Land Use and Zoning Implications
Municipalities and the development community should work together to identify and address the potential impacts of high cube and automated warehousing, as municipalities amend their zoning ordinances and subdivision and land development ordinances to reflect these emerging and rapidly evolving uses. High cube and automated warehousing can happen anywhere, from new construction on former agricultural fields, to redevelopment of existing retail properties, to retrofit of existing buildings. When evaluating these different development approaches, municipalities should consider the tools at their disposal in the form of zoning ordinances, subdivision and land development ordinances, and building codes, that can assist in planning for an increase in these uses, while mitigating adverse community impacts.
The following sections provide specific considerations for communities when assessing potential impacts—positive, negative or neutral—of high cube and automated warehousing:
Permitting and Review / Approval Process
Municipalities looking to regulate high cube and automated warehousing in their zoning ordinances should consider a number of zoning specific factors, including refining industrial use types, as high cube and automated warehousing uses require specific definitions and regulations.
Zoning district locations are critically important for matching the intensity of land use with locations that minimize impacts and provide the best outcomes for municipalities. Generally, locating these uses in existing industrial parks and in urban areas with proximity to major arterial roads and highways will mitigate conflicts between area residents and commercial vehicles. Municipalities must balance their needs between matching building form and scale, to matching transportation demands, to appropriate infrastructure. Locating a high cube or automated warehouse in an urban area with similar building heights may be appropriate for the landscape, but traffic generated by the use may also be detrimental to the street network. Conversely, matching the use and scale of development to appropriate infrastructure may result in an inconsistent building form if there are no existing buildings of the same scale.
Special Exceptions and Conditional Use
Municipalities should consider allowing these as special exceptions or conditional uses, rather than uses permitted by right, to allow thorough understanding of project specifics and resulting impacts of the proposed use.
“Special exceptions and conditional uses are usually reserved for those land uses that will have a significant impact on the zoning district or the whole community, or for those uses that necessitate additional safeguards. Common examples of such uses include, but are not limited to, landfills, warehouse and distribution facilities, telecommunications towers, etc. These additional safeguards take the form of specific standards and criteria stated in the zoning ordinance. The applicant for a special exception or conditional use must demonstrate compliance with the specific standards and criteria stated in the zoning ordinance.”
- Pennsylvania Department of Community and Economic Development, Planning Series 07
Municipalities should position themselves for developing the best projects in the interest of their community by periodically reviewing and amending ordinances to reflect modern or emerging development trends like high cube and automated warehouses. Subdivision and land development ordinance amendments should be made to require an impact analysis for these specific types of uses. Analyses should consider not only traffic impacts but economic impacts, such as job creation, as well as environmental impacts, including but not limited to viewshed analysis and environmental impact statements. Studies of this nature allow communities to make more informed decisions on land development proposals, especially related to public safety.
One tool used to facilitate conversations between a municipality and developer is a sketch plan. A sketch plan submittal and review requirement is designed to provide developers an opportunity to informally discuss project intentions with municipalities. The plan is reviewed for general scope and layout, conformity with applicable municipal requirements and the local comprehensive plan, as well as for conditions which might affect the implementation of the development. Incorporating a sketch plan requirement in the subdivision and land development ordinance will enable public and private collaboration to ensure the project is designed to fit the fabric of a community, while also respecting property rights. Municipalities may also choose to require that the sketch plan be reviewed by the LVPC. This is recommended, as it allows for review of consistency with FutureLV: The Regional Plan, and provides an opportunity for a municipality to receive additional recommendations for improving upon the proposal.
Amending both the zoning code and subdivision and land development ordinances with these provisions allows a developer, in a site development or redevelopment scenario, or an end-user, in the case of a building retrofit, to understand community needs and vice versa. This allows communities to consider industrial sector needs related to goals outlined in the comprehensive plan, empowering communities to facilitate discussion among residents, stakeholders, appointed officials, elected representatives and developers and facility end users. Ultimately, this leads to more sustainable and resilient businesses and communities.
Height and Viewshed
In consideration of the larger region, there is a possibility of significant changes to the landscape created by tall industrial buildings, lacking architectural features, potentially visible from miles away. These projects set unique standards for warehouse height, resulting in significant visual impacts across the region. Building architecture and articulation standards should be considered to support community character.
This substantial building height could not only change the character of the municipality where it is proposed, but of neighboring communities and even the region. Permissible building heights should take into account distance to adjacent buildings and property lines to avoid impacts to emergency access and changes in neighborhood character—both critical to safety and to the tax base. Topography and tall structures nearby are also considerations for viewshed impacts. For example, a 100-foot-tall high cube warehouse may not have a negative impact in a location with other tall buildings or high hills or mountains.
Height of high cube warehouse compared to Bethlehem Steel Blast Furnaces
On the other hand, high cube warehousing could have a sharp effect if the heights of buildings nearby or topography are out of scale with the proposed tall structure. In these cases, the high cube warehouse becomes the “landmark” or the dominate feature in the landscape. In communities and neighborhoods with lower height buildings and flatter topography, taller structures will have more of an impact.
Height of high cube warehouse compared to Talon roller coaster at Dorney Park
The contrast between these two points of reference is created by the topography and character of the communities in which they are located, and underscores the importance of municipal height and viewshed consideration.
Communities should amend subdivision and land development and zoning ordinances to require viewshed information and analyses to assess the potential impacts, both positive and negative, where high cube and automated warehousing is proposed. Appropriateness of these taller structures in environments that can accommodate their impacts to the landscape, such as in existing industrial parks, with similarly tall buildings and where substantial elevation changes exist in the surrounding landscape should be considered.
Airport-Related Height and Use Restrictions
An important consideration municipalities must make in allowing for high cube and automated warehousing are Federal Aviation Authority (FAA) height restrictions related to airports. These regulations are reinforced through Pennsylvania Act 164 of 1984, the Airport Hazard Zoning Law.
Height restrictions exist to ensure obstructions, such as buildings and signs, are not constructed in airspace associated with airport approaches. They are mandated through both the state and federal governments and should be reflected in municipal ordinances through airport overlay zoning. The FAA identifies surface zones, which are associated with aircraft approaches to airports and have varying degrees of height restrictions depending upon the type of aircraft utilizing the airport, approach paths and topography, among other things. These height restrictions must be considered when municipalities are implementing zoning ordinance changes.
Regionally, the Lehigh-Northampton Airport Authority oversees Lehigh Valley International Airport, Queen City Municipal Airport and Braden Airpark. Half of all municipalities in the Lehigh Valley are within one or more surface zones. As many municipalities are experiencing the pressure of industrial growth, coordination with the Lehigh-Northampton Airport Authority and implementation of standards that do not allow for obstructions in airspace is vital.
Use restrictions are also a consideration for municipalities that are within surface zones. The permissibility of industrial uses is not of concern outright, but detailed assessment should be made into the proposed materials used, stored or manufactured at facilities within the surface zones to ensure no site-specific hazards are presented. Limitations or outright prohibition should be made to the extent and intensity of hazardous materials stored or utilized at high cube and automated warehouses to mitigate impacts of a disaster, should one occur.
Structures of this scale and height pose a need for thorough evaluation of services provided by fire companies, police forces and emergency medical operations. These considerations are especially important for those entities that rely on volunteers, have equipment that can only serve lower height buildings, and organizations that lack specific emergency response training for larger, taller and high-powered (potential electrical, hazardous materials risks) facilities. Communities should evaluate the equipment required to mitigate emergency situations and engage service organizations in conversations about capital equipment needs, training and resources necessary to serve these facilities. Simultaneously with the development or use alteration or change, communities need to understand the fiscal impact and ultimate pressure on the tax base.
Emergency Services Impact Statement
Municipal subdivision and land development ordinances should be amended to reflect standards that consider the equipment and capital needs of emergency service operations. The best way to do this is to involve emergency management personnel including, police, fire and ambulance services, in the application review process. Emergency services impact statements, which could be in the form of a questionnaire included with the zoning or subdivision and land development application, should be developed and codified for high cube and automated warehousing proposals. This is especially vital to the success of service provisions to existing facilities that are retrofitted to accommodate these emerging technologies. Impacts evaluated in association with existing facilities should consider not only those on the surrounding community but also on the project site, such as reviews of parking, drive aisle, fire lane and staging adequacy.
In many ways, use changes or expansions should almost be treated like a new development proposal by the local government. This doesn’t necessarily mean that a full land development application is required, though it could, depending on the extent of the proposal. In some cases, a municipality may simply require a building permit to retrofit a structure. However, if traffic could double, the types of materials stored is changing, volume of goods warehoused is substantially increasing, or amount or type of energy being used to operate a facility is changed, then emergency response needs will change.
Public Safety Committees
In order to facilitate communication and coordination between emergency response organizations affected by a development proposal, it is recommended that municipalities establish a ‘public safety’ or ’emergency services’ committee. As appropriate, based on entities providing service in a particular municipality, the committee should be comprised of local police, state highway patrol, fire companies, ambulance services, municipal public works departments, and appointed municipal residents. This committee would afford an early opportunity for engagement and review of the potential impacts of a plan on the general health, safety and welfare of a community.
A committee of this sort would further allow for emergency services, such as fire departments, to coordinate anticipated emergency response and planning for future service to a proposed high cube or automated warehouse, and ensure that the most accurate data is included in the Lehigh Valley Hazarard Mitigation Plan. It is important for first responders to have knowledge of the internal structure of a building, any operations that may hinder or complicate emergency response and inner workings of a proposed facility, including any hazardous material situations particularly involving automation or stored goods. The location of areas accessible to employees is also important to planning for future public safety needs, especially in high cube and automated warehouses where employees are not generally located within the structure above the typical first floor height.
The LVPC recommends that municipalities incorporate requirements for the economic study and assessment of development impacts into their subdivision and land development ordinances. Proactive municipal provisions will ensure that a community is not required to bear full responsibility for costs associated with a proposed development.
Changes in development patterns and community character associated with high cube and automated warehousing pose potential impacts to property values, for example, by reducing market interest in buying a home near a facility that has high rates of ongoing daily traffic, noise generation, or a blocked viewshed. Considerations of all possible economic impacts to the region, municipality and residents compels a partnership between the public and private sectors to ensure the long-term viability and success of these facilities. The use of cost-benefit analysis in planning, development and infrastructure decisions is vital to quantify potential impacts.
In addition to considering the amount of tax revenue a community may receive, it is important to assess potential costs to ensure:
Ultimately, if workers cannot get to their jobs because of poor system quality or congested infrastructure and a lack of public safety, businesses will struggle, tax revenue will decline and the potential economic benefits of a high cube or automated warehouse will decline.
Cargill Cooler DRY Automated Storage and Retrieval System – 103 feet – Sidney, Ohio. Photo courtesy of Griffco Design/Build, Inc.
Job creation and retention is a major consideration and should be integral to any negotiations between municipalities and developers or end users. Municipalities can account for economic impacts of both new and existing facilities by including high cube and automated warehouses as a special exception or conditional use in their zoning ordinances as a mechanism to allow for municipal negotiation through the development review and approval process.
Counties, school districts and municipalities should consider ways to ensure a return on investment in terms of tax revenue compared to local costs associated with service of these facilities. Monitoring industrial occupancy and vacancy is also important to maintaining jobs and the tax base, and ensuring that development is as additive to the community and region as possible. Creating a database of building and property actions allows local governments to monitor use and allows municipalities, counties and the region to get in front of major changes. This allows for incentives for redevelopment; changes in employment density, transit ridership, and emergency response needs; and other impacts to be managed in the best interests of all segments of the community.
High cube warehousing and related industrial land uses are often built with the intent of leasing to companies based upon agreed timeframes for property rental. By leasing a property, a company does not need to commit to the additional expenses and responsibilities of long-term property ownership. At the end of a contract the leaseholder will either need to renegotiate an agreement or may be free to vacate the warehouse or industrial space. This can, in turn, create the need to redevelop or renovate such structures to attract new leaseholders.
An industrial development analysis by CBRE Group, a national commercial real estate services and investment firm, identifies the Lehigh Valley as a key region for assessment in the Interstates I-78/I-81 Corridor. Analysis from the second financial quarter in 2020 has identified several trends in the supply of industrial space for leasing that may impact the long-term viability for high cube and automated warehousing. As speculation and the supply of industrial space throughout the Lehigh Valley region has increased, the long-term usage of these structures should be considered.
The “persistent demand” for industrial space is indicative of the need to prepare for change. CBRE notes that both third-party logistics companies, e-commerce, retailers and food and beverage manufacturers are the primary sub-markets leasing industrial facilities. Space that has been vacant for several quarters was beginning to fill as a result of the stay-at-home order, which halted new construction in the spring and early summer. The Lehigh Valley, in particular, has the lowest industrial vacancy and corresponding highest contract rents in the I-78/I-81 Corridor. As the land available for industrial development declines, inventory declines and consumer demand for products and services purchased online increases, proposals for high cube and automated warehousing will only increase.
Municipalities should strive to understand the existing development trends to best plan for a healthy supply of various land use needs. Permitting too much industrial space, or any type of land use for that matter, may create an oversaturated market, and lead to high vacancy rates or a need to constantly revitalize existing structures. The technology used in high cube and automated warehouses is often built with a dual-purpose of serving as the support structure for the building frame as well as facilitating goods movement. These structures, particularly in instances of new construction, are often built to serve a specific tenant. Municipal plans and ordinances should encourage flexibility to support reusability and long-term marketability of these facilities, as the specificity of building design may reduce opportunities for reuse if the tenant vacates.
Below is a warehouse in the City of Allentown proposed for redevelopment into apartment units in 2020. The structural building frame lends itself to a variety of reuse options that would not be available for structures built to consist only of automation technology.
LVPC file photo
Approximately 10% of the region’s workforce, 31,795 Lehigh Valley employees, is in the transportation and warehousing industry (Lehigh Valley Workforce Development Area Profile, October 2020). Highly-automated facilities are bound to have substantial impacts on the local and regional workforce, with the distinct possibility of requiring fewer employees. This could result in fewer jobs available to people with minimal education and younger workers with little work experience. It’s a concern for many communities as the potential loss of regional warehousing jobs to robotics technology occurs simultaneously with the ongoing decline of retail positions. Scott Anderson, director of Amazon Robotics Fulfillment, said in a 2019 statement that it’s possible that existing facilities will convert to high automation within the next 10 years (Gizmodo), and a 2020 report from the National Bureau of Economic Research indicates that companies are likely to move even faster towards automation investments as a result of the COVID-19 Pandemic.
As one of the largest employment sectors in the Lehigh Valley, changes in the number of warehousing jobs resulting from the trend toward automation should be closely monitored by municipalities, counties and the Lehigh Valley Workforce Investment Board. However, there is currently no data to confirm that rapidly increasing automation will result in massive layoffs in the near future. Reports by the University of California Berkeley Labor Center and Harvard Business Review suggest that automation is more so changing the day-to-day functions of existing jobs.
Assessing Employment Impacts
Communities should assess potential employment impacts related to new development, redevelopment and retrofit projects. Public and private partnerships should be formed to ensure that developers are advising municipal governments of job creation and loss, or overall change, as a measure of impact to a community. Subdivision and land development ordinances should include provisions for economic impact statements with these types of proposals that specifically address impacts to a community’s workforce. For building retrofits, where the subdivision and land development ordinance is not applicable, municipalities should consider the implementation of assessment forms with required zoning applications. These assessment forms should collect pertinent information, such as expected change in employee volume and traffic generation, so that municipalities can appropriately plan for shifts in municipal service needs.
Sustainability and Design
Incorporating sustainable building practices and design provides immense benefits to the community and developer. Utilizing renewable resources or employing sustainable design increases asset value, and decreases operational costs for the user through energy, water, maintenance and waste savings. Additionally, stormwater management benefits are generated through overall green infrastructure design.
As communities implement sustainable building practices, the benefit of reduced building footprint through increased building height should be considered. Increased ‘vertical’ impact is likely to result in the need for less land to develop these facilities and will result in reduced pressure on greenfield development, helping to sustain the Valley’s limited natural resources. Building retrofits for automated warehousing are also supportive of the environment in this way.
Geneva II Warehouse in Charlotte, NC. Photo courtesy of Shelco LLC.
Prologis Park 33 Building 1 (above) in Lower Nazareth Township utilizes energy-efficient lighting. Prologis Park 33 Building 2 (below) utilized recycled and locally sourced materials for construction.
Photos courtesy of Mowery
Developers should also consider the benefits of incorporating sustainability into designs, as green building has become an increasingly popular and widespread practice that can enhance business reputation in the industry. Warehousing and distribution developers such as Prologis are pushing the envelope in this area.
Although a relatively new land use, the nature of high cube and automated warehouses to be highly efficient opens them to many sustainable opportunities to reduce development pressure and lessen their carbon footprint. Developers or end-users can initiate these energy cost savings by installing solar panels or energy-efficient light fixtures.
Municipalities can incentivize the inclusion renewable energy systems and energy-conserving building design in their subdivision and land development ordinances, per the Pennsylvania Municipalities Planning Code (MPC) Section 503(6). For example, offering a density bonus when meeting sustainability thresholds can benefit the developer and the community by offsetting the associated costs of sustainable systems over the long-term, while lessening impacts of the development on the environment.
For greenfield and redevelopment sites, aesthetic features such as building form and shape, as well as minimum percentage of window area per building wall, would supplement these sustainable design recommendations and reduce the visual impact of the building’s height. Standards for building form and shape should address wall and roof scale to break up one’s line of sight. For instance, municipalities could require columns on building walls to break up the monotony of a flat wall. Minimum window requirements should ensure adequate visibility into and out of spaces accessible to employees and the creation of the appearance of windows, through building wall design, in storage areas.
Allowing high cube and automated warehouses as a special exception or conditional use supports the ability to secure minimum architectural standards. In addition to building form, architectural standards can also involve a variation of colors on building walls to reduce the perception of a ‘white box’, all of which can be negotiated through the special exception or conditional use process.
Establishing a process that enables and encourages community feedback on proposals helps build trust between local governments, residents and the private sector, educates the community on the legally applicable process, and ultimately results in better projects that are more suitable to community needs and desires.
It is in the private sector’s best interest to have an understanding of a community’s goals and objectives. For instance, a public open house allows residents to visualize what the project may look like early in the planning process. This can garner community support and understanding, and can serve to address or mitigate concerns that may not otherwise be raised until substantial investment has already been made in the project design. These community engagement opportunities provide a platform for resident voices to be heard prior to any formal review and informs developers of potential historical issues within the area, such as road flooding. It also allows resident desires, such as a walking trail or buffering beyond what the subdivision and land development ordinance requires, to be considered.
In addition to internal meetings held between a municipality and developer, pre-submission meetings can involve the other community partners, such as the LVPC, Lehigh and Northampton Transportation Authority (LANTA) and the Lehigh Valley Workforce Investment Board. Pre-submission meetings are highly encouraged because they offer parties the opportunity to provide higher-level insight into regional implications and consider a holistic approach to development, transit accessibility and sourcing workers once the project is completed.
Changes to existing traffic patterns, especially truck traffic, is a principal concern of most communities. The LVPC encourages that any special exception or conditional use, and particularly any warehouse use, include a traffic impact study. Traffic impact studies are reports that estimate the changes that are likely to occur to the overall transportation network near the land development project based upon access needs, projected trip generation of traffic and potential effects to congestion along access roads.
Traffic Impact Studies and Trip Generation
Traffic impact study requirements are established within a municipality’s subdivision and land development ordinance. A traffic impact study is another tool used to assess the ramifications of a development, inform of future transportation constraints and enable a community to plan the best possible project outcome. Transportation impacts specifically related to high cube and automated warehousing are not fully known and are changing rapidly, therefore such scrutiny should be taken for these types of land uses.
Traditional and high cube warehouse land uses are each estimated by a separate traffic trip generation rate by the Institute of Traffic Engineers (ITE) Trip Generation Manual, 10th Edition. The ITE Manual is the engineering standard for calculating estimates of vehicle trip generated by developments. There is a relatively small volume of study information available in the high cube warehouse land use database. The database relies primarily on floor area, while there is a stronger correlation between vehicle trips and building gross square footage in regard to high cube warehousing. Gross building storage square footage is currently not available in the ITE Trip Generation manuals.
The ITE manual calculates traffic based only on gross floor area, a reflection of traditional warehouse footprints, which may not necessarily reflect the impacts of structures with storage capacity of 100 vertical feet or more. In essence, by measuring only floor area ITE treats a 24-foot-tall building with a floor area of 200,000 square feet the same as it treats a 100-foot-tall building with 200,000 square feet of floor area. In reality, the 100-foot-tall high cube or automated warehouse building is akin to stacking four traditional warehouses on top of each other.
Careful consideration is necessary to develop policies regarding a ‘warehouse built on top of a warehouse’. As these uses appear it may mean radical changes in trip traffic generation calculations. The goods stored and moved are available in far greater quantities when stored vertically rather than in traditional warehouses, making assumptions of transportation impacts a complicated endeavor. The limited data available for cold storage facilities produce acceptable levels of accuracy for vehicle trip estimates. However, vehicle trip generation rates based on data collected in recent years are higher than those derived from data collected at least 10 years ago. It is recommended that further investigation be made into the existing data and that additional data be collected.
In the meantime, it is anticipated that industrial developers and engineers will utilize the ITE Trip Generation Manual to calculate vehicle trips and level of service changes to the roadway system. It is critically important to note that bridge sufficiency ratings, pavement quality and maintenance, transit connections, air quality impacts, among other key questions should be addressed as part of a transportation impact statement. Some of these factors have standardized data available to assess impacts, like the ITE Manual and PennDOT traffic safety data, but other impacts are more localized, like bridge condition assessments or the ability of a road to withstand higher frequency and higher weight vehicles without falling apart. Proximity to housing, hospitals, elder care facilities and schools can have impacts as well. These may be negative, such as lowered air quality, or positive like infrastructure already built to standards that support more intense uses. Transportation Impact Statement requirements should accommodate the variety of scenarios that can arise when development is proposed.
As automation makes loading and unloading of trucks more efficient, it is likely that truck turnaround time may be faster as well, enabling a higher usage of the transportation network than traditional warehousing.
Challenges have been noted, but opportunities also exist. Higher intensity uses can be clustered to target costly infrastructure improvements to limited areas, reducing upfront and long-term maintenance costs, as one example. Also, high cube and automated warehousing, in and of itself, is a significant technological achievement. This increase in efficiency and advancement can be carried beyond the building’s interior and to the parking areas through electric charging stations for tractor-trailers and solar powering for the building’s operation, as well as supporting automated traffic signal corridors key to reducing congestion and air pollution and enhancing emergency management services delivery. Again, each development or redevelopment will have unique needs, as will the seamless integration of that facility into the community. Holistically approaching issues and needs through traffic impact assessments can support facility and community success.
This 68-foot-tall Prologis facility in Seattle features a highway-style ramp network that enables tractor-trailers to dock at two levels of bays, potentially doubling truck traffic at the building. These increased impacts are something for the Lehigh Valley region to consider. Locations with substantial industrial development near highway interchanges, near the Lehigh Valley International Airport or along major freight corridors should prepare for highly intensive facilities as industrial land becomes more limited.
Photo courtesy of Prologis
Truck Routes and Access
The scoping of a traffic impact study should identify all transportation impacts, including vehicular, truck, pedestrian, multimodal and transit access. The scope of the traffic impact study should scrutinize the planned truck routes, particularly between the project location and the closest highway or interstate because the trucks utilizing these facilities will ultimately want to connect to a highway. It is critical to plan and identify the best logical and capable truck route to access these high classification roadways, to minimize tractor-trailer impacts on local roads. Improvements to potential conflict points along these routes may be negotiated between the developer, municipality and Pennsylvania Department of Transportation (PennDOT), which will ultimately make a project more accessible to tenants and users. Traffic impact studies should also consider on-site needs, including parking and insufficient infrastructure capacity.
Tractor-Trailer and Driver Amenities
Minimum truck parking and queuing requirements at facilities, along with driver amenities, should be included within the subdivision and land development ordinance. This recommendation also involves access opportunities, such as gated facilities, to ensure that trucks are not queuing along the roadway but rather internal to the site.
Municipal standards should also require or incentivize electrical hookups within truck parking areas, both for trucks and for refrigeration trailer units in which goods are transported. Electric-diesel hybrid refrigeration trailer units are becoming more common. The availability of hookups will mitigate the impacts of diesel-run units on the neighboring area and regional air quality.
Impacts to the origin and destination of goods, as well as staging and parking concerning the commodity flows to logistics of freight, are anticipated to change. Driven by continual e-commerce demand, it is likely that regulation of these uses will require ongoing evolution to maintain the service expectations of citizens. Direct attention by both PennDOT and municipal officials should focus on monitoring traffic generation and it impact on the Lehigh Valley transportation network. The true changes to both state of good repair and existing conditions present an ongoing issue, and the growing demand on the transportation network will require continued assessment on both a case-by-case and global basis.