real property work classificationwork … property work classificationwork classification ... –...

Real Property Work Classification

Real PropertyWork ClassificationWork Classification

Office of the Assistant Chief of Staff for Installation Management

Michael Dean Bill Allen(703) 601 0703 (703) 601 0705(703) 601-0703 (703) [email protected] [email protected]

Installation Management Command

Anthony White(703) [email protected]

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PURPOSE:Provide an Overview ofProvide an Overview of

W k Cl ifi ti R l P tWork Classification on Real Property

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Art or Science?

• Work classification is 2 parts science and 1 part art

• the rules based on – Laws

Regulations Science}– Regulations• the fog

– experience

}Art}p

– interpretation Art}

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• All work classification and approval rules apply

Modular & Pre-EngineeredAll work classification and approval rules apply (RPF).

• Construction, may not be permanent.• Comply w/ARPLANS. • Comply w/RPMP & IDG.

R l t bl b ildi• Relocatable buildings arenot classified (WHY?) A RLB i E i t t R l P t !• A RLB is Equipment not Real Property!

• Site prep is construction.

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What Is Work Classification?

• Work included in a Real Property Undertaking is Classified to determine whether the work is:– Construction– Repair

• Maintenance– Equipment (Real Property or Not)

• Installed-Building-Equipment (Real Property) – Priced as Part of the Project IBE examples:– HVACHVAC – Utility Monitoring and Control Systems– Auxiliary Generators – support building not readily removable

• Equipment-In-Place (Not Real Property) – Not Priced as Part of the Project EIP examples:– Auxiliary Generators – support personal property may be readily removable– Electronic Security Equipment

LAN systems & Telephone systems includes cables (except in Barracks for phone and Cable TV)– LAN systems & Telephone systems, includes cables (except in Barracks for phone and Cable TV) – UPS

• AR 420-1 Army Facilities Management• AR 415-15, Chapter 6 & 7 or DA Pam 420-11, Chapter 2

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What Is Its Basis?

Public LawPublic Law

What Is Its Basis?

Public LawPublic Law

10 US Code, Chapter 169– Sec 2661 – Repair– Sec 2801 – Definitions

S 2805 C t ti

RealProperty– Sec 2805 – Construction

– Sec 2811 – RepairProperty

10 US Code, Chapter 159

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– Sec 2688 – Utility System


What Is Its Basis?DoD PolicyDoD Policy

What Is Its Basis?yy

– DoDD 1015.2, Military Morale, Welfare, and Recreation (MWR) 14 Jun95(MWR) 14 Jun95

– DoDI 1015.12, Lodging Program Resource Management, 03 Oct 96 g ,

– DoDI 4165.14, Real Property Inventory and Forecasting, 31 Mar 06

– DoDI 4165.56, Relocatable Buildings, 13 Apr 88– Memorandum - Definition of Repair, 2 Jul 97

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Army PolicyArmy Policy

• AR 420-1 Army Facilities Management (effective 12/02/07)

• AR 420-10* Management Of Installation Directorates Of Public Works

Memorand m HQDA DAIM ZA 2 J l 97 s bject Ne Definition of Repair• Memorandum, HQDA, DAIM-ZA, 2 Jul 97, subject: New Definition of Repair

• AR 420-18* Facilities Engineering Materials, Equipment, And Relocatable Building Management

• Memorandum, HQDA, DAIM-ZA, 19 Feb 08, subject: Interim Policy Change on Relocatable Buildings for Paragraphs 6-13 through 6-17 in AR 420-1, Army Facilities Management

• Memorandum HQDA DAIM ZA 19 Feb 08 subject: Interim Policy Change for AR• Memorandum, HQDA, DAIM-ZA, 19 Feb 08, subject: Interim Policy Change for AR 420-1, Army Facilities Management, on Maintenance and Repair and Construction Approval Authority

• AR 420-49 Utility Services

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Army PolicyArmy Policy

• AR 420-70* BUILDINGS AND STRUCTURES

• AR 420-72* TRANSPORTATION INFRASTRUCTURE AND DAMS

• AR 415-15 * ARMY MILITARY CONSTRUCTION AND NONAPPROPRIATED-FUNDED CONSTRUCTION PROGRAM DEVELOPMENT AND EXECUTIONDEVELOPMENT AND EXECUTION

• AR 210-50* HOUSING MANAGEMENT

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Army PrecedentArmy Precedent

• DA PAM 420-11 Project Definition and Work ClassificationClassification

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What Work is Classified?What Work is Classified?

• The Garrison Commander is the owner of all Real Property on an Installation.

• The DPW Classifies any work or services related to the Installation owned leased orrelated to the Installation owned, leased, or controlled real property.

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What Work is Classified?What Work is Classified?

•• The Source of Funds does not affect Work The Source of Funds does not affect Work Classification! Classification! –– OMAR, OMA, OMD, NAF OMAR, OMA, OMD, NAF

• Neither does the method of work accomplishment! -- Contract, in-house work force troops donatedhouse work force, troops, donated Manpower

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Who Is Responsible?Who Is Responsible?

The Director f P bli W kof Public Works

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Who Can Assist the DPW?Who Can Assist the DPW?

• Garrison Legal Office

IMCOM R i Offi• IMCOM Region Office

• IMCOM

• ACSIM

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What Is the Role ofWhat Is the Role ofWhat Is the Role of What Is the Role of HQ, IMCOM? HQ, IMCOM?

• Publish technical guidance Delegate approval authority• Delegate approval authority

• Review work classification• Validate & fund projects• Request project approval• Request project approval• Implement mgmt controls

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What is the RoleWhat is the RoleWhat is the Role What is the Role of the IMCOM Region? of the IMCOM Region?

• Review project documentation and work classificationand work classification

• Perform technical review• Request project approval• Monitor project execution p j• Technical assistance

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What is the Role of theWhat is the Role of theWhat is the Role of the What is the Role of the Garrisons? Garrisons?

• Implement technical guidance• Classify work, justify, and legalClassify work, justify, and legal

review• Prepare project documentation• Ensure projects are properly

approveWithi th it– Within authority

– Request project approval• Maintain project record

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Maintain project record


I t t TI t t TImportant TermsImportant Terms

• Component – subset of system• System – subset of facility• Facility – all components and systems necessary to

perform designated functionperform designated function• RPF – real property facility• Interdependent• Interrelated• Funded Project Cost• Unfunded Project Cost• Phased Repair Project• Installed-Building-Equipment (IBE)• Equipment-in-Place (EIP)• Repair to Replacement Ratio• Undertaking

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• Undertaking


Important TermsImportant Terms• Component• Component

– Windows, Doors, Floors, Ceilings, valves, pumps, fans, etc. . .

• SystemSystem – HVAC, Fenestration, Plumbing, Electrical, Roofing , etc. .

. • Facility y

– The term “facility” means a building, structure, or other improvement to real property

• Real property facility – A separate and individual building, structure, utility system,

or other real property improvement identifiable in the CATCODES listed in AR 415-28 .

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Important TermsImportant Terms

InterdependentInterdependentTh f iliti hi h t ll d d tThose facilities which are mutually dependentin supporting the function(s) for which they were constructed and therefore must be costedwere constructed and therefore must be costed as a single project, for example, a new airfield on which the runways, taxiways, ramp space

d li hti t ll d d t tand lighting are mutually dependent to accomplish the intent of the construction project

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I t l t dI t l t d


InterrelatedInterrelatedThose facilities which have a common support pppurpose but are not mutually dependent and are therefore funded as separate projects, for example, billets are constructed to house soldiers with thebillets are constructed to house soldiers with the subsequent construction of recreation facilities. Their common purpose to support health, welfare, p p pp , ,and morale creates an interrelationship. However, neither facility is necessary for the operation of the

th

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other.


F d d C t AR 420F d d C t AR 420 1010


Funded Costs AR 420Funded Costs AR 420--1010

• Transportation & materials• Civilian labor• Supervision and Inspection• Troop travel & per diem • Installed Building Equipment & Manuals• Mitigation & demolition• Site preparation

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U f d d C tU f d d C t


Unfunded Costs Unfunded Costs AR 420AR 420--1010

• Military labor & licensesMilitary labor & licenses• Equipment depreciation• Excess equipment or relocated RP itemsq p• Surveys & engineering design• DPW overhead costs• Furnishings & Equipment-In-Place

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Phased Repair Project Phased Repair Project AR 420AR 420--1010

• In determining the total cost of a repair project, all phases of a multi-

i j t t i l f ilitUS Title 10

year repair project to a single facility are approved as a single project. Projects over $500 000 must include

Section 2811

• Projects over $500,000 must include all phases.

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What Are Phased RepairWhat Are Phased RepairWhat Are Phased Repair What Are Phased Repair Projects?Projects?

• Sequenced work executed over multiple fiscal years on a RPFy

• All phases must be approved as a single project g p j

• DD 1391 / DA 4283 project approval• Phases are based on work process andPhases are based on work process and

on funds availability• Approval is for life of project

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Approval is for life of project



Total funded cost of all known repair and construction

What is Repair to Replacement Ratio? What is Repair to Replacement Ratio?

Total funded cost of all known repair and construction Divided by

replacement cost of facility, i l di d liti & di l & t ti f itincluding demolition & disposal & restoration of site

See DA Pam 420-11 Paragraph 3-4UNIFIED FACILITIES CRITERIA (UFC) UFC 3-700-05 DESIGN GUIDE: CONSTRUCTION COST ESTIMATING

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WWII WoodWWII Wood

• If total funded project cost > $40/ft2, Garrison Commander approval isGarrison Commander approval is required in addition to project approval

• Goal is elimination of WWII wood

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AntiAnti Terrorism / Force ProtectionTerrorism / Force ProtectionAntiAnti--Terrorism / Force ProtectionTerrorism / Force ProtectionMust be considered on all undertakings:

Required When a Project:• Implement the standard building renovations, repairs, and restorations where those costs exceed 50% of the replacement cost of the building. [The 50%where those costs exceed 50% of the replacement cost of the building. [The 50% cost is exclusive of the costs identified to meet these standards.]

• Any portion of a building is modified from its current use to that of an inhabited building, billeting, or a primary gathering building for one year or more. [Examples would include a warehouse (uninhabited) being converted to administrative (inhabited) use and an inhabited administrative building being converted to a primary gathering building or billeting. ]

• Glazing Replacement or Door Replacement – will meet the standard!

• Additions to existing inhabited buildings shall comply with the minimum standards for new buildings. If the addition is 50% or more of the gross area of the existing building, the existing building shall comply with the minimum standards for existing buildings.

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g g


SeismicSeismic

A Seismic Evaluation and Mitigation Are Required When a Project:

1. Significantly extends the facility's useful lifeor

2. Significantly increases the facility's value or

3. Cost exceeds 50 percent of the current l l

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replacement value


AccessibilityAccessibility

• When needed to provide access to new employees.

or• When repairing an area that requires accessaccess.

or• When needed in Family Housing.

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Life Safety Code Compliance Life Safety Code Compliance

• Every undertaking must evaluate NFPA 101 Compliance. UFC 3-600-01

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Historic PropertiesHistoric Properties

Consult the Installation Cultural Resource Manager to determine if the project involves a “historic property” and if so, insure compliance with Federal, State, and Local Requirements.Repair to Replacement Ratio is based on replacement value of constructing the Historic Structure just like it was originally built. This includes cost of special materials and handicraft work.

Note the presence of a Historic pproperty and compliance w/ HostNation Standards on the DD 1391

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What About Facilities Damaged by FireWhat About Facilities Damaged by Fire, Storm, Flood, Freeze, or

Other Natural Occurrences?Other Natural Occurrences?

• Project approval requests that require• Project approval requests that require HQDA approval will be submitted within 30 daysdays

• Approvals and congressional notifications ill b bt i d hil tiwill be obtained while prospective

contractors are preparing their proposals

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Maintenance & Repair Maintenance & Repair Approval AuthorityApproval Authoritypp ypp y

< $750K IMCOM, ACOM, ASCC, DRU

$750K HQDARep/Rpl > 50% ≥ $750K HQDARep/Rpl > 50%

Rep/Rpl < 50% < $5M IMCOM

$7 5M Congressional notification &

Rep/Rpl < 50% ≥ $5M HQDA

$7.5M Congressional notification & 14-day waiting period

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M i & R iM i & R iMaintenance & Repair Maintenance & Repair Approval AuthorityApproval Authority

• Project approvals are “Per Project”• Project approvals are Per Project • The IMCOM limit for a Maintenance &

Repair project is $750KRepair project is $750K. – If the R/R is less than 50 % a project may

be approved up to $5M. pp p $– Maintenance is not a separate project;

project is a Maintenance & Repair project.

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What vs. WhyWhat vs. Why

It is not only what you do but also why you do it that determines work classification.– Repair - Failed or failing – Construction - Inadequate size, category codeConstruction Inadequate size, category code

change, standard change, or mission change– Repair - Work can be easily differentiated from p y

Construction– Construction - Work is interdependent

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p


Examples of MaintenanceExamples of Maintenance

• Exterior weatherproofing• Preventive maintenance• Preventive maintenance• Recurring maintenance• Dredging• Grounds Maintenance• Boiler water treatment

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What About Grounds?What About Grounds?

• Grounds Management may be classified as either maintenance, repair, or construction. However, pMaintenance and Repair are funded out of either Municipal Services (BOS) or SRM (dams, bunkers, RR t k i ht f )RR track right-of-way).

C t ti i f d d t f SRM ( ithi• Construction is funded out of SRM (within limits).

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What Is Repair?What Is Repair?What Is Repair?What Is Repair?

Definition of Repair

“To restore a real property facility system or

Definition of Repair

To restore a real property facility, system or component to such a condition that it may effectively be used for its designatedeffectively be used for its designated functional purpose.“ Quote from Title 10 USC, Section 2811

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Wh t I R i ?Wh t I R i ?What Is Repair?What Is Repair?Definition of Repair

1. When repairing a facility, the components of the facility may be repaired by replacement, and the

l t ill b t t t d d

p

replacement will be up to current standards or codes.

2. For example, a) Heating, Ventilation, and Air Conditioning (HVAC) equipment

can be repaired by replacement, can be state-of-the-art, and provide for more capacity than the original unit due to increased demand/standards.

b) Interior rearrangements (except for load-bearing walls) and restoration of an existing facility to allow for effective use of existing space or to meet current building code requirements (for example, accessibility, health, safety, or environmental)

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( o e a p e, access b ty, ea t , sa ety, o e o e ta )may be included as repair.


What Is Repair?What Is Repair?What Is Repair?What Is Repair?Definition of Repair

3. A facility must exist and be in a failed or failing condition in order to be considered for a repair project

p

for a repair project.

To qualify for repair the you must be able q y p yto say the facility is failed or failing. This assessment is based on the condition of existing components and systems! (It isexisting components and systems! (It is not based on the functional layout of the facility.)

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What Is Repair?What Is Repair?What Is Repair?What Is Repair?Definition of Repair

4. When repairing a facility you will now bring the facility (or a component of a facility) up to

p

y ( y)applicable codes or standards as repair. a. An example would be adding a sprinkler system as part

of a barracks repair project. b Other examples would be adding air conditioning tob. Other examples would be adding air conditioning to

meet a current standard when repairing a facility c. Another example is installing an elevator or chair-lift

when repairing an administrative facility or an MWR f ilitfacility.

d. Pursuant to the definition of Repair, moving load-bearding walls, additions, new facilities and functional conversions must be done as construction.

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What Is Repair?What Is Repair?

The restoration of a failed or failing RPFThe restoration of a failed or failing RPF, system, or component to meet current codes and standards for its designatedcodes and standards for its designated functional purpose.

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R i i b d i ti f il d f iliRepair, is based on existing, failed or failingRPF, systems, components or an existing

d t h i ll b l t tilit tand technically obsolete utility system.

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Enough components and systems of an RPF are failing that the

Examples of RepairExamples of RepairEnough components and systems of an RPF are failing that the entire facility is determined to be failing. 1. You must bring the facility up to standards and it must include all items required by codes.items required by codes. 2. Accessibility must be addressed. (some types of facilities are exempt from Accessibility by UFAS.)3 Fire seismic AT/FP Etc3. Fire, seismic, AT/FP. . . Etc….

All of the above are done as repair while you are repairing the floors ceiling walls windows etcfloors, ceiling, walls, windows, etc…

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Bringing a RPF, system, or component up to applicable codes or standards forCOMPLIANCE PURPOSES ONLY, is

CONSTRUCTION.CONSTRUCTION.

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ConstructionConstruction Approval Authority≤ $750K IMCOM, ACOM, ASCC, DRU

> $750K MILCONNon-HLS > $750K MILCON

HLS≤ $1.5M *

$1 5MHLS > $1.5M MILCON

C bi d≤ $1.5M Total *

Combined $1.5M Total

BUT no more than

$750K Non-HLS included in project.•Not delegated lower than

IMCOM ACOM ASCC

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IMCOM, ACOM, ASCC,DRU


By Way of Explanation

• AR 415-15 governs military construction (MILCON)(MILCON)

• All construction is military constructionSRM b d f i• SRM may be used for some minor military construction

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What Is Construction?

• To erect, install, or assemble a new facility• To add, expand, alter, convert, or replace anTo add, expand, alter, convert, or replace an

existing facility

• New rules for construction on “relocatable buildings” in LTG Wilson’s 19 FEB 08 gDelegation of Authority Memo.

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Real Property FacilityReal Property FacilityReal Property Facility (RPF) is a separate and individual building, structure,

utility system, or other real property improvement identifiable in the three-digit Category Codes listed in AR 415-28 . Examples are as follows:

(1) Buildings. May be a single-purpose facility or a multipurpose facility containing one or more functional areas. In a(1) Buildings. May be a single purpose facility or a multipurpose facility containing one or more functional areas. In a multipurpose facility the functional areas may be associated with a single all encompassing activity such as one stop unit training or the functional areas may have no association beyond existing in the same facility. While, each functional area is accounted for using the Category Codes contained in AR 415-28. A repair project may be carried out on all or part of an single-purpose facility or on one or more functional areas of a multipurpose facility.

a) The repair of an entire building will restore the real property facility to such a condition that it may effectively be used for its designated functional purpose.

b) A barracks facility CATCODE 721XX may contain an organizational class room CATCODE 171XX and a dining facility CATCODE 722XX. If the barracks is damaged by fire, it may be repaired if the foundation and walls still exist, and a total replacement is not required The facility will be restored to such a condition it may be used for itsand a total replacement is not required. The facility will be restored to such a condition it may be used for its designated functional purpose. The individual areas may be re-sized during the repair to meet current or projected usage and components may be added, as an example a sprinkler system that did not exist maybe included as repair, so the building may be effectively used for its designated functional purpose. The building will be brought up to codes and standards as repair.

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Real Property FacilityReal Property Facility (RPF) is a separate and individual

building, structure, utility system, or other real property improvement identifiable in the three-digit Category Codes listed in AR 415-28. Examples are as follows:

(2) Utilities. A individual system for the treatment or supply of water and the equipment, fixtures, structures, and other improvements utilized in connection with the treatment or supply of water including the real property, easements, and rights-of-way associated the system.

A single (physically or geographically identifiable) water supply, treatment, s g e (p ys ca y o geog ap ca y de ab e) a e supp y, ea e ,and storage facility (Category Code 84X) represents a single RPF. Items such as failing wells or water storage tanks or a section of pipe may be completely replaced as repair since they are considered component parts of a RPF.

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a RPF.


Real Property FacilityReal Property Facility (RPF) is a separate and individualReal Property Facility (RPF) is a separate and individual

building, structure, utility system, or other real property improvement identifiable in the three-digit Category Codes listed in AR 415-28. Examples are as follows:

(3) Surfaced Areas. All the real property improvements listed under ( ) p p y pthe three digit category codes 851 (roads) or 852 (sidewalks and other pavement) are a single RPF. All contiguous airfield pavements, i.e., runways, taxiways, aprons, category code 110,

t i l RPF F ili b id i fi ldrepresents a single RPF. Failing bridges or airfield runways may be completely replaced as repair since they are considered component parts of a RPF. The same is true for railroads where 860 (tracks spurs etc ) or 861 (improvements associated with

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860 (tracks spurs etc.) or 861 (improvements associated with operation of RR) are considered a single facility.


Construction Must …

• Provide:– Complete and useable facility– Complete and useable facility – Complete and useable facilities

OrOr– Complete and usable addition to an

existing facilityexisting facility– All work that is interdependent must be

included

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included


Construction Includes:

• Conversion • Complete facility replacement• Repair which is inseparable from

construction• Demolition associated with constructionDemolition associated with construction• Facilities or work is interdependent

(engineering and mission)• Check AR 415-15 for which equipment

is considered to be a funded part of the project.

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p j


F iFencing

D-Drainage SystemE-Electrical System

Gate

BuildingUnit or use A

BuildingUnit or use B

B BEA B E E

D D1 site

B BE

D1 site

A B

1 site1 siteE

DD

1 site

A B

DE

B

D

EB

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1 site

Work Classification for Relocatable Buildings (RLB) sites1 site

D


D-Drainage SystemE-Electrical System

Gate

BuildingUnit or use A

Fencing

BuildingUnit or use BU t o use

EA A A A

U t o use

E

D1 site

A A E E

D D1 site

A A

1 site 1 site

E

D ED

1 site

A A EE

DD

2 sites

A B

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Work Classification for Relocatable Buildings (RLB) sites1 site 2 sites


Conversion

• Two steps for a Conversion– Step 1. Obtaining the authority and changing the real

property recordsproperty records– Step 2. Real Property Construction Project to make the

changes needed for the facility to be effectively [complete and useable] used for the new use.]

• Repair that is needed before the conversion is needed after the conversion and can still beneeded after the conversion and can still be executed as repair to the extent it would have been required for the former use.

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What Is Health-Life-Safety?Guidance from Congress“intended solely for urgent projects whose sudden emergence could not have beenemergence could not have been anticipated and which pose so immediate a threat to the life, h lth f t f l th thealth, or safety of personnel that their correction cannot wait until the next appropriation cycle.”

Justification for correcting a deficiency that is lif h lth f t th t i i l d

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life, health, or safety threatening includes:


Justification of HLSJustification of HLSJustification (in project folder)

1 Wh i t d t i d?1. When was requirement determined?

2. Why deferral poses an unacceptable and imminent risk to personnel?

3. Describe on-going actions and temporary work-arounds to mitigate risk and safeguard lives.

4. Explain why the deficiency cannot be repaired or4. Explain why the deficiency cannot be repaired or corrected by other means?

5. Assure that the construction is intended primarily to correct a deficiency that threatens the life, health, or y , ,safety of personnel.

Approval authority is SES or GO level

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What Is Non-Construction?

• Costs associated with installing personal property (Equipment-In-Place) p p p y ( q p )into existing real property facilities is “Non-Construction"

• The cost of transporting, installing, and connecting this equipment is funded

i h h i i h b hwith the same appropriation that bought the equipment

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What Is Non Construction?What Is Non-Construction?

• Equipment which supports Information Management is not Real Property it is Equipment-In-Place (EIP). (LAN Cables and Phone Cables)

• In repair projects as a general rule installation and the cost of EIP is funded by the proponent not the DPW. “Non-y p pConstruction"

• The cost of transporting, installing, and connecting this i t i f d d ith th i ti th tequipment is funded with the same appropriation that

bought the equipment• Guidance from AR 415-15 and DA Pam 420-11

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Guidance from AR 415 15 and DA Pam 420 11


Examples of Construction?Examples of Construction?

An emergency generator is failing and needs to be repaired.1. The generator may be increased in size to meet current and projected loads as

repair.2 S it h d l t i l l d d i i b l d i i th t ill b2. Switches and electrical leads and wiring may be replaced in a size that will be

compatible with the resized loads. In addition new wiring may be run to locations not previously serviced to accommodate equipment and areas not previously serviced but which have been determined to be essential during an emergencyemergency.

3. If the generator is be moved outside of the current footprint of the building. a. The new building housing the generator is construction.b. The generator, wiring and other items needed for the generator to work located in

the new building (facility) are repair.the new building (facility) are repair. c. The electrical lines and new switches needed are repair to support the generator

are repair. d. If the generator required a sprinkler in its old location then the sprinklers in the new

building maybe installed as repair.

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OMA Project Re-Approval

• Projects approved below DA may be re-approved as necessary andbe re approved as necessary and they should be kept current.

• Once the project costs exceed local approval authority projectslocal approval authority projects must be submitted to higher HQ for approval.

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for approval.


Questions?Questions?

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C t t I f tiContact InformationAssistant Chief of Staff for Installation ManagementAssistant Chief of Staff for Installation Management

Installation Management CommandATTN: DAIM-FDF-FE ATTN: IMAH-PWD-M600 Army Pentagon 2511 Jefferson Davis Highwayy g g yWashington, DC 20310-0600 Arlington, VA 22202-3926

Michael Dean Anthony White(703) 601-0703 (703) [email protected] [email protected]

Bill Allen Barry Bartley(703) 601-0705 (703) 602-3389bill allen@us army mil barry bartley@us army mil

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[email protected] [email protected]

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