Council Weighs in on the Housing Issue at the Innovation Parks


Community Development Director Mike Webb on Tuesday night explained to the Davis City Council that right now, all three innovation park proposals – Mace, Northwest, and Nishi — are on schedule to be placed on the ballot in March 2016.

Obviously, the council, as well as City Manager Dirk Brazil, has some concerns about the viability of three proposals simultaneously, and the discussions on potential bifurcation and determining who would go first, second and third will need to take place sooner rather than later.

“I do agree that we need to start thinking strategy,” Councilmember Rochelle Swanson noted later in the meeting. “I do get concerned when we talk at the 30 thousand feet that we’re suddenly going to have folks in the community say ‘oh my goodness we’re going to have 10 million square feet on the ballot all in the same month.’”

“I know that’s what the applicants are looking for,” she said. “But I do think we need to start having that conversation.”

Much of the evening was informational, but there was important discussion about the mixed use component that was presented in one project alternative. As Mike Webb explained, “Our recommendation to include that as an EIR alternative stems from that community feedback and there being a clear interest in seeing what that looks like from a CEQA perspective.”

The housing would not necessarily be restricted to those working in the park. Currently the city is modeling for job generation at the two centers, what types of jobs, where those employees may be coming from and where they would live, so they can calculate assumptions for traffic impacts.

There are a certain number of homes that will be built in Davis as well as in the surrounding communities that would factor into this analysis. “Those additional employees would have to secure housing outside of the area if there weren’t additional homes either built as part of the project or elsewhere,” Heidi Tschudin, the Contract Project Manager told council on Tuesday.

Ms. Tschudin added, “I don’t know that right now we could leap to an assumption as to the relationship between the houses and the businesses. It could be that there is a stronger relationship between the businesses and the homes, depending on where the EIR analysis takes it.” She added, “I think that that piece of it kind of remains to be seen.”

Councilmember Brett Lee noted that CEQA analysis seems to lean towards increased vehicle miles for all projects unless there is literally housing on site to accommodate new employees. “I’m a little concerned that… this notion that (we have) 5000 jobs created and therefore we need to build 3000 units,” he stated. “It’s somewhat alarming because the applicants and what community feedback and council feedback has been… these are not to have residential.”

Mike Webb stated that this was really theoretical at this time. He did note that the correlation between units and employees living there depends on the type of units that are created and whether they are created with that employee in mind. “If there’s high-tech companies, that’s attracting a certain demographic of employee, and that employee is looking for a certain type of housing… there are some studies that indicate that there is relationship there between the type of housing that those employees are looking for,” he explained. “That may strengthen the argument that there may be a bit higher than typical ratio of employees who actually do work and live there.”

Davis Chamber CEO Matt Yancey spoke in support of the staff recommendations. On housing, he noted, “It’s important to note that it’s not included in staff’s guiding principles. It really has only entered the conversation at this stage for the purposes of keeping the city compliant with CEQA law.” He added, “It’s not indicative of a change in direction relative to the innovation parks and what the city would like to see those look like.”

Elaine Roberts Musser spoke on the issue of the housing component. “I agree with Brett’s (Lee) concerns about the housing element. I think he raised some very good questions. My fear is if you start raising this – you gave everyone the impression that there was going to be no housing, now you bring up the issue of housing, this gives a wedge issue for those who are opposed to innovation parks to try and defeat an innovation park. This what we don’t want to see.”

She urged caution in how the issue was handled.

On the other hand, Don Fouts said, “I really think it’s fooling ourselves if we don’t talk about housing concurrently with this. If we’re going to build 5000 jobs, long after Cannery’s 547 houses are built and occupied, the 96 I’m going to build at Chiles Ranch, the 47 at Grande, the 16 a Villas and El Macero, those will long be built and occupied.”

“Where are the people who are going to be working in these 5000 jobs going to find houses?” he asked. He noted he is constantly called by people wanting to find executive housing. “The people who own the business parks want a place to put their head on a pillow at night, we don’t have any of that in Davis.”

He concluded, “I think it’s foolish not to at least parallel track a conversation. I know the fear of Measure R, Measure J or whatever we’re calling it today.”


If everyone who reads this post could pledge just $10 per month, we would meet all financial goals for 2015 and the Vanguard would be fully fiscally viable

Mayor Pro Tem Robb Davis said, “I hear the concerns about housing. It’s really interesting to me that as we just started talking to the community, it came up.” He called it “the third rail” or “the word that cannot be spoken,” “it was when we talked to community members that people said it’s what makes sense.”

He said how do we reconcile our desire to having meaningful jobs but have them not just sprawled out, living everywhere. He said, “The point that I wanted to make is that it came up because of community conversation. It didn’t come up because someone pushed it. It came up because people said, how are we going to manage this.”

Councilmember Lucas Frerichs said, “Housing and/ or the debate about housing in Davis is indeed alive and well. For me, a major reason for my support of the Cannery a year ago, and other infill projects, is because it’s part of a larger strategy of housing and jobs balance that we are certainly looking for in Davis.”

He said in part he supported the Cannery because he knew they would be moving forward on innovation centers. He sees them providing for the likelihood of jobs that would be generated by a potential innovation center.

He talked about VMT (vehicle miles traveled) reduction: “The keys for the whole process of VMT reduction are integrating land use and transportation decisions…, investing in alternatives to solo-driving, increased public transportation…” He noted that there are ways to reduce VMT aside from having workers living where they work.

Councilmember Swanson said that when the housing issue came up, she was concerned and also used the term, “third rail.” “It does cause concern, there were conversations that there weren’t going to be houses on this site,” she said. “But it is hard to reconcile” our desire to reduce vehicle miles and reduction of GHG emissions. “We can’t expect people to jump on a hovercraft from Sacramento to come to Davis” so “we don’t have any emissions.”

At the same time, she reiterated that the council is not talking housing at the innovation parks.

—David M. Greenwald reporting

About The Author

David Greenwald is the founder, editor, and executive director of the Davis Vanguard. He founded the Vanguard in 2006. David Greenwald moved to Davis in 1996 to attend Graduate School at UC Davis in Political Science. He lives in South Davis with his wife Cecilia Escamilla Greenwald and three children.

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  1. Barack Palin

    I think a lot of voters are going to see this as the plan all along.  Get a foot in the door with proposed business parks then push the housing element.  I feel if these projects push housing then the voters will reject it all.

    1. David Greenwald

      I really don’t believe that was true. There is a discussion to be had for sure, but I don’t see a huge push on council to include housing. Brett Lee was skeptical, Rochelle at the end of her comments basically said to make it clear this wasn’t the plan, Lucas talked about alternative ways to reduce VMT’s.

    2. Davis Progressive

      i think you’re right bp.  the question is really who is driving this boat.  there is no way that we can add 5000 without adding housing and remaining true to our ghg, vmt, environmental and transportation goals – there is just no way around that.  why can’t our leadership acknowledge it.

      1. Matt Williams

        DP, Davis is blessed with an Amtrak train station. Can you see workers at the respective Innovation Parks catching the train to work in Davis. I suspect that currently the public transportation vector points out of Davis, not into Davis. For each worker who uses the existing public transportation modes, our ghg, vmt and environmental goals will be unchanged and our transportation goals will actually be improved.

        One of the significant challenges to Davis’ current collective ghg, vmt and environmental impacts is the fact that significant numbers of Davis residents commute to jobs outside Davis. Over time I would expect the employees filling the 5,000 incremental jobs in the Innovation Parks to be in a better competitive position for existing housing resale opportunities than Sacramento job holders are. As a result the number of (for example State Government employees) living in Davis will decline as those employees find that purchasing a house closer to their work achieves a superior personal ghg, vmt and environmental footprint as well as reduced personal cost of living.

        In addition some governmental agencies may choose to locate some of their jobs in the new Innovation Parks in Davis (much like USDA currently has at 5th and G). That will transform the workplace of some current Davis residents to their place of residence.

          1. Matt Williams

            Agreed Frankly; however, Davis has housing issues as a result of the actions of its “neighbor” UCD that neither party (the City or UCD) are really dealing with, so an inclusive, meaningful dialogue about housing is absolutely (in my opinion) needed.

            In Greek mythology, when Achilles was a baby, it was foretold that he would die young. I see a parallel to the fears expressed here in Davis about the possibility of a “young death” for the Innovation Parks. To prevent Achilles death, his mother Thetis took Achilles to the River Styx, which was supposed to offer powers of invulnerability, and dipped his body into the water. But as Thetis held Achilles by the heel, his heel was not washed over by the water of the magical river. Here in Davis, there is no question that Housing is an “unwashed” issue.

            Just as Achilles grew up to be a man of war who survived many great battles, but in the end succumbed to an arrow that in his heel, Davis’ efforts to be a self-sustaining community may succumb to our inability and/or unwillingness to deal with housing.

        1. Alan Miller

          “Can you see workers at the respective Innovation Parks catching the train to work in Davis.”

          That sounds good in theory.  The problem is, you can get in your car and drive to Sacramento or Fairfield before the shuttle has reached the Amtrak station and you wait for and board the train.  That’s with about three viable commute options a half-hour to an hour-and-a-half apart, at significant ticket cost (intercity price levels) and when you get to the other end, you have to transfer to another mode again.

          I am a huge believer in public transit, but let’s be real about why large percentages of workers don’t use it:  lack of convenience.

          1. Don Shor

            I had one employee move to Sac to save rental cost, found a place not far from the train. She found it inconvenient, very time-consuming, and expensive and ended up just driving most of the time. The nominal savings in rent quickly disappeared. Transit to and from Dixon is hopeless, and I don’t think Woodland is much better.

        2. Davis Progressive

          it’s interesting, i know a number of people who like to take the train either from davis to the bay area or to sacramento.  i do so half the time.  i would prefer an extension of light rail to davis, but then again, i’d incur the wrath of alan miller.

    3. TrueBlueDevil

      I brought up the issue, I am not a developer.

      Is Davis’ goal really slated for 5,000 FT jobs at these 3 sites?

      I  was (in past posts) just asking if this was a possibility, there are all kinds of options. Live / work. Or simply apartments and / or condos over the businesses. I wasn’t envisioning single-family homes on the site, I don’t know if others were. There could be no housing on the three sites, or some housing at one site. I have no agenda, it just seemed like an un-addressed issue for month after month as the insiders spoke about “innovation parks” endlessly.

      I think this most recently came to my mind when I visited Santana Row in the South Bay, where there is a fancy shopping district, and fancy apartments above. Many business areas in America go quite at night, but a place like this gets foot traffic from its residents, which is kind of a throwback to old neighborhoods and old European cities. It also can extend the business hours of the local coffee shop, corner store, or Mom-and-Pop eatery.

      More Meat / Real World: Santa Row is a 42-acre mixed-use site billed as a “village within a city”. I know its upscale, I know it’s retail, but it’s somewhere to start with real numbers.

      “Last year alone, this development contributed approximately $24 million in sales tax revenue for the city of San Jose and Federal Realty has paid $40 million in property taxes since purchasing the land in 1997. ”

      1. Michelle Millet

        I really like the idea of residential units above retail/office space. My parents, who are in their 70’s, live  in a 3rd floor loft in downtown Davis, (my husband works in the office space located on the 2nd floor). They love living downtown and being in walking distance of shops and restaurants, both of which they frequent. IMO it’s a great use of space that benefits them, the environment, and the downtown economy, I’d love to see more of it in our downtown.

    4. Matt Williams

      In the end the decision driver for each individual voter will come down to WIFM … What’s In It For Me.

      — Every parent of a DJUSD student who would like to have their child(ren) live and work close to them in Davis will see WIFM value to increasing the supply of high paying, next economy, innovation jobs in Davis.

      — Most current UCD grad students in UCD’s core competency of innovation/research/development programs who would like to continue a close relationship with their current academic program will see direct personal WIFM value to increasing the supply of high paying, next economy, innovation jobs in Davis.

      — Current Davis residents, whose children are currently going to UCD will be one rung up the ladder from the DJUSD parents and will see WIFM value to increasing the supply of high paying, next economy, innovation jobs in Davis.

      — Davis residents like you who don’t want to pay higher taxes and/or see a decrease in the quality of services (quality of life) in Davis will see WIFM value to increasing the supply of high paying, next economy, innovation jobs in Davis.

      Those are just a few of the demographic cohorts who will be weighing the quality of life/value proposition that the Innovation Parks have the potential to deliver. The real question will be whether potential will become reality.

  2. SODA

    But in watching it did seem to take the council somewhat by surprise that it would need to be included.  Was it me, or did Dan have little to say on most all the topics?  Thought he ran a good mtg but said little to contribute to the discussion??

  3. Doby Fleeman

    Interesting conversation.  Maybe we should commend the City’s CEQA consultant to the City of Palo Alto.   How has it been possible for their city of 66,000 residents to support over 90,000 jobs?   It may be too crowded over there for some, but our town of 66,000 supports fewer than 35,000 jobs.   What standards will CEQA employ to determine what is the correct balance?




  4. Frankly

    I think this is a move by some on the CC and city to poison the well for one or more of the innovation parks because they have friends with interests in the other developments.  I think the concern is that more than one of these will end up on the ballot at the same time… and to help ensure the favored one wins, certain CC members along with certain city staff are creating public opposition in a strategy to enable them to kill one or more of the innovation parks that don’t benefit them in some way politically.

    Recently Rob White commented that he will no longer be posting articles and he will be working on other tasks.   This leads me to believe that we are seeing some behind the scenes work to kill certain parks.   My guess is that Nishi is the favored development and the others are being pushed under the bus with this fear of housing tactic.

    Time to put an end to these shenanigans and flush out the back room dealings.

    Vanguard… we need some deeper investigatory reporting on what is going on in the city with respect to economic development since the new CM (the one that was elected with Robb Davis abstaining for some reason) was hired.



    1. Davis Progressive

      interesting thought frankly.  i have heard rumblings that there are changes afoot and not good for the good.  cutting off rob white from communicating to the public is a clear signal of change in the air.  i always assumed that fire was wagging this boat, but perhaps its deeper.

    2. hpierce

      …along with certain city staff are creating public opposition…

      Care to ‘name names’, or is this just supposition on your part?  If the latter, are you trying to give birth to a new ‘conspiracy theory’?

        1. Davis Progressive

          i agree with frankly.  there are people who are opposing these projects not because they are anti-growth, but because they are friends with or on the payroll for one project over others.

    3. Alan Miller

      “This leads me to believe that we are seeing some behind the scenes work to kill certain parks.”

      I thought liberals held the market on paranoid conspiracy theories.

      (Not that they are not all working together to get you.)

  5. Anon

    “I think this is a move by some on the CC and city to poison the well for one or more of the innovation parks because they have friends with interests in the other developments.”

    I very much doubt it.  IMO, city staff is extremely supportive of all the innovation parks, and I very much doubt one is being favored over the other.  From the discussion at City Council last evening, it appeared the issue of workforce housing was voiced by the two commissions involved in the Innovation Park Task Force, Business and Economic Development and Finance and Budget (I think those were the two).  And it sounds like various community members have also voiced their support for workforce housing.

    I think it is perfectly appropriate to be concerned about where the people are going to live, brought here by the jobs the innovation parks would create.  What we have is a clash between the environmental policies of the community/city, and the slow growth policy of the city and preferred by many members of the community.  The fact of the matter is, if innovation parks are brought to Davis, it will create a huge number of new jobs for employees.  If the employees are not housed on site, they will have to create GHG emissions to get to work from outside Davis if Davis does not provide the housing.  That goes against the city’s policies of GHG reduction.  On the other hand the city has a slow growth policy in regard to housing, which discourages building more housing.  The question is how does the city strike the right balance to accommodate these two competing policies? That is the issue in a nutshell.

    I personally am not against workforce housing on the sites of these innovation parks.  I think it is a smart idea.  However, as Elaine Roberts Musser pointed out, “My fear is if you start raising this – you gave everyone the impression that there was going to be no housing, now you bring up the issue of housing, this gives a wedge issue for those who are opposed to innovation parks to try and defeat an innovation park. This [is] what we don’t want to see.”  

    How does the city reconcile the two competing city policies of GHG emission reduction with slow growth/traverse the minefield of Measure R?  It will be a very tricky business, as some City Council members pointed out last night.  There is no “conspiracy” here, but various city policies that are at odds with each other.

    1. Davis Progressive

      “IMO, city staff is extremely supportive of all the innovation parks, and I very much doubt one is being favored over the other.”

      that’s two interesting comments.  so let me ask: is dirk brazil extremely supportive of all the innovation parks?  and remember the comments back in june/ july, the bowing down to dan ramos and schilling robotics, do you really believe that some won’t be more equal than others?  if we have a first and a second, do you have any doubt which will be the first?

      1. Matt Williams

        Why is “first and second” meaningful? If the innovation jobs engine of UC Davis’ research and development programs is producing the high income jobs and innovation-based companies built on UCD’s core academic competencies, then the demand will be there that justifies sufficient applied research (applied development) demand matched to both sites, as well as the incubation ecosystem that Nishi will focus on. The success of the Davis innovation ecosystem really depends on how successful UCD is in achieving its academic research and development goals … which includes the transfer of the products of those academic research and development efforts into the private sector.

        1. Davis Progressive

          “Why is “first and second” meaningful?”

          because no one believes that you can convince the voters to support one project and then another, so everyone wants to be first and are probably willing to kill to be in that position.

    2. Don Shor

      How does the city reconcile the two competing city policies of GHG emission reduction with slow growth/traverse the minefield of Measure R?

      They don’t try to reconcile it. Build the peripheral business parks; skip the housing. This is a side issue that can’t be resolved. If they’re concerned about GHG reduction, the cities can work together to provide transit solutions.

      1. Anon

        Yet you have commissions and some others clamoring for including workforce housing in these innovation parks.  I am assuming what you are saying is to ignore the commissions and persons who think workforce housing should be included in any innovation park proposed?

    3. Doby Fleeman


      Not questioning your recollection, and not sure about the other commissions, but page 8-13 of the staff report states:
      “During the review of the Guiding Principles with the various City Commissions, questions about the inclusion of a residential component were raised by the Bicycling, Transportation, and Street Safety Commission, the Natural Resources Commission, and Cool Davis”
      This can be found on page 08-13 of the council report, located at this link:

      1. Robb Davis

        Don – No one is “clamoring”.  The issue was raised and opinions about the value of housing on the site in terms of helping reduce VMT and GHG emissions were included.  And the report is correct that these are the entities that raised this explicitly in the meetings we held with them.

      2. Anon

        Doby, thanks for correcting me!  You are absolutely right. Which brings up an interesting point. All the “environmentalists” are the ones bringing up workforce housing – just an observation.

  6. Alan Miller

    BPs stated concerns (first comment) about what many voters may see in the housing / business parks issue reflect the concerns of many who believe in that these business parks could/should be built.  I’m pleased that the first quote chosen was the one from Matt Yancey, who clarified clearly the context in which the housing element was brought up: as a alternative for the CEQA document, as required by law.

    Indeed, to leave that out of the CEQA document could have opened up the document to immediate legal challenge, as it would have been glaringly incomplete.  Had city staff presented the housing issue clearly in context it may have kept the “third rail” housing issue from having been an article written about in the Vanguard, and the associated concerned comments from council and the public about how bringing up housing would tie housing to the project vis-a-vis how the public would view the project in a J/R vote.

    However, city staff should tell it like it is without polish/spin as much as possible.  We can’t hope to never have the “H”-word uttered in the 18-month ramp up to a J/R election, and instead, we should deal with it rather than avoid it.  Indeed, the City should clearly explain (similar to how Yancey did) why housing was brought up and in what context.  No need to make anything up as that is exactly why.  Unfortunately, a high-percentage of low-information voters will only see the headline and the picture of high-density housing and assume the City is proposing housing on the sites.

    Having said that, dealing with where the workers live will be challenging.  The housing alternative brings up the issues of:  1)  This housing element is NOT a plan from developers or city, but a necessary alternative for CEQA; 2) The workers have to live somewhere, and that is a regional issue; 3) Even if housing were provided, only X% (unknown) percentage of workers would actually live within walking distance of their office; 4) Public/alternative transit is unlikely to have a dense enough origin point for commute shuttles to make such shuttles have a viable inroad in the transportation mix for the project, certainly not in the early phases of build-out; 5) VMTs will increase and that must either be accepted or mitigated.

    I have no problem with all the parks being built given a green light.  However, it would have to be done in phases in each project, either planned that way or simply by whichever park could attract tenants.  I have not had a clear idea if all the business parks are OK with getting the OK to build in a multi-park environment, knowing it may slow the buildout time for each park.  In other words, will the developers be willing, and financially able, to build the infrastructure out a piece at a time to meet the needs of each building/tenant as they go?  Especially given upfront costs that must be shelled out to get each project to go forward at all.

    Thus, to make it viable for the developers, one important approach for each park must be that the City insist on transportation improvements in a phased approach; i.e. money must go into a pot for each new building, with flag infrastructure investments to be built when X% buildout is reached.  As an example, a bicycle/ped crossing over Hwy. 113 would be built from the pay-in fund when the park is built out at 60%.  The right-of-way for the connecting bicycle trail and bridge footings would be pre-planned into the project to avoid later conflict of space.  These sort of approaches may make all the parks feasible, to grow as the market dictates over a period of a decade or so.

  7. Michelle Millet

    It (housing) really has only entered the conversation at this stage for the purposes of keeping the city compliant with CEQA law.

    General question, is housing the only way for the city to be compliant with CEQA law.


    1. Robb Davis

      Michelle – Let’s be clear.  The CEQA requirement is to analyze certain alternate scenarios (including a “no project” scenario) so that the City Council has a basis for comparing projects with alternatives.  The staff report lays out the alternatives to be assessed.  There is some judgment permitted on which scenarios would be acceptable but Heidi Tshudin–our consultant–is highly trusted and experienced in CEQA matters and she recommends including the live/work housing alternate scenario because VMT is generated by commutes and having housing on site, theoretically, offers a way to mitigate VMT.  She made it clear that in modeling this and other scenarios all assumptions used would be made explicit so each one can be analyzed.

      Again, the requirement is NOT for housing but for an analysis of alternative scenarios, one of which (as approved last evening) is to analyze the live/work housing scenario.

      1. Michelle Millet

        Thanks Robb, what I was not totally clear on from watching the meeting was if housing was an alternative option or a necessary one. Basically what you are saying is that “live/work” housing is  one way to mitigate for VMT (which I just learned stands for vehicle miles travelled, not knowing this while watching the meeting may have contributed to my confusion:-), but other options exist?

  8. Robb Davis

    Sure, other options exist and it is not required to have this exact one.  However, Heidi believes it is necessary to include it.  Keep in mind that the entire CEQA process is subject to legal challenges and so this process is about ensuring that we have met critical requirements in the law that can withstand such challenges.  BTW, this is also why I asked how the CC might actually “use” the results of the alternate scenarios.  I don’t just want them to be a pro forma legal requirement but to actually inform, in the broadest way possible, our decision making.

    1. Michelle Millet

      So CEQA requires that we consider these housing options (or other VMT mitigation), not that we actually implement them? This is very confusing, you may have to explain to me in person;-)

      1. Alan Miller

        CEQA is confusing.  Basically, you need to give an outer-range of viable options, from no-build to alternate.  In a way, however, it is dictated by politics, as the range/nature of options considered should be based on realistic options that an opponent may sue on, as the only “real” test of if you have met CEQA requirements or not is to test the lack of a scenario in court.  So you view what an opponent would consider lacking and if they have the monetary means to sue on that basis and if they could win.  If they do, you should definitely include that option and make your analysis air tight.  I’m not saying that’s the starting point for CEQA analysis, but any good CEQA consultant had better consider such, lest the CEQA be challenged in court.   Actually, a “good” but morally-scrupulous CEQA consultant will leave something undone so the CEQA is challenged so that they can get a giant, profitable change order to prepare the CEQA for court.  Welcome to America.  Welcome to California.

    2. Matt Williams

      Based on my numerous observations of Heidi’s work on the extensive Yolo County General Plan Update, I feel very, very comfortable following her recommendations on an issue like CEQA process compliance (and many, many, many more issues as well). We would be very wise to follow her advice on this issue.

  9. Gunrocik

    Agreed, we are in good hands with Heidi — and you have to assume we will be getting a lawsuit if any of the projects succeed.  Our locals have a very good track record at attempting to stymie progress — and if they can’t stymie progress–they will try and extort us for legal fees.

    1. Robb Davis

      Michael – the 2:1 mitigation will be part of negotiations in the development agreement. I asked your second question Tuesday night and the answer is we should begin to get estimates in the first quarter of next year. The finance and budget commission will be actively involved in analyzing the fiscal model’s parameters and assumptions.

        1. Robb Davis

          That is what I am referring to David. This will not be done “in-house” as I understand it. An outside firm will be engaged. I do not have the details at this time.

          1. Matt Williams

            Robb, I would hope that one of the “leave behinds” from that independent analysis will be a computerized model that the City can use in future analyses.

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