ERA Architects

Toronto Set in Stone

A guest article by Brendan Stewart—Assistant Professor, Landscape Architecture, University of Guelph


Stone plays an outsized role in defining many of Toronto’s most beloved and well-used public spaces. Of course there is something singularly enchanting about the material itself, but as important is how it is arranged and put together — the artistry and craft that elevates the average to the exceptional.

Stone and stone work is something I’ve been thinking about more and more, starting with an article I wrote last year in Ground Magazine about dry stone walls, which has led to my involvement as a guest speaker at the upcoming Dry Stone Canada Festival on Amherst Island at the end of the month, and a talk next week at ERA with visiting Scottish stone artist David Wilson (RSVP here), which will explore ideas about the creative use of stone in public spaces.

In Toronto, a recent recurring theme is the importing and re-purposing of ancient precambrian boulders; carefully selected, removed and transported at great expense from northern Ontario’s Canadian shield wilderness, and strategically re-installed in vibrant downtown settings.

Ryerson Image Centre and Devonian Square (photo: Hoice, Wikimedia Commons).

Think of Devonian Square at Ryerson, created in 1978 by landscape architects Richard Strong and Steven Moorhead, which features artistic groupings of massive boulders scattered around the plaza, and is the setting for winter scenes of ice skaters whose silhouettes are dwarfed as they weave in and around the rock.

Then, there’s the giant granite outcropping that defines Village of Yorkville Park, created in the early 90s by US landscape architects Martha Schwartz, Ken Smith, David Meyer and PWP Landscape Architecture. An iconic landscape landmark to match any in Toronto, the experience of emerging from underground at Bay station to meet a friend for coffee on the warm rock is unique to Canadian urbanism.

Sugar Beach by Claude Cormier + Associés, opened in 2010, pays homage to the granite outcropping at Yorkville Park, but integrates playful white and red candy-cane stripes, referring to the active Red Path sugar factory that animates the dramatic, working waterfront views.

And finally, there is the newly opened Trillium Park, designed by lead landscape architects LandInc, which features the 83 metre long ‘Moraine Bluff’ — an artfully sculpted, complex wall of stone that was designed using an innovative combination of digital modelling and in the field craft. Laid out in full on the floor of a quarry in Dwight Ontario, the wall was then transported and re-constructed on the lakeshore at Ontario Place[1].

‘The Ravine with Moccasin Identifier’ Trillium Park (photo: Brendan Stewart).

‘The Ravine with Moccasin Identifier’ Trillium Park, details (photo: Brendan Stewart).

Moraine Bluff, Trillium Park (photo: Brendan Stewart).

These projects, all representing in one way or another the ancient and sublime landscapes of the near north, all go to extraordinary lengths logistically, technologically, and artistically to bring the sensual and intangible resonance of stone into the city to create powerful civic experiences.

Stone, of course, has been used in many other wonderful ways in Toronto’s public realm. From interpreting and commemorating the history of the Irish Famine migrants who landed in Toronto in 1847 at Kearns Mancini’s Ireland Park (2007), to defining tranquil academic courtyards such as the Quadrangle at University College, executed by landscape architect Michael Hough in the mid 1960s[2].

And before this, there is the rich legacy of carved stone, integrated into the great buildings of 19th and early 20th century Toronto, some of which remain in situ, and some of which can be explored, as salvaged and re-constructed artifacts in the unique Guild Park and Gardens at the top of the Scarborough Bluffs. This wonderful and curious place is described and explored in a 2016 article in Ornamentum by ERA alum Tatum Taylor here.

For more fascinating discussion on the topic of creative urban use of stone and placemaking, join us at ERA on Monday, September 24 with Scottish stone artist David Wilson (RSVP here).

 


[1] See ‘Romance of the Stone: When metaphor meets technology’ by Patrick Morello in Landscapes Paysages v.19, Winter 2017.

[2] See ‘Quiet, Green, and Orderly: The History of the UC Quadrangle’ by Jane Wolff

Creative Space & Urban Stone: Public Talk

Stone is the most fundamental material but over the last 50 years its creative use has declined in the public realm. Through a Winston Churchill Memorial Trust Fellowship David F. Wilson aimed to discover how other creatives are exploring the space between tradition & current practice, travelling in the USA & Canada through the summer months of 2017.

Where problems exist, new opportunities open up. Using photos and examples, David’s talk will explore the findings of his North American tour, the challenges posed to creative stone craft through modern building practice, and innovative ways to keep stone craft alive in urban spaces.

Through the lens of his landscape architecture practice and university teaching, Brendan Stewart will respond to the report and extend the conversation, relating these findings, challenges and opportunities to urban spaces in Toronto and Canada.

Report here: https://www.wcmt.org.uk/fellows/reports/creative-space-contemporary-use-stone-urban-spaces


A public talk by David F Wilson (UK) in conversation with Brendan Stewart (University of Guelph), co-hosted with the Dry Stone Walling Association of Canada (Dry Stone Canada).
REGISTER HERE VIA EVENTBRITE 

Doors at 6:30pm, Talk begins 7:00pm
625 Church Street, Toronto

3 minute walk from Bloor-Yonge Station (TTC)
Car and Bike Parking at the rear of building (Impark Parking)
This venue has elevator access and an accesible washroom

Reception to follow, generously sponsored by Jonathan Kearns, Founding Principal of Kearns Mancini Architects (B.ARCH., OAA, FRAIC, RIBA, FRIAI, AIBC, AANB, AAA) and Member Dry Stone Canada


David F. Wilson
Artist, Designer, Waller, Maker
Winston Churchill Memorial Trust Fellow and author of Creative Space: Contemporary use of stone in urban spaces

David graduated in 1987 from Duncan of Jordanstone, Dundee, with a Masters in Public Art & Design. Following a college art degree, he was inspired by a new trend for artists to work outside the traditional gallery system and decided to pursue a creative career in art for a wider public.

Flexibility has always been an asset in David’s practice when creating works in a public space. Every client & every different situation requires a unique design solution. Combining creativity with a playfulness of technique and form has always been at the heart of his process.

Two public projects that display this aspect well are the Edinburgh Airport Interchange and Livingston Landmarks. The latter was awarded the coveted Pinnacle Award from the Dry Stone Walling Association of Great Britain.


Brendan Stewart
Assistant Professor, Landscape Architecture, University of Guelph; past Associate, ERA Architects, Toronto

Brendan Stewart received his BLA from Guelph, attended Edinburgh College of Art, and received an MLA from the University of California, Berkeley. Brendan’s research focuses on heritage conservation planning and design processes, cultural landscape theory, design history, service learning and participatory design practices.

Throughout his more than a decade of practice experience, Brendan has been actively engaged in the academic, professional, and community spheres. He has been a regular guest lecturer, critic, and instructor at the University of Toronto, Ryerson University, and the University of Waterloo, and was an editorial board member of Ground Magazine, the journal of the OALA.

In 2015, he was involved in organizing and participating in the ‘Leading with Landscape’ conference in Toronto, hosted by the Washington DC based Cultural Landscape Foundation, which was attended by over 400 landscape practitioners and scholars from around the world. He is a director of the Friends of Allan Gardens a not for profit organization with a mission to revitalize one of Toronto’s earliest designed landscapes. Starting in 2017, Brendan is the University of Guelph’s appointed educator to the Ontario Association of Landscape Architects governing council.

 

ERA & CaGBC: Sustainable Development

Late last month, on Thursday April 26th, the Toronto Chapter of the Canadian Green Building Council met for their annual Spring Open event. Hosted at the newly opened EY Tower downtown, the event included a series of rapid and informative presentations known as the event’s “Building Blitz” —highlighting the newest and most sustainable buildings in Southern Ontario.

ERA’s Shelley Ludman was invited to speak about the adaptive reuse of 158 Sterling Road, the new home of Toronto’s Museum of Contemporary Art (MOCA). We were honoured to present on the often overlooked importance of adaptive reuse as a strategy for a sustainable future.

Other presentations included: 

  • 80 Atlantic Avenue, Presented by Quadrangle
  • Zero House at the Endeavour Centre, Presented by Ryerson University, Department of Architectural Science
  • Kiln Building at Evergreen Brick Works, Presented by LGA Architectural Partners
  • University of Toronto – The Centre for Engineering Innovation & Entrepreneurship, Presented by Montgomery Sisam Architects Inc. 
  • York University Student Centre, Presented by CannonDesign

Government Conference Centre: Progress on Heritage Interiors

The heritage interiors and finishes are coming to life at the Government Conference Centre (GCC) in Ottawa. Since the new year, the scaffolding has come down in the General Waiting Room (GWR, as shown here), revealing the rehabilitated suspended ceiling in its entirety and the recently painted imitation travertine wall finishes.

The GWR is an elaborate and significant interior space, part of the formal processional route bringing visitors through the building to some of its grandest interiors. As a visitor enters through the Rideau Entrance Lobby, down the grand stair, they find themselves here: viewing the building’s Beaux-Arts features evident in its monumental use of classical forms such as the columns, entablatures, pilasters, arches and vaults.

The GCC Rehabilitation Project is transforming the former Ottawa Union Station into an Interim Senate Facility for ten years, after which it will revert back to its role as the GCC. The rehabilitation aims to reveal the historical elements of the building that were concealed over time, such as its theatrical qualities and rich palette of materials.

ERA Architects is working as the heritage architects with Diamond Schmitt/KWC Architects in Joint Venture.

Photos courtesy of ERA Architects.

62 – 64 Charles Street: The Lost Craft of Tuck-pointing Returns

Tuck-pointing was developed by the English back in the late 17th century and was practiced all the way up to the early 20th century. Historic preservationist/educator Michael Shellenbarger states in a 1993 essay titled Tuck Pointing History and Confusion the correct definition of tuck-pointing (based on historical precedents) is:

…… a masonry jointing that uses mortar in two colours to simulate the appearance of narrow joints. The actual joint is disguised with a flush mortar tinted to appear similar to the colour of masonry units. A joint like groove (the tuck) is often cut into this flush joint. Then mortar of a contrasting colour is added onto the flush joint and into the groove and is shaped and trimmed into a narrow false joint, which usually projects slightly. This line gives the appearance of a narrow projecting jointing.    

Completed properly, tuck-pointing is the most highly skilled of all pointing finishes. It creates the illusion of finely pointed gauged brickwork, enhancing the quality of appearance of buildings constructed of damaged or irregular bricks.

62 – 64 Charles Street East, an ERA project where recent conservation work has restored the tuck-pointed building to its former glory under the expert hand of Hunt Heritage. This is the largest application of the process that ERA has been involved with, and it’s an exemplar for bringing this lost craft back to the city. The project was undertaken in the late summer of 2015 and completed in late spring of 2017.

As heritage consultants ERA strived to protect the value, significance and integrity of the heritage assets. The work required a full conservation scope on the semi-detached house, that included the rarely-seen craft of tuck-pointing for which National Trust (Aus) award-winning Tuck-pointer Antoni Pijaca was hired to share his expertise and the secrets of his trade.

The Charles Street project was honoured last fall with a 2017 CAHP Award of Excellence —Materials, Craftsmanship and Construction. ERA is continuing to feature this technique prominently through work on the Selby Hotel at 592 Sherbourne, which is set to be completed in the summer.

For more information: https://www.youtube.com/watch?v=zxPc6_2R-Hc
Article by Dave LeBlanc in the Globe and Mail: https://www.theglobeandmail.com/real-estate/toronto/the-lost-art-of-tuckpointing-reborn-intoronto/article37802073/

Related content: http://www.eraarch.ca/2017/capitalizing-on-heritage-awarding-conservation-materials-craftsmanship-and-construction/
http://www.eraarch.ca/2017/era-learns-the-fine-art-of-tuckpointing-from-a-melbourne-based-master/
http://www.eraarch.ca/2012/tuckpointing-a-note-on-detail/

 

In-House Experts: Barrier-Free Design and Heritage Buildings

At ERA we thrive on finding new uses for existing buildings and integrating the heritage fabric of our city into contemporary designs. One of the ways we approach conservation of existing fabric is through modifications to buildings and cultural landscapes that enable all users to enjoy our shared heritage. Many heritage structures are not barrier-free by today’s standards: the main entrances often are only accessible by stairs, they have heavy doors without automatic operators, the washrooms don’t accommodate wheelchair users, the stairs don’t have the tactile and colour-contrasting nosing that aid users with low-vision in navigating them.

Improving upon our heritage fabric to create a more accessible environment requires a careful and sensitive approach. Whereas a barrier-free approach to a new building design is integrated from the very beginning, a barrier-free retrofit requires considering the impact of the alterations on the historical features of the building: How can we position a new entrance ramp to minimize its visual impact? How can we modify existing doors to accommodate power door operators without damaging the existing fabric? How can we renovate an existing washroom to allow for universal access? What materials can we use to provide tactile and colour-contrasting nosing without negatively impacting a historical wood stair?

Two of our most recent projects in downtown Toronto feature smart designs that integrate barrier-free features into the existing fabric of heritage structures: the Sultan Street Development and 330 University Avenue.

The Sultan Street Development features the integration of a row of red brick Romanesque houses with a new office tower development designed by Hariri Pontarini Architects (HPA). As the original entries to the heritage houses featured a series of steps up to the doors, they impeded the possibility for barrier-free access from the street. ERA proposed a simple modification to the entrances which lowered the doors to street level and enabled barrier-free access without the need for a ramp or elevating device.

At 330 University Avenue (also known as the Canada Life Building), ERA took a different approach to providing barrier-free access. In this case, the existing steps to this Beaux Arts building were maintained and a ramp was designed to allow barrier-free entry through one of the three main doors off University. In addition, the original bronze and glass doors were equipped with power door operators to ensure a fully barrier-free path of travel to the public lobby.

Post by guest writer Max Yuristy.
All photos courtesy of ERA Architects.

A hospital with heart that embraces its patients celebrates its grand reopening

Dignitaries from the city and province flocked to the grounds surrounding Casey House on a beautiful autumn morning to celebrate the reopening of Canada’s only stand-alone hospital dedicated to those living with HIV/AIDS.

Founded by a group of volunteers in 1988, Casey House was Canada’s first stand-alone treatment facility for people with HIV/AIDS, and the first freestanding hospice in Ontario. At that time, many people were dying alone, cut off from the support of family and friends because of stigma and misplaced fear. The founders’ wise response was to create a home environment in which people with HIV/AIDS could be cared for with dignity and compassion. They created new approaches to palliative care, and played a leading role in both end-of-life care and HIV/AIDS care.

Fast forward almost 30 years, Casey House has been conserved and updated as a warm and welcoming environment; a brand-new state-of-the-art AIDS/HIV healthcare facility that integrates the historic house with a new four-storey extension designed by Hariri Pontarini Architects. The 58,000 ft² addition and restoration of the heritage building commenced in Spring 2015.

As heritage architects, ERA prepared a Master Plan for the property and oversaw the rehabilitation of all exterior and interior heritage fabric. The conservation strategy was to retain and conserve the fabric, replacing deteriorated elements where necessary.

The design of the contemporary facility juxtaposed against the Victorian mansion is distinct but complementary; respecting the existing materiality, preserving its qualities and organizing the day-to-day user experience. Throughout the project, the architects considered how to manifest unifying themes from the AIDS movement such as ‘embrace’ and ‘quilt’ by working the design concept from the inside out.

At its heart, the redevelopment of Casey House was a community-inspired and driven initiative, with stakeholders recognizing the importance of their generous contributions.

Link to Globe and mail article: https://beta.theglobeandmail.com/life/home-and-garden/architecture/torontos-new-casey-house-building-shows-the-medicinal-power-of-light-beauty-anddignity/article36767563/?ref=http://www.theglobeandmail.com&

Photos by ERA Architects

The Lost Craft of Tuck Pointing

Pointing, repointing, tuck pointing, ribbon pointing, flush pointing, there are many techniques and they are all different. Tuck pointing is a style of jointing that was predominantly used on English brickwork from the late seventeen century and it continued in popular use through the early 20th century. Done properly, it is the most highly skilled of all pointing finishes and gives the illusion of finely pointed gauged brickwork on principal facades. It helped give the impression of quality to buildings constructed of damaged or irregular bricks. When laid in the normal manner of the day, such bricks produced walls with wide joints of irregular and uneven pattern which appear the sum of their constituent parts rather than as a coherent surface or plane. In the late 17th century the problem was avoided by using soft, rubbed bricks which could then be laid with thin, straight joints, however such work was costly. Tuck pointing was a less expensive alternative which seems to have been particularly popular for use on terraced housing up to the late 19th century. One of the most famous terraced houses in the British empire was tuck pointed: 10 Downing Street. While the technique is no longer in prominent use, knowledge of it is needed to repair those buildings which remain.

The effect is achieved by filling joints with a base mortar which has been coloured to match the surrounding brickwork. Where necessary, it covers the rounded or damaged brick edges in order to finish flush with the wall face. Over this is a narrow ribbon of fine, vernally white or cream coloured pointing material of well-sifted lime mixed with fine silica sand. This is skillfully applied or ‘tucked’ onto the regular grooved centres of the prepared joints and precisely trimmed to size.

Walking through neighbourhoods such as Cabbagetown, lower Rosedale and Parkdale, you still see the remnants of original tuck pointing on old brick buildings. This was a prominent aesthetic element throughout the city. However, it can be difficult to determine whether an historic building had been tuck pointed originally, mainly because of the sand blasting practice in recent decades.The abrasion of the sand on the surface removes paint and staining, but also often erodes the surface of the brick, mortar, and adjacent materials, including the tuck pointing ribbon if present, effectively removing any evidence of the brick building being tuck pointed.

Such a specimen can be seen at 62-64 Charles Street, where recent conservation work has restored the tuck pointed building to its former glory, under the expert hand of Hunt Heritage. This is the largest application of the process that ERA has been involved with and it’s an exemplar for bringing this lost craft back to the city.

ERA Principal Scott Weir Walks Designer Tommy Smythe Through a Few Current Conservation Projects

Scott Weir was invited to tour designer Tommy Smythe of The Marilyn Denis Show through some of ERA’s current conservation projects.

The first project shown is the conservation of houses at 62-64 Charles St (project team: Andrew Pruss, Daniel Lewis and Julie Tyndorf) which is being undertaken in collaboration with aA, for Cresford Developments. Hunt Heritage is the heritage contractor.

The second is the moving and repair of 76 Howard as part of the long-term heritage conservation of a neighbourhood bounded by Sherbourne, Howard, Parliament and Bloor (project team: Daniel Lewis, Jeff Hayes, Nicky Bruun-Meyer, Gill Haley and Scott Weir) with aA for Lanterra Developments. Hunt Heritage is the heritage contractor. Video of the building move by David Dworkind.

Link to related blog post:  http://www.eraarch.ca/2016/76-howard-streets-moving-day/

The third project is the adaptive reuse and incorporation of a Jarvis Street mansion into Casey House (project team: Luke Denison, Mikael Sydor, Sanford Riley, Jessie Grebenc, Michael McClelland, Edwin Rowse and Scott Weir) for Casey House Toronto, with Hariri Pontarini Architects Clifford Masonry Ltd is the heritage contractor.

Thanks to the Marillyn Dennis show, and Tommy Smythe and his team for profiling heritage work happening in the city!

Link to segment: http://www.marilyn.ca/…/s…/Daily/May2017/05_04_2017/Segment3

These projects will be featured in greater depth on the ERA portfolio page of the website in the weeks to come.

ERA Learns the Fine Art of Tuckpointing from a Melbourne-based Master

On March 15th 20 staff from ERA and members of the Architecture Conservancy of Ontario’s Next Gen group joined Antoni Pijaca, a heritage mason with over 30 years of award-winning tuckpointing experience for a workshop focusing on techniques and skills of the trade. English Tuckpointing is a brick-laying method used on homes, churches, schools and institutions. Materials required included lime mortar, lime putty, a straightedge, tuck irons and frenchman (ribbon knives).

This technique was popular in Toronto’s late 1800’s architecture as a cosmetic solution that imitated the gauged brickwork found in England during the same period. It was an efficient and effective means of capturing the same appearance, but requiring less work and precision.

After the introduction, staff participated in a ‘hands on’ session, demonstrating their new found knowledge.

ERA wishes to thank Hunt Heritage for providing this unique learning opportunity.

Toronto House Transformation

Streetscape 2

Throughout most of the dynamic city of Toronto, structures originally built as houses have been transformed for innovative use. These transformed houses often create spaces for businesses, organizations, and various other establishments; such alterations often generate some of the busiest streetscapes in Toronto. Continue reading…

Gemini House exceeds expectations

turret

Recent data shows that Gemini House, a green retrofit of an 1880s Second-Empire home, is a real success, with energy savings up to 72% reduced from current Ontario standards. For this project, ERA collaborated with University of Toronto and Ryerson University to transform a poorly performing heritage home into a model for sustainable design. The project challenges a common misconception that heritage architecture and sustainable design do not mix.­ Continue reading…

Heritage Masonry with Dr. Gerard Lynch, May 13 to 22

Masons, heritage professionals, architects, historians, and all interested parties: We invite you to join us for a new installment of Dr. Gerard Lynch’s extraordinary courses in brickwork, May 13 to 22 at Evergreen Brickworks, Toronto.

Learn from scholar and master mason Gerard Lynch about traditional limes and mortars, traditional binders, historical forms of pointing and jointing, causes of failure in brickwork, and all manner of detail in the mason’s art.

Update: We will also be joined May 20 to 22 by master mason Terry Mullarkey of J. Mullarkey & Sons Stonemasons, one of the top marble and stone masonry restoration companies in the world.

Continue reading…

Ghost wall: casting a heritage façade in concrete

Holt Renfrew 1912 web

As part of the development of the Bay Adelaide Centre East Tower, ERA is working with KPMB, Adamson Associates, and Brookfield Properties to conserve and refurbish two facades of an impressive four-storey masonry building constructed in 1850 and heavily renovated in 1910. Part of the interpretation of the history of this site involves making moulds from the heritage masonry and recasting these in concrete to construct additional sections of façade. Continue reading…

The Red Mason

Recently, as part of ERA’s ongoing interest in preserving and applying traditional building crafts, we were happy to be involved in heritage masonry workshops led by Dr. Gerard Lynch. Dr. Lynch is an internationally acclaimed historic brickwork consultant, master bricklayer, educator, and author.  He is considered the world’s leading authority of gauged brickwork, and affectionately known by the historic term “The Red Mason.” Continue reading…

Conference in Charleston

Recently Andrew Pruss and Jan Kubanek traveled to Charleston, South Carolina to attend the Association for Preservation Technology International Conference, 2012.

Jan Kubanek presented on Sharon Temple, a fascinating project ERA has had the opportunity to work on for several years. Jan’s presentation focused on the importance of working collaboratively with an interdisciplinary team. In this project, ERA was able to make the best use of our multi-disciplinary team’s combined expertise in traditional construction carpentry and wood conservation. The team included a structural engineer specializing in heritage preservation and a carpenter with extensive experience at the Temple site. Continue reading…

Polychrome brickwork

Following up with more masonry-related topics in honour of an upcoming visit by our friend Gerard Lynch, today’s post is on a distinctive masonry tradition used internationally: polychrome brickwork, the use of usually two, but sometimes three, colours of brick, generally red with buff accents (but the opposite in the image above). Continue reading…

Heritage Masonry with Gerard Lynch

Oct. 23 to 31 – various one- and two-day courses.

Masons, heritage professionals, architects, historians, and all interested parties are invited to join us for a series of very special courses in brickwork. Learn from scholar and master mason Gerard Lynch about traditional limes and mortars, traditional binders, historical forms of pointing and jointing, causes of failure in brickwork, and all manner of rich detail in the mason’s art.

Continue reading…

Tuckpointing: a note on detail

This month we are posting on a few masonry-related topics in honour of an upcoming visit by our friend Gerard Lynch, who is leading heritage masonry workshops at Evergreen Brickworks, from October 23 to 31. Today’s post is on an ingenious but little-known art called tuckpointing. The term tuckpointing is often used today as a synonym for repointing, the replacement of old mortar in brickwork. But historically, this term in fact refers to a less common subtlety of the mason’s practice. Continue reading…

Heritage masonry courses with Gerard Lynch

Oct. 23 to 31 – various one- and two-day courses.

Masons, heritage professionals, architects, historians, and all interested parties are invited to join us for a series of very special courses in brickwork. Learn from scholar and master mason Gerard Lynch about traditional limes and mortars, traditional binders, historical forms of pointing and jointing, causes of failure in brickwork, and all manner of rich detail in the mason’s art. Continue reading…

Amendments to Heritage Policies in Toronto’s Official Plan

The City of Toronto has just brought forward draft Official Plan Amendment No. 199 regarding Public Realm and Heritage policies. In May of this year, a staff report recommending the adoption of revised heritage policies was brought forward, and a public open house was scheduled. Prior to the public open house on September 10th, ERA submitted comments to the City outlining our concerns. We are pleased to report that some of our comments have been incorporated into the newly drafted OPA No. 199, but find that some areas could benefit from further revision. Continue reading…