One City, One Future: strategies for housing, jobs, and equitable growth (that Thompson has mostly ignored)
There are two strikes against it, however. Though it was released after the economic downturn and makes the case that the recommendations are sound in both bad times and good, the document--the product of four years of work--seems geared to harness an expanding economy rather than a struggling one--after all, it’s always easier to share the pie when it’s growing.
And, though the document is measured in tone, it represents a forceful criticism of many (but hardly all) policies pursued by the administration of Mayor Mike Bloomberg and thus could have served as a blueprint for underfunded, lagging Democratic candidate Bill Thompson.
Thompson only belatedly has sounded populist chords on issues like rent and and the transit fare. And, as Ted Hamm points out in The Nation, Thompson--despite an endorsement from One City supporters like the Working Families Party, has not pushed for a living wage.
Broad endorsements across the AY divide
One City/One Future, a collaboration between National Employment Law Project, New York Jobs with Justice, and the Pratt Center for Community Development, has been endorsed by a large number of organizations.
Interestingly, among them are some antagonists in the Atlantic Yards sage, such as pro-project forces like ACORN and the Carpenters Union and critics like the Fifth Avenue Committee and the Pratt Area Community Council. Indeed, some of the policies--affordable housing, job training--that emerged via the privately negotiated Atlantic Yards Community Benefits Agreement are part of this blueprint, though with public oversight and a far more transparent and responsible process.
Other cities offer examples to emulate. Los Angeles, home of the strongest CBAs, has led the way on good jobs and career training. Washington, D.C., ensures that all security guards earn a living wage. London produced a comprehensive master plan.
Three fundamental strategies
The blueprint sets out three fundamental strategies, followed by detailed policies, of which I’ll highlight a few.
Raise the Standards
Government should set clear standards for economic activity in New York City, especially activity that benefits from public spending or actions. Meeting these standards -- whether they concern the quality of jobs created or the environmental sustainability of new buildings -- must be a prerequisite for anyone doing business with the city.
Invest for Shared Growth
The city and state currently spend billions keeping New York's economy humming. These investments in housing, transportation, and employment need to be designed and managed with the explicit objective of improving opportunity and strengthening neighborhoods.
Reform the Process
Planning and development must take place in an open and democratic environment, in which communities and the city work as partners, not adversaries, with the objective of building a prosperous city on the strength of livable neighborhoods.
The problem with growth
The document sets the stage by criticizing the city’s economic development policies for being “narrowly designed to focus on growth — growth of population, the tax base, jobs, infrastructure, housing, and office buildings” with the unfortunate result of increasing rather than narrowing inequality.
(After all, who built all those new buildings? Often, non-union workers, some clearly exploited or endangered.)
In fact, economic development has led to an unequal supply of open space and other unfortunate results:
Whether in the form of large subsidized real estate projects, incentive packages for private developers, or rezoning for residential development without affordable housing guarantees, economic development policies continue to exacerbate the growth of low-wage jobs in a high-cost city; to escalate real estate prices, thus driving out manufacturers, small businesses, and affordable housing; to strain an aging and inadequate infrastructure; and to take place without meaningful community input and planning.
The document even mentions the backlash at two major projects:
Development as currently practiced has simply become intolerable for many New Yorkers, and it is creating new problems even as it addresses others. We hear it in the outrage against major development projects, from the Columbia University expansion to Atlantic Yards. It comes out in community board rejections of neighborhood rezonings.
Thus it points to the interconnection of policies: affordable housing depends on increasing workers’ wages, while community benefits from development require “significant and sustained community input.”
The hangover of history
As we learned during the belated reform of the 421-a tax break, the city and state waited too long to respond to policies that had, in recent years, turned into a giveaway to the wealth. The blueprint states:
New York’s current economic development policies are outmoded legacies of a period of economic crisis in the 1970s, when the biggest challenge facing the city was to cease the flight of jobs and investment. These policies were designed to maximize growth and the economic activity that accompanies it. But in the 21st century, New York stands in a very different place. Its strength as a global city can be leveraged...
Between 1990 and 2006, the city gained 51,600 restaurant jobs, which pay just $22,887, while losing many more manufacturing jobs, which pay more than $48,000 a year.
Bloomberg's ambitious “New Housing Marketplace” plan, which promises to create or preserve 95,000 affordable units by 2012 (now 2013), has produced about half that number and is falling short on its goals, as Gotham Gazette reported last month.
The report points out that, from 2002 to 2005, because of the loss of rent-stabilized and Mitchell-Lama housing, there was a loss of 205,000 rental units in New York affordable to a family earning up to $56,000.
(That income limit would apply to about half of the 2250 affordable units promised for Atlantic Yards. The others would be more costly.)
Living wage jobs
The report states:
Ensure that Economic Development Investments Create Living Wage Jobs
The city should use all of its economic development tools — including subsidies, city-owned land, land use changes, and city contracts — to create living wage jobs, by making wage standards formal conditions for receipt of these benefits. The city has begun to use these standards on individual major redevelopment projects, including most recently Willets Point, where it has agreed to require developers to guarantee good wages for certain categories of workers employed there. We should now move beyond this deal-by-deal approach and make it formal city policy.
The same wage standards should apply when the city conveys public land or buildings to a developer for an economic development project — or uses the state’s eminent domain powers to take control of privately owned land and then passes it on to a developer. And the city should institutionalize such wage standards by requiring that the City Planning Commission include them as part of all Urban Renewal Plans.
There’s no cost figure attached to this recommendation, as each project would differ. But the implication is that the city has leverage because the conveyance of public property or the granting of public permission has significant value. (Such pledges were made privately regarding AY, rather than part of a public process.)
The report recommends:
Require Businesses Receiving Public Subsidies to Hire Community Residents through a “First Source” System
Currently EDC does not require employers in subsidized projects to connect with city or nonprofit agencies that provide job search assistance to employers and workers. In most cases, it does not even encourage them to do so. Recipients of economic development subsidies — both large-scale development projects and loans or grants to individual companies — should be required to participate in a “first source” hiring system that links employers with community residents and low-income New Yorkers seeking employment and career opportunities.
This is something that some developers have done on their own. With the Atlantic Yards CBA, the curious thing is that developer Forest City Ratner hooked up with BUILD (Brooklyn United for Innovative Local Development) rather than established job-training organizations, as the New York Observer described three years ago.
The report recommends ways to make sure promises are more than words:
Codify and Enforce Clawbacks
Developers and companies receiving city subsidies should be required to make clear commitments about what they will do in exchange for government support, and then be held to those promises. Over the last several years, the New York City IDA has taken a step forward by including language in its subsidy agreements giving the city authority to demand the return of subsidy funds if a company does not fulfill its hiring promises. So far, however, it has failed to enforce these “clawbacks.” New York City should implement systematic clawbacks — penalties that companies must pay if they fail to honor their commitments. A good model is the performance-based approach to contracting that the city now uses in the human services area.
As I’ve pointed out, the penalties for not meeting the rather flexible terms imposed by the city and state regarding Atlantic Yards are fairly light--and the enforcement of the CBA is up to the signatories. The term “clawback” is one that deserves to be used a lot more in NYC.
The report recommends:
Repeal Luxury Decontrol
New York City has lost at least 150,000 rent stabilized housing units over the past decade.28 To keep housing affordable for the more than 1 million rent-regulated apartments that house most of the city’s working-class families and to keep affordable developments like Stuyvesant Town a haven for New York’s middle class, we must end “vacancy decontrol,” the 1997 rule that removes apartments from the rent stabilization system when the rent reaches $2,000 per month.
Under this rule, an apartment can be removed from rent stabilization if the rent is raised to $2,000 while it is vacant, or even while it is occupied under certain circumstances. As rents have shot up across the city, it has allowed landlords to decontrol many apartments through creative use of permitted rent increases and capital improvements. To stop this hemorrhaging of affordable apartments the state legislature should end the decontrol rule, and extend rent stabilization to all apartments and tenants in expiring affordable housing programs — including those financed under Section 8, Mitchell Lama, J-51, 421-a, and the low-income housing tax credit. Doing so will require that the legislature either impose these new rules when it renews New York City’s rent laws in 2011, or else simply repeal the “Urstadt Law” to return authority over rent regulations to the city.
That’s easier said than done, because landlords will fight back, but it seems hard to argue against increasing that threshold rent, which by now would be well over $3000 if it had been indexed for inflation. The newly Democratic state Senate should address the issue, right?
The report recommends:
Mandate Inclusionary Zoning
All new residential development over a minimum number of units should include affordable housing. The city should adopt a mandatory inclusionary zoning policy — like those of more than 200 cities across the country — that allows developers to make a profit while maximizing the number of units that are affordable at the lowest feasible income levels.
Such mandates should be combined with two existing incentive strategies — density bonuses and tax exemptions — to produce more affordable units, more reliably. Currently, in areas that are being rezoned to allow for greater housing density, density
bonuses permit developers to build even bigger structures in exchange for including affordable apartments. In Manhattan and selected areas of the outer boroughs, the 421-a program grants a property tax exemption for new residential buildings that include at least 20 percent affordable units. These incentives should be combined with a baseline inclusionary zoning requirement to ensure that all new large housing developments include at least some affordable units, and then reward developers that go beyond that basic requirement by granting them tax exemptions or additional density allowances.
These incentives should be structured to promote affordability at all income levels, especially the lowest.
In addition, the city should use its inclusionary zoning policy to address the need for community space and other kinds of social infrastructure, including child care facilities, senior centers, and schools. Developers should be allowed to partially satisfy their inclusionary zoning obligations by developing or preserving community spaces where they are needed, or by paying into a fund to do so.
Given the battle over the 421-a exclusion zone, this would be a hard one to win and one which requires some hard numbers. In fact, the real estate industry wants to go backward and restore the old rules to boost development, even though a lot of the condos built under 421-a remain unsold.
The report provides an example from San Francisco, which in 2002 enacted inclusionary zoning for all new residential development of 10 units or more. As April 2008, the program had produced about 450 ownership units and 150 rentals--not a particularly large number.
What about AMI?
The report acknowledges that the median income depends on where you draw the map:
Ensure that Housing Subsidies Meet Real Needs
The city and state should ensure that their housing programs create units that are affordable to lower-income households. Most housing subsidies target specific income levels, typically below the area’s median income. But these programs have proven inadequate to address the housing needs of huge segments of New York City, including low-wage workers, people on fixed incomes (including public assistance), the homeless, and those at risk of homelessness. Skewed by high incomes at the top, New York’s unsubsidized marketplace offers almost no housing that low-income New Yorkers can afford, yet subsidies reach only a small fraction of those who are eligible — typically those at the upper end of their income brackets.
City and state affordable housing programs generally target households earning some fraction of New York area’s median income, or AMI. But thanks to New York’s extreme income inequality, the AMI, which is calculated based on incomes across the New York metropolitan area, is much higher than the actual median incomes in the neighborhoods where incomes are lowest and the need for affordable housing highest. The result is that developers can satisfy the “affordable housing” requirements of many programs by renting or selling units to households earning as much $90,000, and sometimes more. New York City needs to do a better job of targeting its housing subsidies to where the needs are greatest, while also working to preserve the affordable housing we already have.
Indeed, while 900 of 2250 AY affordable units would be aimed at households earning 50% of AMI, 900 would be aimed at households earning above the AMI. That's why attendees at a July 2006 affordable housing information session were dismayed.
More funds for housing
The report recommends:
Continue to Support and Expand the Portfolio of Affordable Housing
The city and state should continue to make substantial investments in the creation and preservation of affordable and mixed-income housing. They should do this by increasing funding for housing development programs — including the Housing Trust Fund, Low Income Housing Tax Credit, Homeless Housing Assistance Program, and preservation loan programs — for the purposes of creating and preserving more units, achieving deeper affordability, and increasing wage standards for workers.
There’s no target figure, but it would be much easier to base the goal on an expanding pie (including federal funds) rather than reallocating funding from other programs.
The report recommends:
Promote Permanently Affordable Housing
In addition to existing programs and policies, which are incentive-based and income-targeted, the city should expand its affordable housing development portfolio to include models that promote permanent affordability. The city should use financing tools that promote the creation of new, permanently affordable housing, as well as find strategies to help projects set to age out of affordability restrictions stay affordable. All forms of subsidized housing, including Mitchell-Lama, project-based Section 8, and Low Income Housing Tax Credit developments, should be protected from loss of subsidy. The city and state should continue to explore all options for promoting permanently affordable housing.
Again, the cost is the question.
The retrofit investment
The report recommends:
Retrofit Residential Buildings
With the price of energy continuing to spiral upward, New York has an opportunity to make an investment with a great payback: retrofitting existing residential buildings to make them energy efficient. The city has already embraced this goal under Mayor Bloomberg’s PlaNYC 2030, which calls for retrofits for residential buildings with 50 or more apartments. The city and state can go even further and make retrofits affordable for owners of all residential buildings, both large and small, by creating an innovative residential retrofit investment fund that makes loans to cover the up-front cost of retrofits and allows owners to slowly pay them back as a line item on their new, lower reduced utility bills. Once this system is established, private capital can finance the retrofit fund, allowing the program to operate at little cost to the taxpayers. The city should then actively market the retrofit fund to building owners and perhaps even require large residential buildings to participate in it.
To ensure that the new green jobs created are good jobs, the city and state should require contractors hired for retrofit fund-financed projects to pay living wages and participate in the apprenticeship training system. And to protect tenants, the program should include safeguards to ensure that retrofits financed through the fund do not become the basis for rent increases. In this fashion, the city can cut energy use, reduce the pressure on rents created by rising fuel prices, and create good jobs — all at little cost to the taxpayers, and with savings for building owners.
Since the price of energy has gone down, the investment may seem less vital, but it's obviously a key long-term goal.
Look carefully at subsidies
The report recommends:
Reevaluate All Economic Development Subsidy Programs
New York City and State hand out billions of dollars each year in the name of economic development, with remarkably little accountability given the amount of money involved and the potential impact of the spending. Every significant economic development program should be subject to a rigorous reevaluation to assess whether it works and, if not, how it should be modified or scrapped to ensure that economic development delivers real benefits for taxpayers.
New York City’s Industrial and Commercial Incentive Program (ICIP) recently went through such a review, which led to urgently needed reform of the program (now renamed the Industrial and Commercial Abatement Program, or ICAP). ICIP was perhaps New York’s foremost example of an economic development program that had strayed from its original intent and become largely wasteful.
Indeed, civic groups have called for an audit of public monies allotted to Atlantic Yards; that would be a start on the accountability issue. Perhaps the City Council will have a hearing.
Strengthening sectors vs. real estate deals
The report suggests that big real estate deals are not the solution:
Focus Economic Development Policy on Strengthening Sectors
The city should reorient its economic development program to focus resources on sectors of the economy with the greatest potential for employment and career opportunities. Research from multi-city demonstration projects finds that the most effective municipal economic development programs are those that strengthen the sectors of the local economy that provide good jobs and can grow with public support — not on one-off, uncoordinated subsidies or real estate deals.
Under a sector-based approach, the municipal economic development agency conducts thorough and transparent research into specific industries, to identify those that can grow collectively, offer more quality jobs, and produce local revenue that has larger impacts on the area economy. A coalition of stakeholders — businesses, labor unions, investors, workforce development organizations, academics, and marketers — then convene to develop a strategy for strengthening the sector as a whole.
The full array of economic development tools— infrastructure investments, real estate actions, financing, subsidies, incentives, and workforce development — are used to enhance the sector as a whole, helping a wide range of companies and individuals to thrive and grow.
Unfortunately, the Economic Development Corporation has focused on deal-by-deal subsidies sought by individual companies and on large-scale redevelopment projects designed to maximize land values.
Remember, Andrew Alper, then-president of the New York City Economic Development Corporation, told City Council 5/4/04, "So, they came to us, we did not come to them. And it is not really up to us then to go out and try to find a better deal."
More transparency needed
The report recommends:
Improve Transparency of the Economic Development Corporation
EDC must make the development process more accountable and transparent. One simple step it can take is to publish all the responses it gets to requests for proposals, instead of only the winners. EDC also should develop a formal evaluation formula for ranking responses to requests for proposals (RFPs). The formula should be disclosed to the public and include job creation and job quality standards as central factors, with a special focus on the quality of the service jobs and other lower-wage positions generated. While EDC’s general guidelines do include “permanent on-site employment and payroll” as a factor in weighing development proposals, the agency does not in practice look carefully at job quality in the evaluation process. EDC should develop and consistently apply an RFP evaluation formula that makes the number and quality of jobs that will be created key criteria in assessing proposals.
At the Industrial Development Agency, projects should be subject to Local Law 48 reporting requirements for the duration that a subsidy remains in effect. Local Law 48 was enacted in 2005 to improve transparency around city subsidies. It requires yearly reporting on subsidy recipients, including information on the wages that they pay. But its reporting requirements end after seven years –regardless of the duration of the subsidy agreement. This truncated reporting term prevents a thorough examination of subsidy performance over time. The IDA should also ensure meaningful public notice
and participation in its award process by notifying community boards when it proposes subsidizing major developments, allowing for enough time and outreach to build public awareness and hear public concerns.
This did not happen with the New York Yankees’ request for additional bonds, according to Good Jobs NY.
Unified Development Budget
The report recommends:
Adopt a City Unified Development Budget
Following the lead of several states, the city should produce a unified development budget (UDB) that reports all local economic development spending in one place. UDBs combine information on appropriations (such as spending for grants, services, and infrastructure) with expenditures (tax breaks and other foregone revenue). In New York City, a UDB should include municipal spending as well as state projects where the city makes a large contribution and that have an impact on the city’s economic development, such as city-based Metropolitan Transportation Authority and Empire State Development Corporation projects. Juxtaposing these with Economic Development Corporation, Department of Education, and other municipal capital projects would enable a thorough, yearly analysis of the city’s major capital investments by city officials and watchdogs.
Remember, the ESDC oversees Atlantic Yards. Planner Alex Garvin has called for a capital investment strategy.
Community impact reviews
The report recommends:
Require Community Impact Reviews for Projects Receiving Subsidies
The city should require Community Impact Reviews for new development projects that receive city subsidies. The city’s main review process, the Uniform Land Use Review Procedure (ULURP), does not currently address many development impacts of great concern to communities, such as what sort of jobs will be created by a project. Moreover, some large projects, such as as-of-right developments and state-led projects, can sidestep ULURP altogether. A Community Impact Review would give area stakeholders and the City Council key information about proposed new developments that will have significant effects on their community. For example, it would include reporting on a project’s subsidy profile, land-use approvals, and construction permits — information already in the city and the developer’s possession but which is not always easy to access. In addition, it would require disclosure of other key details such as the quality and quantity of jobs that will be created, affordable housing production, demolition and displacement effects, and diminution of critical public services like police or fire response. The City Council is considering legislation to require Community Impact Reviews.
Whether this would go beyond the flawed but extensive EIS process, as exemplified in the case of Atlantic Yards, is another question. At the least, it should offer a more rigorous cost-benefit analysis than that conducted by the state.
Comprehensive city planning
The report recommends:
Implement a Comprehensive Citywide Planning Framework
The city Charter should be amended to require a new comprehensive citywide planning framework — New York City’s vision of itself for the future. This framework should be based on an analysis of existing challenges and projected growth within the region, city, boroughs, and neighborhoods. It should incorporate plans generated at the neighborhood level. The Department of City Planning should develop the plan in consultation with community boards, elected officials, and other stakeholders, for adoption by the City Council.
This comprehensive planning framework should be the basis for the city’s infrastructure plans and capital budget investments — so that new schools can be built where the number of youth is expected to grow, public transportation can meet projected needs, and so on. The plan should be reviewed on a regular basis. Proposed zoning changes or developments that comply with the comprehensive plan should be expedited in the land use review process. Those that do not comply would require amendment of the citywide plan, under tougher standards than required in the usual land use review procedure. Community-initiated 197-a plans created within the citywide framework, and that are adopted by the city, should be given the force of land use law to guide future public and private development.
This surely would’ve led to a lot more discussion about a proposed project like AY.
The report recommends:
Set and Achieve Standards for Neighborhood Services
The city’s Environmental Quality Review law should be amended to incorporate clear standards for the level of amenities and services each neighborhood can expect — such as school seats, neighborhood park space, and police and fire response times.
These standards and their application should reflect a careful assessment of the level of amenities and services necessary to keep a neighborhood livable, while reflecting each area’s unique demographics. The standards should also be based on a “fair share” plan that ensures all neighborhoods take responsibility for hosting necessary but environmentally burdensome facilities that serve the entire city, such as waste transfer stations and truck routes. These standards should help drive the citywide planning framework.
Even in the absence of a comprehensive plan, the new standards should be incorporated into the land use review process.
This would’ve avoided some of the debate about who exactly was responsible for new schools to serve the new community of AY.
The report recommends:
Make Community Boards Effective Partners
An effective city planning process relies on the city’s 59 community boards as central actors in shaping their neighborhoods. They need a level of funding, capacity, support, and accountability commensurate with that responsibility.40
The city should establish an Office of Community Planning to provide planning expertise and resources to the community boards and directly respond to issues of concern across neighborhoods.
The office should be responsible for proactively involving community boards in planning, for managing new planning responsibilities under the proposed expanded citywide planning framework, and for helping them meet their broader goals. To serve effectively as democratic neighborhood institutions, community boards must also better reflect and be accountable to the range of constituencies in their neighborhoods. The Office of Community Planning should help ensure that community board appointees are representative of local stakeholders, and that they are complying with rules to limit conflicts of interest and promote transparency.
The report points to the Portland (OR) Office of Neighborhood Involvement, which provides technical assistance and coordinates with city agencies, but also hosts various projects, including the Restorative Gentrification Listening Project.
The report recommends:
Make the Chair of the City Planning Commission Independent
Currently, the mayorally appointed commissioner of the Department of City Planning also serves as Chair of the City Planning Commission, which has resulted in the chair of the commission advocating the perspective of the department as opposed to representing a broader range of public opinions and interests.
The City Planning Commission should no longer be chaired by the commissioner of the Department of City Planning. Instead, a separate chair nominated by the mayor and confirmed by the City Council, should lead the commission. By making the City Planning Commission independent of the Department of City Planning, the city can free the commission to represent interests beyond those of the department.
Still, in the case of the current administration, I’m not sure that advocating the perspective of the mayor would be any different from advocating the perspective of the department.
The report recommends:
Keep the “Public” in New York’s Public Spaces
While private investment has a role to play in supplementing limited government financing for public spaces, the city must be vigilant in guarding against the risks that it can pose. When the city relies on private investment to build, maintain, or police public spaces, the results often disproportionately benefit wealthier neighborhoods and can set the stage for harassment and displacement of lower-income residents and workers. Privatization of public spaces reduces accountability for the services provided and can lead to policies that exacerbate inequality, such as paying maintenance workers less than a living wage and policing practices that marginalize “undesirable” users. Public parks created through public-private partnerships should give communities a strong voice in planning and management. The city should provide equitable funding for the management of all parks, and not allow over-reliance on private funds to create a two-tier system. It should be the city’s responsibility to prevent harassment and exclusionary practices in privately owned public spaces.
Keep in mind that the promised open space in the AY plan would be privately-managed, albeit by a conservancy.
The report recommends:
Create Genuine Mixed-Use Zones
New York City nominally has “mixed use” zones, labeled MX. But because lucrative residential development is permitted in those areas as-of-right, industrial uses are nearing extinction. The city should create a zoning designation that would maintain the character of neighborhoods where there is a mix of light industry, small stores, and residential development. This mixed-use development pattern is characteristic of many vibrant New York neighborhoods (such as Williamsburg, Gowanus, and Long Island City) and promotes strong ties between local jobs and residents. The zoning designation should come with a “good neighbor” mechanism to ensure noise and odor are not a problem. Unlike the existing mixed-use zones, which allow residential and office development without any restrictions, the new zones would limit complete residential and office conversions either to smaller lots or to certain transitional areas within the zone. Balanced mixed-use zones would avoid creating homogenous residential or office development by insisting on a diverse mix of uses.
Such performance-based zoning has worked in Toronto.
Adding it up
The report concludes:
New York City spent about $1 billion on its economic development programs in 2007. As this blueprint has noted, much of that money is spent on projects that would have occurred anyway, or whose benefits flow to neighborhoods and people least in need. It is incumbent on New York to reevaluate how it spends those resources, and to redirect them to build a more broadly prosperous and sustainable city.
There is no doubt New York City and state can do this — but we need strong leadership and commitment from all the stakeholders involved. Through much of its history, New York City has been a national leader in promoting policies designed to improve quality of life, strengthen urban neighborhoods, and promote economic opportunity and a more cohesive city. That tradition has built the thriving metropolis we have today. New York has reaped enormous rewards through its investments in mass transit, higher education, housing, public spaces, and other basic resources that are open to all who live or work in the city. It is an infrastructure unparalleled in North America, but one that urgently needs to be upgraded to meet modern needs and the rise of extreme inequality.
I doubt Bill Thompson has read this far.