POLICY REPORT
                                Urban Structure

                                           Date: February 20, 1997
                                           Dept. File No.  MG
                                           CC File:  8007-1
                                                     2604-1
                                                     2606-1

   TO:       Vancouver City Council

   FROM:     Director of Central Area Planning

   SUBJECT:  Downtown Vancouver Skyline Study - Recommended Option


   RECOMMENDATION

        A.   THAT the recommended skyline and general policy for higher
             buildings, as detailed in Appendix  C  of this report, be
             approved as the basis for adjustments to the maximum permitted
             heights in the Downtown Official Development Plan (ODP),
             noting that in the area covered by this ODP: 
             -  buildings up to but not exceeding 600' high will only be
                considered in the current 450' height area of the Central
                Business District, north of Robson Street;
             -  buildings up to 400' high will be considered in the north
                westerly current 300' height area of the Central Business
                District, generally south east of Bute and Pender Streets;
             -  in no case will building heights be considered that intrude
                into adopted view corridors (except the Queen Elizabeth
                Park view corridor); and
             -  elsewhere, buildings significantly exceeding current height
                specifications will generally not be considered.

        B.   THAT staff report back with text amendments for the Downtown
             Official Development Plan and design guideline amendments
             regarding the proposed changes to the permitted building
             heights and a process for considering higher buildings.

        C.   THAT buildings exceeding the current 450' height limit will
             not be considered until guidelines, zoning text amendments,
             review criteria and a process to enable the consideration of
             buildings at this scale are completed.

        D.   THAT the Skyline Study Advisory Committee be thanked for their
             time and effort and, further, that they be consulted during
             the implementation and follow-up work that is outlined in this
             report.

        E.   THAT the preparation of the text amendments and design
             guidelines for the implementation of the revised height limits
             be undertaken as soon as  staff resources become available to
             do this work, expected to be in 1998; and further that a
             budget in the amount of $6,000 be approved in the 1998 budget
             (subject to the availability of funds and priorities) for
             public meetings and computer resources to do this work.

   CONSIDERATION

        As an alternative to recommendation E:

        F.   THAT $18,000, as an addition to the 1997 Operating Budget, be
             approved for consultants, public meeting costs and computer
             resources to proceed with  preparation of zoning text
             amendments, design guidelines and the appropriate review
             process for immediate implementation of revised height limits
             in the Downtown District.

   GENERAL MANAGER'S COMMENTS

        The General Manager of Community Services notes that these
        recommendations are adding further complexity to the regulatory
        environment. As the desireability of any skyline form is very much
        a matter of community aesthetic taste as experienced through the
        community's elected representatives and as there is no correct
        technical alternative, the General Manager of Community Services
        submits A through F for CONSIDERATION.

   COUNCIL POLICY

   -    The View Protection Guidelines were approved on December 12, 1989
        and amended on December 11, 1990, establishing a number of view
        corridors in the downtown with height limits to protect views of
        the north shore mountains from a variety of locations south of the
        downtown peninsula (see Appendix 'D').

   -    The Downtown District Official Development Plan (ODP), the False
        Creek North ODP, the Coal Harbour ODP and the C-5, C-6, RM-5,
        RM-5A, RM-5B, RM-5C and RM-6 District Schedules regulate building
        heights in the downtown peninsula. Generally, heights in the
        Downtown District range from 450 ft., 300 ft., 150 ft., 90 ft., and
        70 ft. Elsewhere in the downtown peninsula, heights are 350 ft.
        (106 m) or less on the remainder of the north shore of False Creek,
        210 ft. (64 m) or less in the West End and 75 ft. (22.39 m) in
        Yaletown (See Appendix  C  for further details) The height limits
        in the Central Business District and Downtown South were originally
        set in the 1960's and confirmed in 1975. Elsewhere, height limits
        have been established as part of area-specific planning
        initiatives.

   SUMMARY

   Various people have commented that Vancouver's skyline lacks visual
   interest and there is a need for some taller buildings that reflect
   Vancouver's contemporary image. Others are worried about proposals for
   much higher buildings. Many are concerned that the natural setting and,
   in particular, the north shore mountains may be compromised as tall
   buildings proliferate. In response to these concerns and the desire to
   have a clear City policy for considering buildings that exceed current
   height limits, Council directed staff to undertake a Skyline Study.

   The Skyline Study prepared the following 5 prototypical skylines and
   illustrated them from eight vantage points:

       'build out' skyline (retain existing height limits);
       landmark - 600' skyline (2 landmark buildings at 600 feet);
       landmark - 750' skyline (2 landmark buildings at 750 feet);
       gap tooth skyline (8 buildings between 450 and 550 feet);
       dome skyline (12 buildings between 450 and 550 feet).

   During a public review of the prototypical skylines there was not a
   clear majority in support of any particular one. There is a split
   opinion about building height - with many suggesting taller buildings
   and others lamenting any further taller buildings. Most felt that the
   skyline is important and symbolic. The landmark - 750' was preferred by
   one-third of respondents attending the open houses  and meetings. The
   dome skyline was chosen by about one-fifth of respondents. The 'build
   out' or status quo skyline was favoured by approximately one-seventh of
   those commenting. The remaining comments indicated preferences either
   for other options or a hybrid of the prototypes or did not choose any of
   the prototypes. Many were concerned that the north shore mountains
   should remain the predominant element in the skyline.
   Staff are presenting for Council adoption (i) a recommended skyline that
   melds preferred features of the different prototypes but with an upper
   building height limit of 600 feet and (ii) a general policy for higher
   buildings (see Appendix 'C'). It is proposed that all buildings
   exceeding current height limits must be in the Central Business
   District, generally north of Robson Street. Detailed guidelines and
   special requirements are also suggested for buildings exceeding current
   height limits. Prior to approving such buildings, further work is
   required to prepare guidelines that address the massing, design and
   impacts of tall buildings and finalizing boundaries for where they will
   be permitted. This work will also outline a review process which
   includes Council approval of the buildings and review by a special
   panel.

   PURPOSE

   This report recommends a policy for downtown building heights to achieve
   a preferred profile for the Downtown Vancouver skyline. A work programme
   and resources for further work are also put forward for consideration.

   BACKGROUND

   Current downtown height limits allow for typical office, hotel and
   residential towers at maximum density allowances. The height limit also
   serves to generally protect public views of the north shore mountain
   backdrop from medium range vantage points in the city (i.e. south of
   Broadway). Close in views of the mountains are protected by selected
   view corridors (see Appendix 'D').

   In recent years, various people have questioned the current height
   limits. Their concerns are that:

       it appears that the skyline is becoming flat and does not have a
        peak;
       permitting higher buildings would add interest to the skyline;
       views of the north shore mountains are being lost and we should not
        be entertaining additional building height.

   With improved computer technology, the skyline that we will probably
   obtain if all development sites are built within current height
   allowances can be viewed. Options for  adjusting height limits can also
   be observed.

   On May 16, 1996, Council initiated a Downtown Vancouver Skyline Study to
   identify potential prototypical skylines for the future and recommend a
   preferred skyline. A consultant was hired in July and work began in
   August. A public review of work in progress was completed in October and
   a second public review was completed in mid-February  to examine the
   prototypes. The final conclusions of the study are based on the urban
   design analysis by staff and the consultants, input of a specially
   appointed Advisory Committee and comments received from the public. The
   consultant s  full report, completed by the Spaxman Consulting Group and
   Jankovic Consultants is on file with the City Clerk.

   Council s adoption of a general building heights policy for the skyline
   will conclude this study. However, there is essential follow-up work to
   implement such a policy, prior to which extraordinary building heights
   should not be considered.

   DISCUSSION

   The Skyline Prototypes

   The study was done on the assumption that existing density limits and
   view corridors (except the Queen Elizabeth Park corridor) would be
   respected. While this limited options, it reflects widely held public
   concerns that were reconfirmed in the public process.

   After reviewing many possibilities, five prototypical  skyline options
   were prepared for public discussion (see Appendix 'A'):

       a 'build out' skyline (resulting from no change in current height
        regulations);
       a landmark skyline - 600' (tallest buildings at 600 feet);
       a landmark skyline - 750' (tallest buildings at 750 feet);
       a gap toothed skyline;
       a dome shaped skyline.

   These prototypical skylines are created by hypothetically locating
   taller new buildings on a selected number of the 76 potential
   development sites in the downtown peninsula (while recognizing that the
   actual building locations could take a variety of specific patterns).
   The study examines the skylines from 8 vantage points that were selected
   through the public discussion. The tallest buildings in the prototypes
   (with the exception of the   build out  skyline) exceed the existing
   height regulations.

   The following general observations were drawn:

       the 'build out' skyline is not flat from most vantage points;
       higher buildings in the southern part of the downtown peninsula
        will appear much more dominant and block more northerly views in
        comparison to buildings in the northern part, because of the visual
        effects of foreshortening;
       while many people responded positively to higher buildings or more
        variety in building heights, most people strongly supported the
        predominance of the north shore mountain backdrop (especially the
        'Lions') and want this carefully preserved;
       landmark towers in the central business district core must be
        significantly taller (550 to 750 feet) to be noticeable in the
        skyline;
       the skylines are not dramatically different from each other due to
        the limited number of development sites, particularly in the core,
        and the height restrictions of the view corridors; and
       achieving a preferred form of skyline is problematic because
        depending on how and which sites are developed, a landmark skyline
        could evolve into a gap toothed skyline or ultimately to overall
        higher building heights.

   The Selection of a Preferred Form of Skyline

   As summarized below, staff evaluated the 5 prototypical skylines with
   consideration of the following factors:

       relationship to the natural setting (mountains and water);
       the location of the Central Business District is easily identified;
       providing visual interest;
       impact on sensitive areas such as residential neighbourhoods and
        parks;
       impact on the economic and business functions of the downtown;
       practicality of creating the skyline through height regulations and
        the straightforwardness of administration;
       level of public support for the skyline.

   Conclusions regarding each prototypical skyline are identified below.
   Since no one prototype best balanced urban design objectives and public
   preferences, a hybrid is recommended based upon what was learned from
   each one. A detailed list of pros and cons for each prototype is in
   Appendix 'B'.

   'Build Out' Skyline (Retain existing height regulations)

       The mountains remain the most significant element in the skyline.
       South of 12th Avenue, the tallest buildings are below the ridge
        line of the mountains.
       Apart from the mountain backdrop, the skyline does not have strong
        visual interest.
       There are minimal impacts on sensitive areas.
       There are no opportunities for landmark buildings (i.e., taller
        than existing buildings) in the core.
       There is no problem creating this skyline through height
        regulations.
       Public support for this option at the open houses and meetings  was
        13.6% (30 responses)(Also noted by the public as build-out-dome:
        0.5% for a total of 14.1%).

   This option would represent an acceptable future. However, it does not
   provide an opportunity to bring more visual interest to the skyline
   (beyond the mountain backdrop) and does not emphasize the location of
   the core with landmarks.

   Landmark - 600' Skyline (two towers at 600 feet)

       The mountains remain the most significant element of the skyline.
       The buildings are below the ridge line of the mountains from most
        areas south of 12th Avenue.
       Some visual interest created by 600 foot landmark towers.
       There are minimal impacts on sensitive areas.
       There are limited opportunities for landmark buildings in the core.
       Limiting the number of landmark towers to two will result in a
        relative monopoly situation and other owners will want to be dealt
        with equitably and have similar opportunities provided. This will
        result in difficulties administering the regulations.
       Public support at open houses and meetings was 6.3% (14 responses).

   This option is not recommended because it creates so few opportunities
   for taller buildings that would emphasize the core and it would be very
   difficult to administer equitably.

   Landmark - 750' Skyline (two towers at 750 feet)

       The mountains do not remain the most significant element of the
        skyline and the view of 'the Lions' is compromised from certain
        vantage points south of False Creek.
       Landmark buildings at 750 feet are not below the ridge line at 12th
        Avenue.
       Visual interest is created by 750 foot landmark towers.
       There are minimal impacts on sensitive areas.
       Limiting the number of landmark towers to two will result in a
        relative monopoly situation and other owners will want to be dealt
        with equitably and have similar opportunities provided. This will
        result in difficulties administering the regulations.
       At the open houses and meetings, 32.1% of those filling out a
        comment sheet chose this skyline (71 responses). (Also noted by
        public as: gap tooth-landmark 750': 4.1%, landmark 750'-dome: 1.8%
        for total of 38%).

   Although this is a popular option, it is not recommended because 
   buildings of 750 feet would intrude significantly into the mountain
   backdrop and profile, challenging the predominance of the mountains. It   would also block views of the 'Lions' from many locations south of False
   Creek. Moreover, it creates very few opportunities for taller buildings
   thus creating a difficult situation for equitably administering the
   regulations.

   Gap Tooth Skyline (8 towers between 450 and 550 feet)

       It makes the prevailing height of the overall skyline appear taller
        because buildings are located throughout the core, Triangle West
        and Downtown South.
       It begins to challenge the mountains as the most significant
        element of the skyline.
       The tallest buildings are below the ridge line at 12th Avenue.
       There is some visual interest created by having a series of towers
        that are higher than other towers.
       There are impacts on sensitive areas because some towers are in or
        adjacent to residential areas.
       There are some new opportunities for landmark office buildings in
        the core.
       This option would be less complex to administer through revised
        height regulations.
       At the open houses and meetings, public support for this option was
        12.2% (27 responses). (Also noted by public as: gap
        tooth-landmark-750': 4.1%; gap-tooth-dome: 1.4% for a total of
        17.7%).

   This option is not recommended because it would generally have the 
   affect of raising the sense of overall heights over the downtown
   peninsula without providing the benefits of shaping the skyline. It
   unduly diminishes the contrast between the building skyline and the
   mountain backdrop. It would have to include tall buildings (450 feet) in
   sensitive residential areas such as Downtown South and Triangle West.
   Taller buildings in Downtown South will appear even taller and intrusive
   from vantage points south of False Creek due to the effects of
   foreshortening.

   Dome Skyline (12 towers between 450 and 550 feet)

       The mountains remain the most significant element of skyline.
       The tallest buildings are below the ridge line at 12th Avenue.
       Some visual interest is created by having a dome shape.
       There are some impacts on sensitive areas because some towers are
        in or adjacent to residential areas.
       There are some new opportunities for landmark buildings in the core
        at early stages of new development.
       There are significant problems administering complicated height
        regulations because permitted heights for each building site would
        have to be individually calibred to ensure that a clear dome effect
        was being achieved.
       The public support for this option at open houses and meetings was
        17.6% of those responding to a comment sheet (39 responses). (Also
        noted by the public as: landmark 600'-dome: 2.7%; landmark
        750'-dome: 1.8%; gap tooth-dome: 1.4% for a total of 23.5%)

   This option would represent an acceptable future but it is very
   difficult to achieve a highly premeditated dome shape due to the height
   limits of the view cones. It would be complicated to administer the
   regulations with varying heights in the core and in shoulder areas in
   order to achieve the desired dome profile.

   Recommended Skyline and General Policy for higher Buildings

   Based on the analysis above and comments from the public and the
   Advisory Committee, staff and the consultants recommend a skyline which
   combines attractive features of several of the prototypes and
   incorporates the following principles:

       the mountain backdrop remains a predominant element in the skyline;
       the buildings do not block 'the Lions' from most vantage points
        south of False Creek;
       buildings significantly exceeding current height limits are limited
        to the Central Business District, generally north of Robson Street,
        to minimize blockage of the mountains from locations south of False
        Creek;
       building heights should step down as they approach the water;
       there are enough sites for taller buildings to ensure that one or
        two owners will not have a monopoly on the opportunity to develop a
        tall building exceeding current height limits. 

   The recommended skyline involves allowing buildings in the current
   450-foot high zone to go up to 600 feet. Buildings exceeding the current
   height limits would all be in the Central Business District, generally
   north of Robson Street (see map on the following page, more details in
   Appendix 'C'). A review of existing development sites and view corridor
   limitations indicates that there are probably 5 practical opportunities
   for buildings to exceed 450 feet. In two locations, there is the
   opportunity to go up to 600 feet. In other locations, heights would 
   range from 475 feet to 550 feet due to view cone restrictions. The
   increases of height above 450 feet would have to meet criteria discussed
   below and be the subject of a special review process. 

   In one small area, west of Thurlow and east of Bute where the current
   height limit is 300 feet (see map on the following page), buildings
   could go up to 400 feet. The boundaries of this area may be slightly
   adjusted after further study.



                                      map


   In no case, is it proposed that there will be buildings significantly
   exceeding current height limits in locations south of Robson Street nor
   along the Coal Harbour shoreline. One of the intents of this policy is
   to clarify that significant increases above the current height limits
   will generally not be approved for locations outside the core.

   This option is recommended because:

       it addresses the desire, as expressed by some people, for more
        visual interest and shaping of the skyline;
       the 600-foot high landmark buildings will generally keep buildings
        below the ridge of the mountains and not block 'the Lions' from
        most vantage points south of 12th Avenue;
       it provides clear direction on the locations where the current
        height limits may be relaxed significantly and designates the
        Central Business District as the only location where this may
        occur;
       it clearly identifies the Central Business District as the centre
        of the downtown;
       it has minimal impacts on sensitive areas (eg. residential
        neighbourhoods) of the city;
       it would have minimum impact regarding view blockage or the sense
        of encroaching tall buildings from vantage points south of False
        Creek.

   One caution about this proposal is that the area between Bute and
   Thurlow Street (where the relaxation of the 300-foot height limit is
   proposed) is adjacent to Triangle West, a mixed use area that includes a
   significant amount of housing. Detailed analysis of shadowing, view and
   wind impacts would need to be undertaken to ensure that this area is not
   negatively impacted.  On the other hand, Triangle West may have one or
   more other sites for low-impact taller buildings.  Follow-up work is
   necessary to finally settle on boundaries for height increases in the
   northwest corner of the core.

   The preferred skyline will evolve over many years. Once one or two 
   taller buildings are built, the skyline will have the quality of the
   landmark prototypes we tested; after more buildings are constructed it
   will take on a more 'dome like' quality, although not a perfectly shaped
   dome. In any event, it will provide enough development opportunities
   while minimizing negative view impacts south of False Creek or
   environmental impacts on sensitive areas such as residential
   neighbourhoods.

   General Policy for Higher Buildings

   Within the boundaries outlined above, a special process and policies are
   proposed when considering building proposals which exceed the current
   height limits established by the Downtown District ODP. While this must
   be fully fleshed out during implementation, the following aspects are
   essential:

       the highest buildings (i.e. 575-600 feet) should be on one of
        downtown Vancouver s three primary  streets - West Georgia,
        Granville and Burrard;
       the building should exhibit the highest order of architectural
        excellence;
       the building should achieve other community benefits such as being
        a recipient site for density transfers or density bonusing relating
        to heritage retention or the provision of significant cultural or
        social facilities or low cost housing;
       it should not involve the demolition of a Class  A  heritage
        building;
       where possible, the building should include activities and uses of
        community significance such as a public observation deck or other
        public amenity;
       the development should provide on-site open space that represents a
        significant addition to downtown green and plaza  spaces;
       the building should not contribute to adverse microclimate effects;
       signage on buildings should not be located at a height which
        exceeds the current height limits (i.e., 300 or 450 feet); 
       the building should be the subject of a special review process
        which includes, in addition to the current review requirements
        (which includes review by staff and the Urban Design Panel and
        approval by the Development Permit Board), a review assessing
        architectural excellence with input from a special panel of
        respected community leaders and notable design experts, and
        approval by Council.

   Public Comment

   Staff organized a series of open houses and a public meeting in October
   to assist in identifying key vantage points for examining the skyline
   and directions for preparing skyline prototypes. Public Comments from
   this are summarized in Appendix 'E'. In January and February a second
   series of public open houses in a variety of locations and a public
   meeting offered the opportunity to review the prototypical skylines and
   identify a preferred skyline.  Public Comments from this are summarized
   in Appendix 'F'.

   The following were the key themes expressed by the public during the
   October and the January and February events:

   1.   The skyline should complement, not compete with the natural
        setting. The north shore mountains should clearly be predominant,
        especially 'the Lions'.

   2.   The skyline should work with the topography and water features.

   3.   The skyline is an important symbol of the city.

   4.   Landmark buildings should achieve a variety of community
        objectives.

   5.   Landmark buildings should achieve a high degree of architectural
        excellence.

   Staff estimate that several thousand citizens have become aware of this
   study with approximately 1000 individuals having reviewed the
   presentation boards between January 25th and February 5th. There were
   221 comment sheets submitted by participants. The open houses were held
   in Pacific Centre Mall, Library Square and community centres in False
   Creek, Kitsilano, Mount Pleasant and Britannia. This  survey is not
   statistically representative of all the public. It reflects the views of
   those individuals who visited the public open houses or attended the
   meeting and took the time to fill out the comment sheet.

   The results are as follows:

   Is the shape of the Vancouver Skyline important?

                                            %
   very important           139            63
   important                 57                                           26
   no response               10                                            5
   little importance          4                                            4
   not important              6                                            3
   don't know                  1                                            0

   Total responses          221

   Of the five prototypical skylines illustrated, which do you feel is most
   appropriate for Vancouver?
                                            %
   landmark 750'              71           32
   dome                        39          18
   'build-out'                30          14
   gap tooth                   27          12
   no response                 17           8
   landmark 600'               14           6
   gap tooth/landmark 750'      9           4
   landmark 600'/dome           5           3
   landmark 750'/dome           4           2
   gap tooth/dome               2           1
   'build out'/landmark 600'    1          .5
   'build out'/dome             1          .5

   Total responses            219

   The results to the question on the preferred skyline varied by the
   location of the open house or meeting. Generally, the landmark 750'
   skyline was more favoured by those attending the events in the downtown
   at Pacific Centre Mall and Library Square. About 75% of those submitting
   comment sheets attended these events. At open houses in Kitsilano, False
   Creek,  Mount Pleasant and Britannia, there were a smaller number of
   respondents. Generally, the 'build-out' and dome skylines were preferred
   more than the other options at these events.

   Advice from the Skyline Study Advisory Committee

   A majority of the members of the Council-appointed Advisory Committee
   expressed support for the recommended skyline, as illustrated in this
   report. 

   The preference for the retention of the existing height limits (i.e.,
   the 'build-out' skyline) was also brought forward. The importance of
   retaining mountain views was emphasized by those suggesting the
   retention of existing height limits. They noted that further analysis,
   including the provision of more viewpoints for examining a skyline
   should be required prior to final approval of it.

   The committee was unanimous regarding the need to look carefully at the
   implications and impacts of increased building heights and the necessity
   of developing guidelines for tall buildings prior to permitting
   buildings that exceed the current 450 foot limit. The committee also
   noted the importance of carefully defining the areas within which taller
   buildings would be considered, so that the boundaries of those areas
   make sense to the public, City staff and the development community. 

   The Advisory Committee is willing to reconvene to work with the staff on
   follow-up work.

   Next Steps - Urban Design Analysis, Zoning and Guideline Amendments

   Once Council has approved a general building heights policy based upon a
   preferred form for the skyline, follow-up work will be required to:

       review the impacts of the highest buildings (i.e., exceeding 450
        feet) on views, shadowing and wind and prepare guidelines for
        mitigating these impacts;
       prepare guidelines for building massing, roof treatments and
        signage on the highest buildings;
       finalize the exact boundaries within the Central Business District
        where buildings exceeding existing height limits will be
        considered;
       identifying specific criteria and a process for reviewing proposals
        for the highest buildings that involves Council, the public, the
        Development Permit Board and staff;
       draft text amendments for the Downtown Official Development Plan
        and ancillary regulations to permit buildings above the current
        height limit of 450 feet in a limited area of the downtown;
       consultation with the Advisory Committee on this work.

   It is recommended that this work be deferred to 1998 when existing staff
   resources become available to do this work. It is unlikely that there
   will be a rush to take advantage of new height opportunities. To date,
   owners of only one site (Bentall V) have expressed interest in a taller
   building. Staff are currently committed to other Council priorities for
   the remainder of this year.

   Funding of $6,000 will be required for public meeting expenses and
   software and hardware up-grades of two of the city's computers to
   facilitate use of the computer model of  downtown buildings for height
   impact analysis. Staff are recommending that Council approve this
   funding for the 1998 budget subject to the availability of funds and
   priorities. The computer model of the downtown peninsula is being sold
   to the public and staff expect that it will generate revenues that
   defray the costs of computer software and hardware expenses in the long
   run.

   Alternatively, so that this work can proceed immediately, Council could
   approve funding for a consultant at a cost of $12,000 plus  $6,000 for
   public process and computer related costs.   CONCLUSION

   The skyline is an expression of the community, its image and the way it
   works.  Based on the Skyline Study, staff are recommending that a
   limited number of buildings be permitted that exceed the current height
   limit of 450 feet. Prior to considering buildings of this height,
   further work is needed to define boundaries where tall buildings will be
   considered, draft guidelines, text amendments, review criteria and a
   process to enable the consideration of buildings at this scale.

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