September 21, 2018
Author: Wade B. Gochnour, Esq.
Organization: Howard & Howard
Introduction to the A201
The AIA A201-2007 General Conditions of the Contract for Construction is one of the most common documents in the construction industry. The A201 establishes the most of the general terms between the Architect, the Owner, the Contractor, and in many cases, the subcontractors. The A201 is generally used in connection with one of the other AIA contract forms, and together establish the terms of the contract.
The AIA first established the Uniform Contract in 1888. The first set of Standard Documents of the AIA (1911) was published in 1911, and the current 2007 edition of the AIA A201 is the sixteenth edition of the general conditions. So, one of the appeals of using the A201 is the long history of the documents and the substantial amount of legal decisions interpreting and refining the meaning of the general conditions.
Most of the project specific details should be established in the contract form chosen for the specific project. This will generally include the price, the time for completing the work, the insurance limits. The A201 will support the terms of the contract form to establish the details of when and how payment is made, the types of insurance that will be required for the project, and will provide a process for dealing with the project during the course of construction. The A201 sets out several standard terms on many issues, but these terms may be negotiated to fit the needs of any particular party or project.
The A201-2007 is broken out into fifteen separate articles as follows:
1 General Provisions
2 Owner
3 Contractor
4 Architect
5 Subcontractors
6 Construction By Owner or By Separate Contractors
7 Changes In the Work
8 Time
9 Payments and Completion
10 Protection of Persons and Property
11 Insurance and Bonds
12 Uncovering and Correction of Work
13 Miscellaneous Provisions
14 Termination or Suspension of the Contract
15 Claims and Disputes
The Article 1, General Provisions spells outs some of the basic definitions that will be used throughout the A201, and the related contract documents. The Contract Documents do not simply include the AIA contract form and the A201. The Contract Documents also include any supplementary or other conditions, the Drawings, the Specifications, Addenda and any modifications issued after the execution of the chosen contract form1. The General Provisions also provides some general discussion of the intent of the documents and the basic interpretations guidelines.
One thing to note about the General Provisions is the inclusion of a merger clause in §1.1.2. A merger clause provides that all of the negotiations between the parties to a contract are merged into the written contract, and that any prior negotiations, representations or agreements, whether in writing or made orally, will not be part of the agreement between the parties unless those terms are included in the written contract. So, to the extent that promises or representations are made during the negotiation process, they must be included in the final contract terms, or they will be of no effect.
Another key definition in §1.1.3 is “The Work.” The term “The Work” is used repeatedly in all of the AIA documents. Put simply, the Work is the all of the labor, materials and services to complete the construction project set out in the Contract.
Ownership of the Design Documents
Even though the Owner hires the Architect to prepare the design for the Owner’s use in constructing a project, the architect retains ownership and control over the design documents based on copyright law. This ownership is reinforced in the terms of the A201 §1.5, noting that the Architect and its consultants retain all common law, statutory and other reserved rights, including copyrights. Therefore, to the extent that an Owner wishes to obtain the ownership and use of the design documents, this issue must be negotiated up front.
The Architectural Works Copyright Protection Act provides that architectural works created on or after December 1, 1990, are subject to copyright protection. The law defines an architectural work as \"the design of a building as embodied in any tangible medium of expression,\" including any permanent, habitable structures from large office buildings to small structures such as patios. In contrast, projects such as civil works, mobile homes, or recreational vehicles would not eligible for copyright protection under the Act.
The copyright of an architectural work is generally owned by the author of the work, which could include the architect and any other professional that contribute to the work. The Owner will generally only acquire the Architect’s copyright by negotiating a transfer in writing from the copyright holder.
Consistent with other provisions under copyright law, copyright protection for architecture is limited to original works. Essential elements for a functioning building for are not protected by copyright. This would include such items as common space utilization plans, and standard features such as doors, windows and other common building components. The owner of the copyright-protected design documents is entitled to control when and who is allowed to makes copies of the design documents, and the purposes for which they will be used. Therefore, the Architect could control how many copies of the design documents will be made, and to whom they will be given. For this reason, A201 §1.5.2 grants the Contractor and the lower tier subcontractors and suppliers rights use and reproduce the design documents for the named construction project. This right does not extend to the use of the documents beyond the contemplated project. So, if the Owner wanted to use the same plans to build another project, the Owner would have to obtain permission from the Architect, or be subject to the legal consequences of infringing on the Architect’s right under copyright law. Not only does the Architect retain the ownership of the original design, it also retains the exclusive right to prepare derivative works based on the copyrighted work, and to perform or display the work publicly. A derivative work might include a photograph, painting, or other representation of either the design drawings or the building itself.
Recognizing that application of these rights to architectural works could cause harsh results, the Act does include limitations on the copyright relating to architectural works. The copyright in an architectural work that has been constructed does not prevent taking, distributing, or publicly displaying pictures, paintings, or photographs of the work , as long as the building is located in or ordinarily visible from a public place. Another key exception is that a building owner may make alterations to, or destroy a building without the copyright owner's consent. As a result of the general applications of copyright to the design, there are several key issues that should be considered during the initial retention of the design professionals. One item is to address who is actually designing each portion of the project. It is not uncommon for the Architect to specify the appearance and performance criteria for certain portions of the project, which are then actually designed by engineers working for the Contractor or Subcontractors. The ownership of each phase of the design should be spelled out in the documents. This issue should also been considering when looking at A201 §3.12.10. §3.12.10 provides that the Contractor is not required to provide design services unless the services are specifically required by the Contract Documents, or unless the contractor “needs to provide such services in order to carry out its responsibilities with respect to construction means, methods, techniques, sequences and procedures.” If design services are provided by the Contractor, The design services should be provided by a licensed design professional. Additionally, §3.12.10 does not address whether the Contractor, or any subcontractors are required to carry errors and omissions insurance.
The Contract Documents
§1.1.1 defines the Contract Documents. It includes the chosen Agreement form between the Owner and Contractor; the Conditions, including the General Conditions, supplementary or other conditions; the Drawings; the Specifications; any Addenda issued before execution of the Contract; as well as any Modifications (Change Orders) issued after execution of the Contract. §1.1.1 also excludes certain items from the Contract Documents. These include any invitations to bid, bidder instructions, sample forms, and the bids and proposals received.
Identification of all documents to be included in the Contract Documents is important so that the parties each know which documents and materials describe the project and set out the obligations of each party. §1.1.1 includes many of the documents necessary for the construction of the project. However, §1.1.1 does not include designs prepared by or on behalf of the Contractor, such as shop drawings. Owners and Contractors should make sure that the A201 sets forth all of the documents and materials that should be included as part of the Contract Documents upon which their performance will be based, whether existing now or created later.
One key issue to define is the priority of the various documents. It is not uncommon to find inconsistencies between the Contract Documents. This issue is partly addressed by §1.2.1, which states that the intent of the Contract Documents is to e complementary, so that any item required by one document will be required by all of the documents. Defining the order of precedence will help to avoid unnecessary delays and disagreements.
Flow Down Provisions
Flow down provisions, which are also called pass-through or conduit clauses, are a common feature in construction contracts, and are included in the A201 at §5.3. Pursuant to §5.3, the Contractor must include provisions in its subcontracts that require the subcontractors, and their subcontractors, “to be bound to the Contractor by the terms of the Contract Documents, and to assume toward the Contractor all the obligations and responsibilities . . . which the Contractor, . . ., assumes toward the Owner and Architect.” The purpose of flow down provisions is to try to ensure that the subcontractor's obligations under their subcontract mirror the Contractor's obligations to the Owner. This helps reduce the risk of potentially differing obligations on the part of the Contractor.
The difficulty in enforcement of flow down provisions is often how they actually are applied to the lower tier parties. The first thing to notice is that a flow down provisions creates a similar set of obligations between the Contractor and the subcontractors, as those between the Owner and the Contractor. However, the flow down provision does not create any right on the part of the Owner to directly deal with or control the work of the subcontractors. Likewise, the flow down provision does not create any third party beneficiary rights on the part of the subcontractors against the Owner. The contractual obligations are still between the Owner- General Contractor, and the General Contractor-Subcontractor. There can also be practical issues in trying to determine which contractual obligations will actually flow down. If a court finds that the flow down provision is ambiguous in relation to the obligation the Owner or General Contractor is seeking to enforce against the subcontractor, the Court is likely to follow traditional contract interpretation principles and look to evidence of the parties' intent to determine which obligations flow down.
The effect of an order of preference clause should also be considered when looking at a flow down provision. An order of preference provision should help clarify the documents that will govern any inconsistencies.
Submittals
The submission of shop drawings, manufacturer date sheets and samples is an important part of the construction process that is often given insufficient attention in construction contracts. There is a tension between the Owner, Architect and the Contractor in how submittals are handled, and the reliance that can be placed upon them. Architects typically do not want to add additional responsibility for means and methods that are part of the Contractor’s responsibility.
Owner’s would like to have the party responsible for the design make determinations of how the submittals comply with the Architect’s design intent, and to ensure they are getting the project that meets their needs. Contractors are interested in trying to ensure that the work they undertake is consistent with the plans and specifications, and to get as much direction as possible, thereby reducing their risk. This entire process must also be viewed in light of the project schedule. If timely submissions are not made by the Contractor, the review cannot be completed in a timely fashion, and this may cause delays that will be the responsibility of the Contractor. On the other hand, if the Architect or Owner does not timely review and respond to the Contractor’s submittals, the Contractor’s work may be delayed resulting in additional costs to the Owner. The A201 addresses some of these issues, while more specificity may be set out in other AIA agreements between the parties.
The primary portion of the A201 dealing with submittals is Article 3.12. §3.12.4 specifies that “Shop Drawings, Product Date, Samples and similar submittals are not Contract Documents.” The submittals are to show how the Contractor proposes to actually construct portions of the design. This has important ramifications. Since the submittals are not Contract Documents, the submittals cannot vary the terms of the Contract Documents, including the Plans and Specifications. §3.12.8 specifically provides that the Contractor is not relieved of its responsibility to perform according to the Contract Documents, even if the submittal is approved by the Architect, unless the deviation was a minor change, or unless there was a change order authorizing the deviation.
The initial burden is on the Contractor. The Contractor is to review the Contract Documents and provide the Submittals to the Architect in accordance with the submittal schedule approved by the Architect or, if there is no schedule, “with reasonable promptness” to avoid delays. The Contractor is also making a representation to the Owner and Architect that its submittals have been reviewed, that all field measurements have been determined, and that the submittal is consistent with the Contract Documents2. Once the Contractor has made the submittal, A201, §3.12.7 requires the Contractor to wait for approval before beginning any work associated with the submittal.
The Architect’s role in the submittal process is set out in A201, §4.2.7. The Architect will review the Contractor’s submittals in accordance with the Architect approved submittal schedule, or with reasonable promptness. In what should not be a surprise to anyone, §4.2.7 also 2 A201, §3.12.6. limits the duties of the Architect. The Architect’s review obligations are limited to “checking for conformance with information given and the design concepts expressed in the Contract Documents.” §4.2.7 also provides that the Architect’s review is not conducted to determine the accuracy, details, quantities, or to provide approval of installation or performance, all of which are the Contractor’s responsibility. Even with respect to the timeliness of the Architect’s review the reasonable promptness is limited to allow additional time if it is necessary “in the Architect’s professional judgment to permit adequate review.”
In the A201, the Owner’s role is really anticipated to occur through the Architect. However, the Owner still has responsibility to ensure that information necessary to the Contractor is provided. In A201, §2.2.4, the Owner is required to provide “information or services required of the Owner by the Contract Documents with reasonable promptness.” The Owner is also required to provide information under the Owner’s control, which would necessarily include the Architect’s services.
When negotiating an A201, the parties should attempt to further define an appropriate deadline for the submittal schedule. The “reasonable promptness” language in the A201 is vague and open to differing interpretations, and should be refined where possible.
The Architect’s Review of Claims/Claims Procedures
One provision that is unique to the A201 is the role of the Architect in determining disputes between the Owner and the Contractor. In §15.2, unless specifically stated otherwise, the Architect will initially decide disputes between the Owner and Contractor. This can be problematic for several reasons. The Architect will potentially be making determinations of disputes, even if the subject of the dispute is the architect’s own performance. §4.2.1 provides that the Architect “will be an Owner’s representative during construction.” §4.2.8 provides that the Architect “will prepare Change Order and Construction Change Directives, and may authorize minor changes in the Work,” and “will investigate and make determinations and recommendations regarding concealed and unknown conditions.” Therefore, the Architect will likely be deciding disputes that the Architect had a role in creating the dispute. Further, the Architect agrees to act in this role, there could be perceived pressure to make decisions in favor of the Owner who is paying the Architect.
Other problems arise from Article 15. After the Architect issues a decision, and as long as that decision does not relate to aesthetic effect, the parties must mediate, and then arbitrate or litigate. However, there is no requirement that either party allow the inclusion of the subcontractors in the determination by the Architect. It is often the subcontractors who are the real party interested in a particular claim. This is compounded by the flow down provision of §5.3.
All parties should consider whether, and to what extent they desire to allow the Architect to act in the role of Initial Decision Maker. The parties should also consider further defining the standard dispute resolution provisions of the A201.
Waiver of Consequential Damages
In 1997, the AIA inserted one of the more controversial of its provisions into the A201. §15.1.6 provides that the Owner and Contractor waive all claims against each other for consequential damages arising out of or relating to the contract. Often time this provision is arguably more beneficial to the Contractor for a number of reasons, but may be considered a necessary elimination of unknown and substantial risks to the Contractor.
Consequential damages are “losses or injuries which are a result of an act but are not direct and immediate.”3 These damages can include the Owner’s lost profits, loss of use, additional financing costs, and other losses that arise because the contract was not completed in accordance with the Contract Documents. Often times Contractors will seek to limit consequential damages, because the consequential damages are hard to anticipate, and may easily become more than the amount of the contract. These items represent a large, and hard to quantify risk to the Contractor. From the Contractor’s side, consequential damages could include the loss of other contracts, additional non-project expenses, loss of reputation and related claims. For instance, if the Contractor obtained another project but was unable to perform due to a breach by the Owner, the Owner could be liable for any lost profits or other damages resulting to the Contractor from the Owner’s breach.
Part of the justification for the waiver of consequential damages is to allow the parties to quantify their risk. Further, the waiver of consequential damages, and therefore limiting the parties to only direct damages, is seen as a tool to reduce the incentive of the parties to escalate their claims. The hope is that this will help lead to resolution of claims, rather than encouraging protracted disputes.
Both the Owner and Contractor should consider whether modification §15.1.6 is necessary. If there are specific concerns as to potential costs to either party from a breach, then these issues can be specifically identified and addressed, rather than just waiving, or leaving open, the potential for consequential damages. For example, the parties could agree to liquidated damages for any delay in completing the project. Finally, the parties should discuss and determine if there is a possibility of obtaining insurance for any of the potential damage items.
Indemnity/Insurance
Article 11 of the A201 sets out the standard provisions for the insurance coverages for the project. The details of the coverage should be covered in the Agreement form chosen for use by the parties. §11.1.1 sets out the types of risks that the Contractor’s insurance must cover, without specifying a particular policy or form. When looking at the Insurance requirements, the Owner should consider requiring that the Contractor obtain insurance from carriers that meet a designated rating from a recognized source, such as A.M. Best. The Owner should also consider requiring a specific policy form to ensure that the desired coverages and limits are provided. From the Contractor’s perspective, the A201 §11.3.1 requires the Owner to obtain a builders risk policy to insure the project against damages during construction. As with the Contractor’s insurance, the Contractor may wish to specify a particular rating for the carrier, or particular policy provisions. If the Owner does not obtain a property insurance policy, §11.3.1.2 allows the Contractor to obtain the policy, and seek payment for that policy from the Owner by an appropriate change order.
§11.1.4 requires the Contractor to include the “Owner, the Architect and the Architect’s consultants as additional insureds” during the operations, and also covering the Owner for completed operations.
A201, §11.3.7 also requires that the Owner’s and Contractor’s policies include a waiver of subrogation. The purpose of the waiver of subrogation is to keep the insurer from seeking recovery for any claims paid from the other project participant. This allows the parties some security in knowing that if the matter is covered by the policy, the insurance will resolve the risk to the amount of the policy.
All of these are standard requirements for construction contracts. The Owner should take care to ensure that the required limits are large enough to cover anticipated risks. The Contractor will need to ensure that it is able to obtain the required policies for the limits required. One of the most important provisions in any construction contract is the indemnity provisions. §3.18 requires the Contractor to indemnify and hold harmless the “Owner, Architect, Architect’s consultants, and agent and employees of any of them,” but only to the extent that the claim is caused by the negligence of the Contractor, or someone for whom the Contractor is liable. §3.18 goes on to state that the indemnification duty exists “regardless of whether or not such claim, damage, loss or expense is caused in party by a party indemnified hereunder.” There is no reciprocal indemnity from the Owner to the Contractor.
There are also additional indemnity obligations relating specifically to hazardous materials in §10.3.3, §10.3.5, and §10.3.6. Unlike the general indemnity contained in §3.18, §10.3.3 does provide for the Owner’s indemnification of the Contractor (and the Architect and the Architect’s consultants) from losses resulting from working in areas of hazardous materials that were not brought to the site by the Contractor.
In considering indemnity clauses, Owners, and higher tier Contractors, will often attempt to require the Contractor to provide indemnification and defense of any claims even if the Owner is partly responsible for the claim. Often these are presented as requiring defense and indemnity except in situations where the Owner’s sole negligence is the cause of the claim. While several states have enacted anti-indemnity statutes that would limit the Owner’s ability to seek these types of provisions, Nevada does not currently have such a statute. However, the Nevada Supreme Court has set strict requirements on these types of indemnity provisions.
In 2010, the Nevada Supreme Court held “[A] contract of indemnity will not be construed to indemnify a party against loss or damage resulting from its own negligent acts unless such intention is expressed in clear and unequivocal terms.”4 The Nevada Supreme Court went on to hold “a general provision indemnifying the indemnitee ‘against any and all claims,’ standing alone, is not sufficient.”5
So, while it is possible to require one party to indemnify the other party, even as to the negligence of the party seeking indemnification, that intent must be specifically stated in the indemnity agreement.
Payment Provisions
The payment provisions of the A201are set out in Article 9, and are primarily geared for the payments of a lump sum contract. To the extent the Work is being preformed on some form
of cost of the work plus a fee, modifications will be appropriate.
The A201 payment provisions follow a fairly standard construction industry method. An initial schedule of values for the entire Work is to be established.6 At least ten days before any scheduled progress payment date, the Contractor will prepare an Application for Payment for all work expected to be completed by the progress payment date.7 The Application for Payment will show the work that has been completed during the period, and may include material delivered to the site, and any applicable portion of any approved change order work.8 The Application for Payment is to be submitted to the Architect for review.9
Once the Architect has received the Application for Payment, the Architect is given seven days to either issue a Certificate for Payment to the Owner, or to provide the Contractor and Owner a written explanation of why the Architect believes some or all of the Application should be withheld.10 If a Certificate for Payment is issued, the Owner is to pay the Contract within the time set out in the contract.11 Once paid, the Contract is to pay it subcontractors within even days in proportion to the work for which the Contractor has been paid.12
The Architect may determine to withhold some or all of the Application in order to protect the Owner for specific failures by the Contractor, including defective work, Contractor’s failure to pay subcontractors or suppliers, or if there is “reasonable evidence” that the Work cannot be completed on schedule, or for the remaining contract balance.13 If the basis for the withholding are removed, then the Architect is to issue a Certificate for Payment for the withheld funds.14
Once the project reaches the point that the Owner can occupy or use the project for its intended use, the Architect will review the Work, work with the Contractor to prepare a list of items that can be completed prior to final payment.15 Once that is done, the Architect is to issue a Certificate of Substantial Completion.16 Upon issuance of the Certificate of Substantial Completing, the Owner is to make payment of the retention covering the work performed to date.17
Finally, once the Work is fully complete, the Architect is to review the Work, and issue a final Certificate for Payment.18 The final Certificate for Payment requires the Owner to make any remaining payment due to the Contractor.19 The making of final payment by the Owner, and acceptance by the Contractor, includes a waiver by the Owner and Contractor, respectively.20 The exceptions is that the Owner does not waive any claims for liens or other unsettled encumbrances that are the Contractor’s responsibility, the failure of the work to meet the plans and specifications, and the Owner does not waive any warranties.21
When entering into a contract including the A201, the Owner must consider whether it truly wants to give the Architect the responsibility to determine when payment is due. Most Owners will want to take the responsibility for review and approval of the Contractor’s payment applications, and if so, these terms must be modified. Also, there could be loan covenants that require some other form of review before payment is made.
The contractual payment provisions must also take into account the Prompt Payment provisions of NRS Chapter 624. For example, NRS 624.609(2)(a)(2)(II) only allows the withholding “to the extent that such costs and expenses exceed 50 percent of the retention amount withheld pursuant to subparagraph (1).” Further, NRS 624.610 requires the Owner to respond to change order requests from the Contractor within 30 days, or the Contractor will be allowed to bill and be paid for the change order.
Termination
Article 14 of A201 addresses termination and suspension of the Contract. Article 14 allows for termination by both the Contractor and the Owner, but on differing bases. This is yet another area where there may be some overlap with Nevada law, and a Contractor’s right to stop work and terminate the contract under the prompt pay provisions of NRS Chapter 624.
A201, §14.1 sets out the conditions for termination by the Contractor. The Contractor may terminate if the work has been stopped for 30 consecutive days because of: a government order or emergency; the failure to issue a Certificate of Payment or the failure to make payment; or the Owner fails to provide reasonable evidence of the ability to pay for the Work.22 In order to terminate the contract, the Contractor must provide seven days written notice before terminating the contract.23 If the Contractor terminates the contract in accordance with Article 13.1, the Contractor is entitled to recover payment for the Work performed, including a reasonable overhead and profit, and costs for the termination.24
Like the Contractor, the Owner may terminate the contract for cause.25 Cause includes the Contractor’s failure to supply enough workers or materials; failure to make payments to subcontractors; the Contractor’s disregard for laws or codes; or if the Contractor is in “substantial breach” of the contract.26 The Owner must provide at least seven days written notice before terminating the contract.27 Upon termination for cause, the Owner is not required to make any further payments to the Contractor until the project is complete.28 After the work is completed, if the amount spent by the Owner is less than the contract amount, the Owner must still pay the remaining amounts to the Contractor.29 If the amount spent exceeds the contract amount, the Owner is entitled to recover that amount from the Contractor.30
In addition to cause, the Owner may terminate for its own convenience.31 The Owner must pay for the work performed to the termination, and a reasonable profit and overhead for the work not completed.32
Mechanic’s Liens
The A201 does not address the interplay between the AIA contracts and state mechanic’s lien law in any real sense. However, several issues should be considered when negotiating the contract.
Between the A201 and Nevada’s mechanic’s lien law, the Owner and Contractor may be required to exchange initial information relating to mechanic’s lien. A201, §2.1.2 requires the Owner to provide the Contractor the information necessary to allow the Contractor to evaluate and enforce mechanic’s lien rights, upon written request from the Contractor. Under NRS 108.246, the Contractor is required to provide a notice to the Owner of the lien release provisions of NRS 108.245.
The A201 General Conditions set out many conditions that will affect the timing and amount of potential mechanic’s liens. For example, A201, §9.8, §9.9 and §9.10 define Substantial Completion, Partial Occupancy and Final Completion, respectively. These may help define when mechanic’s lien rights may run. NRS 108.226 allows contractors to record liens against the Owner’s property within 90 days of the Completion of the Work of Improvement, the last delivery of materials, or the last work performed, whichever is later. NRS 108.22116 defines “Completion of the work of improvement” as:
1. The occupation or use by the owner, an agent of the owner or a representative of the owner of the work of improvement, accompanied by the cessation of all work on the work of improvement;
2. The acceptance by the owner, an agent of the owner or a representative of the owner of the work of improvement, accompanied by the cessation of all work on the work of improvement; or
3. The cessation of all work on a work of improvement for 30 consecutive days, provided a notice of completion is timely recorded and served and the work is not resumed under the same contract.
A201, §9.10 sets out when the Contractor is deemed to have reached final completion. By withholding a determination of final completion, the Owner and Architect are likely extending the time in which any of the mechanic’s lien claimants may record a mechanic’s lien.
1 A201, §1.1.1
2 A201, §3.12.6.
3 Black’s Law Dictionary (6th Ed.)
4 George L. Brown Ins. Agency v. Star Ins. Co., 237 Nev.Adv.Op 31, 237 P.3d 92 (2010).
5 Id.
6 A201, §9.2.
7 A201, §9.3.1.
8 A201, §§9.3.1.1, 9.3.1.2 and 9.3.2.
9 A201, §9.3.1.
10 A201, §9.4.1.
11 A201, §9.6.1.
12 A201, §9.6.2.
13 A201, §9.5.1.1 - §9.5.1.7
14 A201, §9.5.2.
15 A201, §9.8.2.
16 A201, §9.8.4.
17 A201, §9.8.5.
18 A201, §9.10.1.
19 Id.
20 A201, §9.10.4 and §9.10.5.
21 A201, §9.10.4.
22 A201, §14.1.1.1 - §14.1.1.4.
23 A201, §14.1.3.
24 Id.
25 A201, §14.2.1.
26 Id.
27 A201, §14.2.2.
28 A201, §14.2.3.
29 A201, §14.2.4.
30 Id.
31 A201, §14.4.
32 A201, §14.4.3.