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Nice job assessing the project against the citys residential design guidelines, which is the framework that should be assessed. And the other thing i would observe is the abutting neighbors on the east and west seem to support the project. It seems the Planning Department was constructive in terms of bringing people together in an inherently process that we have. I just want to say that intend no disrespect to my neighbors who have concerns and issues about it. Its a small neighborhood and we pass each other so i want to acknowledge to disrespect against their viewpoints and the comments and concerns that they have. So personally, i believe its appropriate to approve the project. Thank you. Next speaker, please. Im in support of this project. We need a lot more housing in the city. This doesnt consolidate lots so it should be approved right away. And right now, in the excelsior homes are selling over a Million Dollars because theres not enough housing for places like the marina. So to have this proposal to increase housing in the marina completely in the law, it should be a nobrawne nobrainer. Thank you. Thank you. I would like to start off by saying the public sponsor has done approximately 50 projects in San Francisco in the neighborhoods, 50 opportunities for handtohatohand combat. That, plus the fact he has two additional has the support of his two neighbors and 30 letters to support affects volumes to his architect and his eagerness to please and work with his neighbors. There are two drs here today. This asked to remove the top floor and thats completely inconsisinconsistent with what s talks about. Look at the size of the third bedroom, look at the size of that. Its a small bedroom. The next concern is the roof top deck. Despite the sponsor has made numerous concessions to this deck and rooftop decks are important to Family Housing and family living. The project sponsor is suggesting we can do this with cc rs and that wasnt good enough. He went to rescene th resign the so now only topfloor people can use that deck. And he wasnt happy. He wanted the roof deck eliminated. This deck is welllined. Eightfoot sidebacks off the property line. A stair house, recessed staircase, all block the visual line of sight between the users of this deck and these yards. There will not be a visual impact from this deck to these neighbors. Now we should not eliminate roof decks just because theyre a roof deck. When theres good design, roof decks should be approved, especially when theres no impact to the neighbors. Thank you. Thank you. Any more members of the public wish to comment in support of the project sponsor . Seeing none, Public Comment is closed. I just wanted to say im sorry. Dr requester, you have a twominute rebuttal. I am friends with my neighbor and just now friends with the developer who will never lou here and just to clarify, a lot has been raised about the two neighbors. 25 capra is owned by a Large Institution and some are controversial and so as such, it decided it cannot oppose a developer or project regardless of the merits of the case and 39 capra who has tol told us its waiting to follow precedent and in their case, they look at future development and that makes it all the more important of whats happening to 33 capra because it will be followed next door. My presence here today is not about the impacts but affecting everything in the neighborhood and just happening to be carrying that forward today. Thank you. Dr requester number two. I would like to just make two comments. This is about a lot of people who calm here in support of the project. These are going to be luxury condos and none of you that supported the project in front of the commissioner will b comme to afford it. Number two, why is this project dragging so long . Ive bee participating since maf 2018 and along with several of the neighbors that have lived in the neighborhood for decades. He never took it seriously. Thank you. Project sponsor, you have a twominute rebuttal. Im glad that is not personal for mr. Callahan. Mr. Callahan did lie us to alloo take a photo, because we are, as architects, trying to be as responsible as possible to understand what it might be. Luckily, he has the lower unit with this great landscaping. As i said in regards to the changes that we had discussed, our clients are stilling to incorporate this if they the commissioner sees fit. If they were willinwe believe tr units, one is 1300 square feet and the other is 1500 square feet and we believe its not outsized but what the commission has asked us to try to do and encourage our clients who are developers to do and what the mayor wants us to do. I request that you do not talk the Department Dr and approve s submitted. We have 30 letters of support, printed for the commission. Lastly, i did want to say if the proposed changes are of interest, you did not have dr for us to do that because we would for example, if we can get dvu to thank you, out of time. Sorry, i didnt realize. We are tripling the units here and i dont want us to lose a unit and i think that the architect actually did a good job stepping from the taller building down to the lower building. Commissioner . Thi would agree with many of the speakers both for and against that this is the project we should look for, dens densification in areas that dont allow for it. I think the project works and should be commended. We should ask about this, instead of two units that are three stories tall, were getting three great appropriate units for in thund. So the question just comes down to the roof deck. Mr. Lund, could you just show us the project you had. Im sorry. So this is the front, 33 capra, this is the rear yard. I would generally be supportive of the project as proposed, besides the roof deck is offered in west or in what mr. Lum showed us. We would have to take d. R. And approve with those changes, but that is where i would go. Does that also apply to the possible elimination of the penthouse . If it is feasible to eliminate, you can go forward. It could be contingent upon Building Department allowing that. So we would acknowledge the pursuit of that penthouse being removed. We cant dictate it given tbis concerns, but is uncertain at this point whether it is allowed by d. B. I. I think this is where mr. Lum was trying to finish his thought if it could be done, it doesnt need to be considered in your decision because it is reductive from what was originally noted. I move to take d. R. , reduce the roof deck as proposed by the project sponsor, if we can have the appropriate plantings there and encourage the project sponsor to eliminate the stair penthouse. Second. Commissioner fung . Commissioner moore . Mr. Lum, could you explain why the unit that is on the top, which now gets the roof deck, and i agree with the shaping of the roof deck and the possible elimination of the penthouse, why does it also need to have a deck the lower level . The main level . That is correct. It accentuates we had to do a setback for that because of the 30foot, 10 foot rule that says if you are doing in averaging of the rear, the building cannot be any taller than 30 feet. It has to be setback 10 feet to the 40foot height. The only other choice would be that would be a roof. It doesnt seem like a very nice thing for the living room to look upon. Or the walkable part of the roof would be smaller than bringing the deck all the way to the edge, because i do believe that the utilization of that roof, by a balcony all the way to the edge does not look much more massive. You may not understand, maybe you do. It is against a blank wall there on the west side is set back. That side exceeded the required setback to 7 feet on the west side to allow for a shorter west neighbor. While you are there, could you speak one more time about the light well . I understand that the light well has a spotlight on it. It also has a parapet so it is completely enclosed. That neighbor is supportive of the project, also. So he has basically abandoned the request that the light will be okay. Your package is very extensive, and they are sometimes hard to follow given that theres so many pages. I would like to ask you personally, because if this occurs on more than one project, that for the sake of the commissioners, reduce the drawings that we get. Theres just too much information. You mean the number of drawings that we give you . I would love to do that, too. I would love to not have to appear before you. Thank you. [laughter] if theres nothing further, there is a motion that has been seconded to take d. R. To reduce the roof deck and encourage the removal of the stair penthouse. On that motion. [roll call] so moved. That motion passes unanimously 5 0. We will take a small five minute recess and then we will get started with the balboa reservoir shortly thereafter. Welcome back to the San Francisco Planning Commission regular hearing for thursday, september 12th, 2019. Commissioners, we left off on the 2 30 p. M. Calendar. Is the Court Reporter ready . While the Court Reporter finishes up, i will remind members of the public that your public testimony today is on the accuracy and adequacy of the Environmental Impact report, not on the project itself, please. Commissioners, we left off on item 12. The balboa reservoir project. This is a draft Environmental Impact report. Written comments will be accepted to the Planning Department until 5 00 p. M. On september 23rd, 2019. I would like to stress and remind members that you are your testimony should be on the accuracy and adequacy of the final Environmental Impact report, not your opinion on the project itself. Good afternoon commission. I am with Planning Department staff and Environmental Coordinator for the balboa reservoir project. Can i have the screen . Thank you. The item before you is the review and comment on the balboa reservoir project draft subsequent Environmental Impact report or e. I. R. The purpose of todays hearing is to take Public Comments on the adequacy, accuracy and completeness of the draft subsequent e. I. R. Pursuant to the California Environmental quality act and San Franciscos local procedures for implementing ceqa. No approval action on this document is requested at this time. The public review period for the projects draft subsequent e. I. R. Began on august 8th and will continue until 5 00 p. M. On september 23rd. I will briefly explain why we are preparing a subsequent e. I. R. And then summarize the project description and analysis before opening up the meeting to Public Comment. The 17acre project sight is the western portion of the balboa reservoir, which is within the bell balboa park station plan area. The e. I. R. For the area plan was certified in 2008 and it assumed 500 dwelling units would be developed at the was of our project sight mac project site. The subsequent e. I. R. Is a whole new e. I. R. That focuses on the conditions that need new analysis. The current project proposes more density than was assumed in the area plan e. I. R. , so it is a revision to the project and it identifies new significant Environmental Impacts and substantially more impacts than those identified in the 2008 e. I. R. Plus the ceqa document, it is a subsequent e. I. R. And it uses, as a base, the analysis that was done for the 2008 area plan e. I. R. The draft subsequent e. I. R. Analysers two different sets of options or the sites residential density to capture a range of possible development on the project site. The developer his proposed option is proposed by Reservoir Community partners and the additional housing option has been developed by the city to maximize Affordable Housing. Development under each of the two options would entail the same land uses, street configurations, and site plans. The additional housing option adds one story to each of the buildings and includes smaller units to increase the number of residences. The developers proposed option includes 1100 dwelling units and a Public Parking garage. The additional housing option includes 1550 units and no Public Parking garage. The draft subsequent e. I. R. Also analysed is four project variants. They are located at the same project site and they all relate to the parking garage location and transportation access. Before i discuss the findings, i would like to point out that in february 2019, the Planning Department updated its Transportation Impact analysis guidelines pick these guidelines provide methodologies and criteria for undertaking transportation review in San Francisco. They include updated travel rates that account for vehicles operating as Transportation Network companies. The balboa reservoir project transportation analysis is based on these rates and therefore analysers the impacts of these. I will now summarize the draft subsequent e. I. R. s significant and unavoidable impact findings the draft subsequent e. I. R. Identifies three significant and unavoidable impacts during project construction. These involve construction noise, regional air quality during the threeyear three year construction schedule, and localized air quality during the three year construction schedule. All three of these impacts will be significant under both options and all project variance. The drafts of the subsequent e. I. R. Identifies two transportation related impacts during public project operation. One involves potential complex evolving loading along the avenue extension, which is currently a deadend, but will become a through street on the project becomes operational. The other impact involves transit delay under cumulative conditions due to growth of the project site, combined with growth at city college. Both of these impacts will be significant under both project options and all project variance. The draft subsequent e. I. R. Identifies four project alternatives. I know project alternative which is required by ceqa law, reduced density alternative, an alternative that allows passenger vehicle access from Westwood Park via san ramon way , and a six year construction alternative. The only build alternative that would reduce significant and unavoidable impacts is the six year construction schedule, which would reduce the two significant construction air quality impacts to a less than significant with mitigation. Significant Transportation Impacts during the project operation would occur under both options and all variance. While the san ramon way vehicle access alternative and the reduced density alternative would reduce Transportation Impacts, it would not and reduce them to less than significant levels. Today, the Planning Department is seeking comments on the adequacy and accuracy of the information contained in the draft subsequent e. I. R. , members of the public who wish to speak, please fill out a speaker card and state your name for the record. Please speak slowly and clearly so that the Court Reporter can make an accurate transcript of todays proceedings. Staff is now committed to respond will not come out today. Instead, we will transferable verbal and written comments received today and during the Public Comment period, and we will respond to these comments that raised significant environment of issues in a response to comments document. There are no speaker card. No speaker cards, but you can lineup, correct . Sorry about that. We will respond to written and oral comments in a response to comments document, which we anticipate publishing in the spring of 2020. Those who are interested in submitting written comments on the draft subsequent e. I. R. May do so by email or by hard copy all comments must be received by 5 00 p. M. On monday, september 23rd, unless the commissioners have procedural questions, i respectfully suggest the public hearing on the site and be opened. Thank you. Members of the public, please line up on your right side of the room and come on up hello, my name is lisa. Im here on behalf of myself, my husband, and my son. We are supporters of this project living looking at the environment Impact Report, we dont see any reason that this project should not go through. Housing is such an issue in San Francisco and this project has already been reduced in scope, so we would urge you to support this. Is a former high school administrator, with my it is hard for me to see all the students who cannot afford to live here and i have just had to say goodbye to my sun my son s best friend who grew up just blocks from this project. Please approve this project. Thank you. Next speaker, please. Hello. I have already submitted quite a number of written comments to you, hopefully you have been able to read some of them, and i have pointed out a whole lot of inadequacies in the e. I. R. I am wearing the shirt that says no war on iraq. That is because i dont have a shirt that says no invasion of luxury housing onto the balboa reservoir. I am in favor of the Affordable Housing, but not luxury housing i will just talk about two inadequacies out of all the things that i have heard so far , and there have been more written comments forthcoming, but i will talk about two. This is a weapon of mass destruction in terms of what the balboa reservoir project is doing, you know, similar to the iraq war where they were looking for weapons of mass destruction, we have them right here with the rest of our project. And how do i mean . During the iraq war, the British Intelligence agency, m16, wrote the downing street memo. And what the downing street memo said, the evidence and the facts were fixed around the policy, and that is what we have right here. You have the Planning Department that has set this whole project in motion, and the policy and the e. I. R. Is being fixed around that policy. I will go to two specifics. One is the environmental setting. That is critical for ceqa setting up the Environmental Baseline setting. The prescription that is given in this e. I. R. Basically just talks about the plot itself. But ceqa, in terms of code of california regulations says you have to talk about the vicinity , not just the plot itself, so that is already right there. It is in violation of ccr 151525. The second one is regarding transit delay. Transit delay is defined in this e. I. R. With a threshold of significance and it is an inventive threshold of significance. And what does this e. I. R. Say . The threshold of significance is four minutes. What does that mean in terms of the reservoir . It means that the reservoir project can contribute four minutes of delay on munimobile without it being significant. It is b. S. Read it carefully. Thank you. Next speaker, please. I am with united Public Workers for action. I think we see today, already the results of your disastrous Planning Commission decisions. Warrior stadium is a good example of that. You approved that without proper transit. Violation of your rules and you did it because you are basically a kept commission, which represents the developers thats why all today you have been going along with whatever the developers want. You are saying to hell with the people of San Francisco, it is okay to have more gridlock. This project at the balboa reservoir is a project that will destroy city college of San Francisco. Thats not in your plans, although that will be the result, to have massive construction and 1500 condos to prevent the college from developing. It will create chaos. You dont even give a damn about city college were the people of San Francisco because you represent the developers. That is what i think more and more people understand who come here. They see you as a shells for the developers. The fact of the matter is that the corrupt operation and the city of San Francisco spends millions of dollars for avalon for these meetings, staged meetings, to really grease the way for this development. These homes, these condos, and offer the people of San Francisco, working people, students, professors, they are for people who have a lot of money and can afford milliondollar condos. That is not the kind of construction we need. We need working because construction. The Labor Council has said the p. U. C. Should transfer that property to city college for development. That is what we support. It shouldnt be privatized as you are supporting these developers to do. Avalon developers are interested in one thing, profit , profiteering off the land of San Francisco. We need workingclass housing in San Francisco, not more milliondollar condos, but that is apparently what you are driven to do by the developers who appointed you and who you represent. The students at San Francisco city college need that parking. Theres no plans for parking for them. These are workingclass students who work at jobs. Where are they going to go . They will be driven out of city college because they wont have parking. They will have to go to the chubs and they will be able to. That is part of the privatization and the destruction of city college, which is being pushed by the developers and the mayor of San Francisco and if the supervisors approve that, they are part of this development process. We say to the public of San Francisco, stop this corrupt, rotten development. The more gridlock on at ocean avenue. There is no way of getting transportation off there. The m. T. A. Has said they cant provide the extension of the ocean avenue, which means there will be gridlock. There is gridlock now and you want to encourage more gridlock for the people of San Francisco not to be held accountable for the terrible situation with the warriors with two stadiums now, the hospital, two hospitals and people cant go to their own facilities. Thank you. Next speaker, please. I will remind members of the public that the purpose of the hearing is to set testimony and the accuracy and adequacy and completeness of the environment Impact Report. Good afternoon. That is a tough one to follow, but ive got a few concerns. My name is dr. Andrew currier, i am representing Archbishop Riordan High School as its president. Has a multitude of concerns, bus at but as it relates to this report, we serve 680 boys ages nine to 12, and a quarter of them, 170 of them have diagnosed learning needs. If i could pull this up, this circle, that represents the learning area. It is a specialized design learning area for students with diagnosed learning needs that we cant move them elsewhere in the building, so we are worried that theres not enough information about the noise, the dust, the destruction to their learning growth, their academic growth. Again, we dont have any option to move them elsewhere in the building, so we really want more detail on that. We want some sensitivity to that. These are young man that cannot be served by San Francisco public schools. These are specialized programs. We also have 50 students in residents at Archbishop Riordan High School who also, some of them have significant learning needs. They cant go elsewhere to receive this help, so we need to more information about the noise impact. How is the hammering, the excavation, the drilling, all that noise, all that disruption , the trucks, when they are beeping to back up, the backhoes, how will that will that be two years lost on 170 students education who are trying, despite learning needs and differences, to prepare themselves for college . They are paying, in some cases, 60,000 a year to attend riordan for this specialized care. That is all going to be distracted for two plus years . That is unacceptable to us. We need more detail on this. The other thing is, we are worried that firetrucks are going to be able to get to our school in case of a fire. Theres not been enough detail or clarity about the location. They delayed that meeting. Were supposed to take it was supposed to take place that this week. It has been delayed until september 30th. I need more clarity on the impact to transportation on our school. The other thing is, theres not nearly enough detail about the blockage of light into our building. It was designed to have Natural Light coming in to warm the building, to enhance the culture of learning for our students in the classroom. That is all going to be blocked thank you for listening. Thank you. Next speaker, please. Hello. Thank you very much. My name is Christopher Peterson , a resident of ingleside. I strongly support the additional housing option version of this project because it is environmentally superior to options and alternatives that provide lust transitoriented Affordable Housing and or more Public Parking. To reduce the amounts of housing would increase pressure on housing in areas that are more automobile dependent and have more extreme climate, to provide more Public Parking would undercut at first to address Climate Change by reducing automobile use. That said, this draft fails to evaluate how the developers proposed the Public Parking garage would undercut city colleges efforts to reduce automobile use. The colleges 2019 Transportation Demand management and parking plan concludes the tedium measures t. D. M. Measures would be sufficient to address the loss of Parking Spaces caused by this project. The only exception will be varying a few hours of the first week of each semester. Even then, it would be less than one third of the 715 spaces proposed in the Public Parking garage. There is therefore no need for such a large Public Parking garage. It would undercut the citys in the colleges efforts to respond to the Climate Crisis by reducing automobile use. Finally, the transit improvement mitigation measures identified in the draft should not be discussed until after the project is shown to have an adverse impact on Transit Service. Congestion when city college is in session, and congestion associated with the Grocery Store are already impeding Transit Service. The project proponent should be working with munimobile now to implement transit improvement improvement measures upfront without waiting for impacts in the future. Thank you. Next speaker, please. Hello. My name is benjamin and i am a resident of district seven in ingleside and im speaking on behalf of myself and my parents specifically, the duress of affordable, reasonably sized Housing Options in my own neighborhood. Im thrilled to see that this project is making its way to the process with all of these more reasonably sized units that are so transit accessible and in this great location. It appears to me, with my untrained eye that the Environmental Impact report is in order, and that it should proceed to the next round of approvals. I also would like to say that the kind of thing that didnt get included in the environment Impact Report is the number of people who live in these places in the future without cars and who will be taking Public Transit in San Francisco, rather than that same number of People Living out in modesto and driving into San Francisco every day for an hour and a half. I think these are important environmental considerations. I hope that the Commission Approves the more housing rich option and thinks very seriously about the parking garages and increasing Transit Service sooner rather than later. Thank you. Thank you. Next speaker, please. Good evening. Thank you for having this meeting. We appreciate your time. My name is sam moss. I want to reiterate that when developers are being disparaged it is disparaging. Three nonprofits provided over a century and thousands upon thousands of 100 low income Affordable Housing to San Francisco. And to be frank, avalon is an incredible market rate developer that knows and understands the community. This project has taken everything into account and then some and, you know, Mission Housing has over 1,000 children that live in our buildings. We take their health and safety very seriously. We do occupy rehab projects in their buildings all the time. Not that those concerns arent a valid, but i am personally saying that as one of the codevelopers of this project, that his community is community and safety our top of our list. Thank you. In a. I have been speaking in favor of balboa reservoir for a couple of years now. If we cant have an Environmental Impact report tell us that it is better to have vibrant and walkable housing instead of a giant parking lot, then i dont know what to say about the future of San Franciscos ability to deal with Climate Change. It is obvious that we should be turning parking into housing. It is obvious that it will be for the benefit of literally thousands of people who will have the ability to live in this 50 Affordable Housing project. Another great thing, planners have worked really hard to do these cross subsidized projects in a world where we dont have enough funding for subsidized, Affordable Housing. Were working on things like the bond, were working on other sources of Stable Funding these 50 affordable projects we get to cross subsidized with market rate housing in order to get more low income housing, we need to be celebrating those projects. This is exactly the kind of thing that allows the city to get a lot more units of subsidized Affordable Housing. It is tragic to be speaking for this project over and over again. It has been since 2008. This is the fourth time they have tried to build housing here. If San Francisco cannot get its act together and turn a 17acre parking lot into walkable housing, then we are not going to solve any of our other problems. Thank you. Thank you. Next speaker, please. Hello. My name is brad. I live here and i grew up here and i was born here. You made some valid points. You have to really think about what this location is. City college and the main campus. You really have to think about what they the use is for and the impact. Im all for Affordable Housing, you know, i believe in biking, what you really have to think about all the people that cant bike here, to that location or, you know, it is very valuable to have a parking lot, so that is open to everybody that wants to be able to park there, and it is frustrating, and im sure you are frustrated, too, that there is a reason why it has dragged on for so long because people are really awakening to this. I am glad we are taking time to make sure of this. And also, i am also disabled. So we had to think of the mobility for people who need to need to get to class on time. Parking is very limited. Thanks for your time. Thank you. Next speaker, please. Hello. Sorry, im a little nervous. This is my first time at any of these meetings. Watching people speak, it is incredibly inspiring. Sorry. My name is jess and i have been a student since general 20th and a proud recipient of free city. I am incredibly grateful for the opportunity to change my life and my career and use the platform to help gain access for future students. I would like to echo the student disability advocate, brad, for his statement on the lack of available parking for disabled students. Is a representation of students sometimes free city is our only option and get to the next level. We cant afford to even live. The picture showed in the Developers Plan showing the ccsf as being underutilized. The photo was said to be taken on a sunday. I dont know about you, but we dont offer many sunday classes at our school or on ocean campus. I dont think it is a representation of the Current Service of this public lands. Oriordan uses a parking lot near the school for band practice in the upper lot is filled by 10 00 a. M. And the balboa reserve public land has been essential for students. Students have student seven posting of videos on twitter of the reservoir being occupied by students. Students are going to experience the pain and it will affect the success of the community. Neighborhoods are flooded with cars and students are rushing to find parking in residential surrounding areas. It will increase the risk of pedestrian fatalities. As such, San Francisco is known as a premier city. [indiscernible] students commute sometimes an hour to learn. The education rate of reimbursement encourage them to come from hollister, joshua tree, sacramento, just to go. Where will students go . Pushing the responsibilities onto neighbors seems irresponsible. It is the absolute best use of the land pick the school isnt perfect. It has seven i have set on the land, i organized, and ive advocated and talk to students for hours at a time. 70 of this staff are now parttimers. The salaries wont even cover the floor of housing. Thank you for your time. Thank you. Next speaker, please. My name is michael. I come to you as a student of city college. Im a former city planner and former administrator of a Major University in the city and the person who lives in a walkable neighborhood. The access from the walkable neighborhood to city college, there was a comp it was accomplished by rapid transit. Rapid transit in San Francisco is getting in a car, driving twice as far, and in half the time you can get on munimobile or bart and getting to your destination. That parking lot is more than a piece of asphalt. It is kind of like what folks would call the runways at San Francisco airport. Without any context in terms of the cultural and social and economic value of that property it is not a parking lot. It is a transit stock for people shock paying and experiencing the Educational Opportunity that city college provides. We have heard remarks about zoning take this project will require a zoning change, spot zoning is the substance and felt but of federal lawsuits Developers Come in and capture a spot. That is lawsuit material. This group who are opposing this project, i would like you to look at the diversity of the group and compare that with the diversity of this panel and then compare that with the diversity of the project sponsors, who cant find the person who looks like me to support the project. Theres something about San Francisco that gets diverse populations coming together to try to [indiscernible] that legacy has continued, unfortunately. It would be helpful, since you have gone through transition of administrators, to look carefully of not repeating the boast of justin herman. Thank you. Next speaker, please. Hello, my name is vicky. I am a student at city college and i am there because im here to represent a lot of those who couldnt come with me. If you could imagine, the 20,000 students who would be impacted by this and who are currently enrolled at city college. 20,000 students. We already, as is, are a commuter school. We know when we did a survey in 2006 in 2016, it showed that over

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