Millwork Commons

Downtown, Midtown, and all parts east of 72nd.
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U R my Helix
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Re: Millwork Commons

Post by U R my Helix »

The former residential development layout had 17 luxury condo units where the long portion of the Dizzy Mule building is now proposed. I do not see that the condo element has been moved elsewhere. I take it that the condos are no longer planned.


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PotatoeEatsFish
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Re: Millwork Commons

Post by PotatoeEatsFish »

U R my Helix wrote: Fri May 06, 2022 7:24 pm The former residential development layout had 17 luxury condo units where the long portion of the Dizzy Mule building is now proposed. I do not see that the condo element has been moved elsewhere. I take it that the condos are no longer planned.


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I’m kind of glad they are less condo focused. If it’s a neighborhood focused on young professionals, condos should be a second thought after apartments.
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Re: Millwork Commons

Post by nebraska »

PotatoeEatsFish wrote: Fri May 06, 2022 8:10 pm I’m kind of glad they are less condo focused. If it’s a neighborhood focused on young professionals, condos should be a second thought after apartments.
On the other hand... I would love to have a 1000 sqft condo with balcony. I would live in Millwork or anywhere downtown with a full size grocery within walking distance.
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Re: Millwork Commons

Post by nebraska »

Check the parking garage snuck into the background. The city documents show only 30 spots. I consider this progress towards buildings that aren't all parking. We can design outside of the [5-over-1] box!

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Athomsfere
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Re: Millwork Commons

Post by Athomsfere »

PotatoeEatsFish wrote: Fri May 06, 2022 8:10 pm
U R my Helix wrote: Fri May 06, 2022 7:24 pm The former residential development layout had 17 luxury condo units where the long portion of the Dizzy Mule building is now proposed. I do not see that the condo element has been moved elsewhere. I take it that the condos are no longer planned.


Image
I’m kind of glad they are less condo focused. If it’s a neighborhood focused on young professionals, condos should be a second thought after apartments.
I disagree hard here. Omaha is really lacking housing that can be bought right now. Condos are a great alternative to detached single family housing that forces car ownership on the home owner.

I'd really love to see Omaha plop some smaller condo / townhouses in more of the infill projects.
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Re: Millwork Commons

Post by halgy »

I'd love to have more condos downtown, especially if they are reasonably priced and sized for younger folk. While not necessarily necessary, the possibility of homeownership would make it a true neighborhood rather than a business district with a few housing units thrown in.

My issue with a lot of the townhouse-type buildings that are going up in Soma is that they are really expensive for what you get. I'm not sure if that is just the reality of new construction, or if the developers spend a lot of money on the fit and finish to make them "luxury" in order to appeal to higher-income people. I'd rather have an affordable, baseline condo that is big enough to grow into. You can always upgrade the kitchen, but you can't add more square footage.
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Re: Millwork Commons

Post by Garrett »

halgy wrote: Wed May 11, 2022 9:59 am I'd love to have more condos downtown, especially if they are reasonably priced and sized for younger folk. While not necessarily necessary, the possibility of homeownership would make it a true neighborhood rather than a business district with a few housing units thrown in.

My issue with a lot of the townhouse-type buildings that are going up in Soma is that they are really expensive for what you get. I'm not sure if that is just the reality of new construction, or if the developers spend a lot of money on the fit and finish to make them "luxury" in order to appeal to higher-income people. I'd rather have an affordable, baseline condo that is big enough to grow into. You can always upgrade the kitchen, but you can't add more square footage.
It’s hard to build an affordable entry level condo because there are a ton of tax incentives specifically for detached single family home ownership that do not at all exist for multi family developments.
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Re: Millwork Commons

Post by ita »

nebraska wrote: Sun May 08, 2022 8:53 am Check the parking garage snuck into the background. The city documents show only 30 spots. I consider this progress towards buildings that aren't all parking. We can design outside of the [5-over-1] box!
Nice, I didn't even see the parking garage in the background. I actually feel like Millowork Commons works well with the 5 over 1 boxes, because existing building have similar massing and silhouettes. Additionally, they are deployed here (at least as rendered) where they are not so big and uniform, with difference footprints and heights.
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Re: Millwork Commons

Post by ita »

Omaha’s Millwork Commons gets a new tenant: a ‘startup accelerator’
Paul Hammel
LINCOLN — A Capital City company that has helped Lincoln-based startups blossom into major businesses announced Thursday that it is expanding statewide and opening a new office in Omaha’s expanding Millwork Commons district.

Officials with NMotion, powered by gener8tor, said they are planning $3.7 million in new investments over the next two years to help start and grow 24 Nebraska startups.

According to the NMotion website, the startup accelerator has helped 72 early-stage companies since 2013— including QuantifiedAg, Nobl Health, RealmFive, Liveby, LeverageRX and Bumper— with investment, support and mentorship.

Startups and small businesses compete for placement in the accelerator programs. Successful bidders each receive $100,000 investments from NMotion through gener8tor’s venture fund and through a state program, Invest Nebraska, that helps startups.
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Re: Millwork Commons

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Omaha’s Millwork Commons gets a new tenant: a ‘startup accelerator’


A Capital City company that has helped Lincoln-based startups blossom into major businesses announced Thursday that it is expanding statewide and opening a new office in Omaha’s expanding Millwork Commons district. Officials with NMotion, powered by gener8tor, said they are planning $3.7 million in new investments over the next two years to help start and grow 24 Nebraska startups. According to the NMotion website, the startup accelerator has helped 72 early-stage companies since 2013— including QuantifiedAg, Nobl Health, RealmFive, Liveby, LeverageRX and Bumper— with investment, support and mentorship.

Startups and small businesses compete for placement in the accelerator programs. Successful bidders each receive $100,000 investments from NMotion through gener8tor’s venture fund and through a state program, Invest Nebraska, that helps startups. “By serving startups, NMotion will help generate even more great-paying jobs to help retain our graduates and recruit new talent to our state,” said Gov. Pete Ricketts at a Thursday morning press conference in Lincoln. He thanked the investors “whose generosity is allowing NMotion to accelerate the growth of young companies in Nebraska.” Lincoln Mayor Leirion Gaylor Baird also praised NMotion for helping entrepreneurs grow their dreams and for accelerating economic activity in the “hub of the Silicon Prairie.”

Millwork Commons, located near Omaha’s Charles Schwab Field (formerly TD Ameritrade Park), is a roughly 50-acre neighborhood sprouting on a forgotten industrial tract of north downtown. The new office for nMotion will be in the Mastercraft Building. The Millwork area has more than 60 companies and nonprofits and is designed to be a home for entrepreneurs, techies and innovators. Just recently, the $35-million Dizzy Mule project — named after an old mule barn located there — was announced to turn both new and historic structures into 172 apartments and spaces for artists and retailers.
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Re: Millwork Commons

Post by BIGO88 »

Looks like the Hello Apartments are now open as well as a new glasses store called spectical shop that has opened in the retail section below the apartments.
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Re: Millwork Commons

Post by iamjacobm »

Looks like some marketing for ground floor retail space is underway for a new building where the small scrap metal business was 1117 Nicholas. Another great addition in the area.

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Re: Millwork Commons

Post by ita »

iamjacobm wrote: Mon Aug 08, 2022 7:30 pm Looks like some marketing for ground floor retail space is underway for a new building where the small scrap metal business was 1117 Nicholas. Another great addition in the area.

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Listing says available January 2024. Seems optimistic. I haven't seen any groundwork started for this one, but I also haven't been by in a while.
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Re: Millwork Commons

Post by ita »

Dizzy Mule project is up for TIF approval at City Council today. I was reviewing the application again. This will be a neat project for the area. They are shooting for a early 2024 completion.
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Re: Millwork Commons

Post by ita »

New development including affordable housing in downtown Omaha area
John Chapman
Developers also say this project will include some affordable housing units. That is good news for District 2 Councilmember Juanita Johnson. Her constituents are in desperate need of affordable housing.

“I have seen their vision to reflect the inclusion of that particular area so I would be in total support of this,” said Johnson.

City council documents show the units will run from $825 a month for a studio unit up to $1,700 a month for three bedrooms. But developers say they will get help to make sure there are some affordable units available.

“Where maybe they wouldn’t normally be able to afford our apartments get them maxed at a certain amount based on their income we’ve got philanthropy coming in to cover the rest of it to get a more diverse group of people living in our buildings,” said Debra Christensen.

Developer Debra Christensen told the city council that about 5% of the units will help fill the affordable housing gap. City of Omaha Planning Director David Fanslau says getting more people to move into the north downtown area will draw more business and services to the area.
5% is about 8 or 9 units. That's better than nothing, but I would like to see projects along the streetcar route, or even in other TIF districts, have higher requirements, like 10% to help curbed rent trends. I would say, that compared to some other newer apartment projects, this project's monthly rents are on the lower end.
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Re: Millwork Commons

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ita wrote: Thu Sep 22, 2022 8:58 am New development including affordable housing in downtown Omaha area
John Chapman
Developers also say this project will include some affordable housing units. That is good news for District 2 Councilmember Juanita Johnson. Her constituents are in desperate need of affordable housing.

“I have seen their vision to reflect the inclusion of that particular area so I would be in total support of this,” said Johnson.

City council documents show the units will run from $825 a month for a studio unit up to $1,700 a month for three bedrooms. But developers say they will get help to make sure there are some affordable units available.

“Where maybe they wouldn’t normally be able to afford our apartments get them maxed at a certain amount based on their income we’ve got philanthropy coming in to cover the rest of it to get a more diverse group of people living in our buildings,” said Debra Christensen.

Developer Debra Christensen told the city council that about 5% of the units will help fill the affordable housing gap. City of Omaha Planning Director David Fanslau says getting more people to move into the north downtown area will draw more business and services to the area.
5% is about 8 or 9 units. That's better than nothing, but I would like to see projects along the streetcar route, or even in other TIF districts, have higher requirements, like 10% to help curbed rent trends. I would say, that compared to some other newer apartment projects, this project's monthly rents are on the lower end.
What is Omaha's poverty rate? Pretty close to the average 10% right?

I go back and forth a little on "affordable" housing. I'd hate to see a good development go unbuilt because the requirements made it untenable. Eliminating parking minimums might make it a wash, or even lower requirements in a TOD.

Optimistically, I think if you build X units, Y units will become more affordable due to demand. I do think it is critical though to eliminate pockets of poverty, so something like Blackstone needs to replace cheap housing with more housing that those displaced could afford to not leave the neighborhood.
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Re: Millwork Commons

Post by halgy »

Athomsfere wrote: Thu Sep 22, 2022 9:26 am Optimistically, I think if you build X units, Y units will become more affordable due to demand. I do think it is critical though to eliminate pockets of poverty, so something like Blackstone needs to replace cheap housing with more housing that those displaced could afford to not leave the neighborhood.
Most studies do support the idea that building more housing will lower rents overall, even if the housing is expensive. Any development is better than no development. However, that doesn't mean that we can't try to get something more equitable. I'm a proponent of requiring a certain percentage of new construction to be affordable housing, especially if they get TIF money, and double especially if it is downtown.

My primary reason is that I think it sucks that a lot of the service workers (waiters, cooks, baristas, etc.) who work downtown can't afford to live anywhere close. Currently, they have to chose between paying higher rents or paying for a car. They should have the same access to urbanist living as office drones like me.

My second reason is to provide better diversity, and to ensure that people in affordable housing aren't forgotten about. A lot of social housing falls into disrepair because they are segregated away from people with money and influence. And when things aren't maintained, it leads to further degradation (see: the broken window effect). If affordable units are mixed in with the normal units, the landlords will be better incentivized to actually keep up on their obligations.

Thank you for coming to my TED talk.
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Re: Millwork Commons

Post by Athomsfere »

halgy wrote: Thu Sep 22, 2022 11:06 am
Athomsfere wrote: Thu Sep 22, 2022 9:26 am Optimistically, I think if you build X units, Y units will become more affordable due to demand. I do think it is critical though to eliminate pockets of poverty, so something like Blackstone needs to replace cheap housing with more housing that those displaced could afford to not leave the neighborhood.
Most studies do support the idea that building more housing will lower rents overall, even if the housing is expensive. Any development is better than no development. However, that doesn't mean that we can't try to get something more equitable. I'm a proponent of requiring a certain percentage of new construction to be affordable housing, especially if they get TIF money, and double especially if it is downtown.

My primary reason is that I think it sucks that a lot of the service workers (waiters, cooks, baristas, etc.) who work downtown can't afford to live anywhere close. Currently, they have to chose between paying higher rents or paying for a car. They should have the same access to urbanist living as office drones like me.

My second reason is to provide better diversity, and to ensure that people in affordable housing aren't forgotten about. A lot of social housing falls into disrepair because they are segregated away from people with money and influence. And when things aren't maintained, it leads to further degradation (see: the broken window effect). If affordable units are mixed in with the normal units, the landlords will be better incentivized to actually keep up on their obligations.

Thank you for coming to my TED talk.
You basically said everything I often think about.

I think part of my personal issue is the percentage problem. If the original plan was 150 units at market rate, and let's say $1000 /month per unit, and then a requirement for 10% affordable, at say $700/ month. That's a loss of $54k/ per year. So I guess you could increase the rest of the rents to $1100 per month to cover it, and with the lower prices of Omaha that might not be a deal breaker. But somewhere, that math is going to hurt the developer in being able to attract tenants at price X. It's probably in the smaller developments too, like townhomes.

Morally, yes 100% affordable housing requirements makes sense. I just can't personally get the math to always work. Maybe it should be a sliding scale of percentages like taxes. Maybe there is some other thing that hasn't been invented yet that makes the most sense.
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Re: Millwork Commons

Post by ita »

Athomsfere wrote: Thu Sep 22, 2022 12:34 pm
halgy wrote: Thu Sep 22, 2022 11:06 am
Athomsfere wrote: Thu Sep 22, 2022 9:26 am Optimistically, I think if you build X units, Y units will become more affordable due to demand. I do think it is critical though to eliminate pockets of poverty, so something like Blackstone needs to replace cheap housing with more housing that those displaced could afford to not leave the neighborhood.
Most studies do support the idea that building more housing will lower rents overall, even if the housing is expensive. Any development is better than no development. However, that doesn't mean that we can't try to get something more equitable. I'm a proponent of requiring a certain percentage of new construction to be affordable housing, especially if they get TIF money, and double especially if it is downtown.

My primary reason is that I think it sucks that a lot of the service workers (waiters, cooks, baristas, etc.) who work downtown can't afford to live anywhere close. Currently, they have to chose between paying higher rents or paying for a car. They should have the same access to urbanist living as office drones like me.

My second reason is to provide better diversity, and to ensure that people in affordable housing aren't forgotten about. A lot of social housing falls into disrepair because they are segregated away from people with money and influence. And when things aren't maintained, it leads to further degradation (see: the broken window effect). If affordable units are mixed in with the normal units, the landlords will be better incentivized to actually keep up on their obligations.

Thank you for coming to my TED talk.
You basically said everything I often think about.

I think part of my personal issue is the percentage problem. If the original plan was 150 units at market rate, and let's say $1000 /month per unit, and then a requirement for 10% affordable, at say $700/ month. That's a loss of $54k/ per year. So I guess you could increase the rest of the rents to $1100 per month to cover it, and with the lower prices of Omaha that might not be a deal breaker. But somewhere, that math is going to hurt the developer in being able to attract tenants at price X. It's probably in the smaller developments too, like townhomes.

Morally, yes 100% affordable housing requirements makes sense. I just can't personally get the math to always work. Maybe it should be a sliding scale of percentages like taxes. Maybe there is some other thing that hasn't been invented yet that makes the most sense.
This is a good discussion. There are ways for developers to recoup lost funds by available affordable housing credits from the fed, state or city. But only a few specialize in working with these types of credits. Unfortunately, there are almost no options for building for sale affordable housing units. Until there is, we likely won't see for sale affordable housing available, at least how we usually define affordable housing based on poverty rate.

The other thing that might make affordable housing, and I haven't thought about it much, so critique away, is for cities or other public entities to sell property to developers for $1. A decent chunk of any budget comes in the form of acquisition, particularly in high value areas. Once the streetcar is online, all available land is and possible redevelopment sites are going to go up 10-30%, making it even more unlikely that developers can make it work by providing a moderate amount of affordable units. City sells the land for nothing, with the requirement that x amount of units are affordable for x amount of time, enough for the project to become NOAH and enough for the developer's number to make sense.
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Re: Millwork Commons

Post by Athomsfere »

ita wrote: Thu Sep 22, 2022 1:22 pm
The other thing that might make affordable housing, and I haven't thought about it much, so critique away, is for cities or other public entities to sell property to developers for $1. A decent chunk of any budget comes in the form of acquisition, particularly in high value areas. Once the streetcar is online, all available land is and possible redevelopment sites are going to go up 10-30%, making it even more unlikely that developers can make it work by providing a moderate amount of affordable units. City sells the land for nothing, with the requirement that x amount of units are affordable for x amount of time, enough for the project to become NOAH and enough for the developer's number to make sense.
Do these properties come from the city that often?

I could also see: Property tax breaks on anything over a certain density.
Examples:
0.15 per unit or greater: 100% tax rate
Under 0.15 and above 0.12 98% tax rate
.010 to 0.11 97%


Same with your $1 property, but add on uses:
Super Block Development: 100% tax evaluation.
Super block with mixed use: 98%
Multiple buildings: 98%
Multiple buildings with mixed use: 96%
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Re: Millwork Commons

Post by ita »

Athomsfere wrote: Fri Sep 23, 2022 7:49 am
ita wrote: Thu Sep 22, 2022 1:22 pm
The other thing that might make affordable housing, and I haven't thought about it much, so critique away, is for cities or other public entities to sell property to developers for $1. A decent chunk of any budget comes in the form of acquisition, particularly in high value areas. Once the streetcar is online, all available land is and possible redevelopment sites are going to go up 10-30%, making it even more unlikely that developers can make it work by providing a moderate amount of affordable units. City sells the land for nothing, with the requirement that x amount of units are affordable for x amount of time, enough for the project to become NOAH and enough for the developer's number to make sense.
Do these properties come from the city that often?

I could also see: Property tax breaks on anything over a certain density.
Examples:
0.15 per unit or greater: 100% tax rate
Under 0.15 and above 0.12 98% tax rate
.010 to 0.11 97%


Same with your $1 property, but add on uses:
Super Block Development: 100% tax evaluation.
Super block with mixed use: 98%
Multiple buildings: 98%
Multiple buildings with mixed use: 96%
Here's a quick handful of city/county/state owned properties in the urban core:

- Lot A, B, D
- Old UP site
- Current OPPD and OFD HQ's
- The Wedge parcel south of I-480 by HOA
- All of the parcels currently occupied by the I-480 and on/off-ramps (owned by State)
- Douglas County owns the bus station by the correctional center and the adjacent parking lots
- State building
- Parking garage at Jackson and 10th in Old Market

I like the tiered property tax discount, but residential owners will be up in arms about that.
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Re: Millwork Commons

Post by Athomsfere »

ita wrote: Fri Sep 23, 2022 9:41 am
Here's a quick handful of city/county/state owned properties in the urban core:

- Lot A, B, D
- Old UP site
- Current OPPD and OFD HQ's
- The Wedge parcel south of I-480 by HOA
- All of the parcels currently occupied by the I-480 and on/off-ramps (owned by State)
- Douglas County owns the bus station by the correctional center and the adjacent parking lots
- State building
- Parking garage at Jackson and 10th in Old Market

I like the tiered property tax discount, but residential owners will be up in arms about that.
So not a ton of properties, but enough that using it well could make a significant difference and add thousands of homes. Thanks


On the residential owners:

1. Nothing would change directly for the detached SFH homes.
2. It would benefit condo and townhome owners, or SFH homeowners on some of the oldest homes/ lots in the city
3. 8 Townhomes at 97% still helps the city pay for nicer roads / transit / schools more than a single home at any tax rate.

For example the town homes on 38th and Dewey. That's not 6 lots, at ~0.04 acres assessed at what, $500k. The discount for the homeowner is maybe $200 per year, but for the city to make the same money from the original lot, it would have needed to be $6 million dollar home.

I think it's an education issue (like most planning hurdles).
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Re: Millwork Commons

Post by ita »

Rezoning to CBD for a portion of the SE corner of 12th and Nicholas. Plans call for a 5 story residential building, 74 units, with several ground floor commercial bays. Conceptual plans and render in the exhibits. Same design as other 4+1's.

https://planning.cityofomaha.org/images ... rch/19.pdf
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Re: Millwork Commons

Post by Louie »

Foundation work being done on 13th and Nicholas.
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Re: Millwork Commons

Post by skip »

Louie wrote: Fri Mar 17, 2023 9:50 am Foundation work being done on 13th and Nicholas.
Looks like the foundation is for the Dizzy Mule portion of the project
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Re: Millwork Commons

Post by ita »

ita wrote: Tue Feb 28, 2023 9:38 am Rezoning to CBD for a portion of the SE corner of 12th and Nicholas. Plans call for a 5 story residential building, 74 units, with several ground floor commercial bays. Conceptual plans and render in the exhibits. Same design as other 4+1's.

https://planning.cityofomaha.org/images ... rch/19.pdf
With the White Lotus conversation in the Civic Site thread, I checked some of their current projects. I didn't know they were developing this portion of Millwork Commons, but it is listed in their website.
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Re: Millwork Commons

Post by ita »

https://www.crexi.com/property-listing/ ... the-ashton

Is WP Engine/Flywheel out of the Ashton? Listing says it's been up since October '22. Their website says that they are remote first, office optional.
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Re: Millwork Commons

Post by Louie »

ita wrote: Mon May 15, 2023 10:57 am https://www.crexi.com/property-listing/ ... the-ashton

Is WP Engine/Flywheel out of the Ashton? Listing says it's been up since October '22. Their website says that they are remote first, office optional.
They still have the top floor and a half. But they are sub-leasing some of the space out. Bad timing to renovate a massive office space for them.
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Re: Millwork Commons

Post by BIGO88 »

Use workshop is moving into the millworks as well. Company of 30+ and growing.

https://useworkshop.com/blog/our-new-ho ... k-commons/
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Re: Millwork Commons

Post by Louie »

BIGO88 wrote: Thu May 18, 2023 1:08 pm Use workshop is moving into the millworks as well. Company of 30+ and growing.

https://useworkshop.com/blog/our-new-ho ... k-commons/
Just Workshop, the 'use' is only for the domain.
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Re: Millwork Commons

Post by ita »

Today I drove by and the Disbrow Block/Dizzy Mule is well underway with some of the new construction going vertical. It looks like a block east of it is getting shovel ready as well as the one north of that lot. Anyway, lots of exciting construction activity at Millwork Commons.
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Re: Millwork Commons

Post by ita »

https://www.facebook.com/APMArchitectur ... GwkfFPGewl

Update from APMA on the Dizzy Mule project. New construction is going vertical.
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Re: Millwork Commons

Post by TransitOriented »

Another update

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Re: Millwork Commons

Post by Coyote »


A Slice of Northern Italy


By the time you’ve read these words, a Marana Forni rotating wood and gas oven will have travelled 4,950 miles from fair Verona, Italy, to a kitchen under construction at Millwork Commons in Omaha.

Image

“We are going domestic, as locally as possible for everything we can. Except the oven. That was never a question. We needed this exact oven, and they’re only made in Italy,”locally renowned chef Tim Maides said.

Maides is a man who can make just about anything work, but just this once, he wasn’t willing to negotiate. An agile talent, Maides has been found behind the line at some of Omaha’s favorite eateries. Always the first to pick up a shift, take over a dropped pop-up, and fill in when a global pandemic has everyone scrambling for dear life.
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Re: Millwork Commons

Post by ita »

Submission for replat. Last page shows how they are phasing the project development. Looking forward to seeing this fill out and up.

https://planning.cityofomaha.org/images ... ber/14.pdf
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Re: Millwork Commons

Post by ita »

Update from today, one side of dizzy mule:

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Re: Millwork Commons

Post by Athomsfere »

Its nice to see more infill over there. Leaving Omaha for the airport it always just looks like the city ends in North Downtown.
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Re: Millwork Commons

Post by Dusty »

Idea for Millwork Commons. Could we rebuild Izard Street to connect up to 10th and Cuming?
I was just thinking it would be easier for a bus to cut through the area if this road was connected better.

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Brad
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Re: Millwork Commons

Post by Brad »

Dusty wrote: Wed Jan 31, 2024 11:48 am Idea for Millwork Commons. Could we rebuild Izard Street to connect up to 10th and Cuming?
I was just thinking it would be easier for a bus to cut through the area if this road was connected better.

Image
I always assumed that would happen once UP sells that land and its redeveloped.
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BRoss
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Re: Millwork Commons

Post by BRoss »

Dusty wrote: Wed Jan 31, 2024 11:48 am Idea for Millwork Commons. Could we rebuild Izard Street to connect up to 10th and Cuming?
I was just thinking it would be easier for a bus to cut through the area if this road was connected better.

Image
10th and Cuming is set to be connected 11th and Izard this year. See page 39 of the CIP.