must be made within sixty (60) calendar days after the approval of the Final Map. [CDD] 10. The continued maintenance of the subject site and facilities is subject to periodic inspection by the City. The applicant and his/her successors, heirs, and assigns are required to remedy any defects in ground or building maintenance, as indicated by the City within five (5) working days from written notification. [CDD] 11. The applicant and his/her successors, heirs, and assigns must remove any graffiti within five (five) days from written notification by the City of Moorpark. All such graffiti removal must be accomplished to the satisfaction of the Community Development Director. [CDD] Permit Specific Conditions – Tentative Parcel Map 12. Prior to Final Map approval and recordation, Developer shall provide evidence of a recorded permanent access easement for Parcels 1 and Parcel 2 to the nearest public right-of-way, as approved by the City Engineer/Public Works Director. [CDD] 13. Prior to Final Map approval and recordation, applicant shall coordinate with all outside agencies confirmation of any required easements. [CDD] 14. No development or site improvements are proposed with this tentative parcel map. [CDD] Public Works/Engineering Department 15. Prior to Final Map approval and recordation, provide drainage covenants from adjacent property owners, subject to review and the satisfaction of the City Engineer. This includes, but is not to, APNs 513-0-050-225, 513-0-050-255, and 513-0-050-265. [PW] 16. Prior to Final Map approval and recordation, provide access agreements and covenants from adjacent property(ies), subject to review and the satisfaction of the Community Development Director and City Engineer. This includes access for an existing dirt road that is shown on the topographic background. [PW] 17. Prior to Final Map approval and recordation, provide maintenance agreement and/or covenants for all existing storm water infrastructure and conveyance facilities, subject 18 to review and the satisfaction of the Community Development Director and the City Engineer. [PW] 18. Western parcel line for Parcel 2 should be east of the existing terminus of White Sage Road (private road), as depicted on Sheets 1 and 2 of the proposed Tentative Parcel Map 2022-01. [PW] 19. Prior to Final Map approval and recordation, provide any slope maintenance easements, subject to review and the satisfaction of the Community Development Director, Parks and Recreation Director, and the City Engineer. [PW] 20. Easement E10 appears to be for drainage conveyance purposes. Please specify to what entity this easement is being dedicated to and for what benefit. [PW] END 19