Wednesday, November 16, 2022

Latest Transit Ridership Data for Houston and DFW

This week we have another always excellent analytical guest blog post from Oscar Slotboom.
Average transit ridership nationwide remains down 33.4% in September compared to pre-Covid levels, but Houston Metro is doing better. With a strong upward trend in August and September, Metro's September overall ridership is down 26.5% compared to the 12-month pre-covid average. Bus is down 20.2%, light rail is down 26.7% and park & ride is down 63.3%. September and October are normally the highest ridership months of the year, so the upward trend should peak in October or November (which will be boosted by parade ridership).
Houston ridership is also doing much better than Dallas. The chart below, which includes three North Texas transit agencies, is from the most recent NCTCOG meeting data and shows that transit use in North Texas remains down 39% and is basically flat in the last year. DART has a 93-mile light rail system, with nearly all of it built on dedicated right-of-way, including a long subway section, long elevated sections and DFW airport service. As I reported in 2021, the light rail system has always been plagued by low ridership. Recently, the Dallas Morning News reported on the high crime rate affecting DART patrons, which probably contributes to low ridership.
Highway use in North Texas has been back at pre-Covid levels for over a year. There's no readily available data for Houston roadway use, but it's almost surely similar to North Texas.
(I've been working toward a goal of having much shorter blog posts. I have finally succeeded. Yay!)

Labels: , ,

Saturday, October 15, 2022

Why Houston is better with TIRZs, our lack of zoning held up as a model for the country, 45N expansion gets support, professionals migrating to TX, and more

Before getting to some smaller items, I want to comment on the Chronicle's investigative report on TIRZs (tax-increment reinvestment zones).  While I'll admit they can be a bit of a mess and even a bit wasteful, what the reporters miss is that if the TIRZs were dissolved and the money sent to the City instead, it would just get gobbled up by the public employee unions long before it can do any good in any lower-income neighborhoods outside the TIRZs. As the pieces note, every mayor comes into office thinking they will go after the TIRZs, then realize they can make them work for the city as a whole by delegating projects to them (like improvements to Buffalo Bayou and Memorial parks), and shift City budget money to those neighborhoods outside the TIRZs. Finally, I think Houston's core (and the City as a whole) would be in a much more precarious position if it wasn't for the TIRZs making strong investments in Uptown, Downtown, Midtown, the Med Center, and other key districts to keep them attractive to employers and high-income professionals.

Moving on to a backlog of smaller items, mostly from my Twitter feed:

  • You may find it hard to believe, but Houston has the shortest CBD commuting times of the major metros due to a high-capacity freeway and HOV lane network with great coverage (Chart 5, page 7).
  • Harris County/Houston #2 behind Maricopa/Phoenix in total population growth over the last decade. Mapped: A Decade of Population Growth and Decline in U.S. Counties
  • Texas #1 for gaining rich young professionals from other states: States Losing (And Gaining) The Most Rich Young Professionals – 2022 Edition 
  • "According to Nolan Gray, one of the reasons Houston is among the most affordable, diverse and economically dynamic cities in America is because it never adopted zoning." 'Houston's lack of zoning fueled its growth and should be copied elsewhere'
  • Texas is their #1 destination: Young people earning $100,000 or more are fleeing California and New York—here's where they're going
  • Video: "Of all the Texas cities - most of which I'm very bullish on - the one that is probably going to have the biggest success story for the next 30 years is by far Houston." Hat tip to George.
  • The City Without Zoning: "For the most part, Houston’s positives are linked to its lack of zoning, and its negatives are essentially unrelated to zoning."
  • The Search for Intelligent Life Is About to Get a Lot More Interesting: "In 2018, Frank attended a meeting in Houston whose focus was technosignatures... seek out signs of technology on distant worlds, like atmospheric pollution... “That meeting in Houston was the dawn of the new era, at least as I saw it,” Frank recalls."
  • Public comment submitted on raising I10 at White Oak Bayou: this project seems unnecessarily disruptive and expensive to keep the freeway open a relatively tiny handful of days every few years, especially given that 610 provides a natural alternative when I10 is blocked by flooding. Additionally, when the city is flooding badly enough to put I10 underwater, most households and businesses are hunkered down anyway, reducing demand. There are better places to deploy TXDoT's limited resources.
  • "The planned rebuild of I45 in Houston drew the largest number of comments, 382 of the 1,685 TxDOT received through a month-long public comment period. Of those, TxDOT said 299 were supportive of the project while 66 were opposed." (source)
  • "Houston prioritizes the ease and cost of building housing above almost all else. As a result, residents with money have a higher standard of living and those without have more humane sheltering options. Cities with other priorities sacrifice on both of these." -John Arnold
  • Texas #5 state for racial equality, and #1 for states with a significant Black population share. Hat tip to George.
  • Houston is the largest metro below the national average for salary needed to buy a home. Map: This is the Salary You Need to Buy a Home in 50 U.S. Cities
  • The American Conservative: How Zoning Paralyzed American Cities: "America should learn from no-zoning Houston, says Gray...What proved crucial to rejecting zoning was Houston’s allowance of deed restrictions, whereby neighbors can voluntarily opt into zoning-like restrictions and design standards...And while neighbors get a say over their neighborhood, Houston as a whole is still allowed to grow. It builds housing at 14 times the rate of its peers and, in the process, has become one of the most affordable and diverse cities in the country.""
"Is Nolan Gray really calling for zoning abolition? Yes, he is. And before you dismiss him—perhaps Houston isn’t your cup of tea, or maybe you simply like your home and its zoning, thank you very much—consider that Houstonians agreed with Nolan’s view in 1948, 1962, and 1993, killing zoning each time it came up for a vote, largely thanks to working-class voters. What proved crucial to rejecting zoning was Houston’s allowance of deed restrictions, whereby neighbors can voluntarily opt into zoning-like restrictions and design standards to ensure whatever character of their community they desire for the next 25 to 30 years. And while neighbors get a say over their neighborhood, Houston as a whole is still allowed to grow. It builds housing at 14 times the rate of its peers and, in the process, has become one of the most affordable and diverse cities in the country." 

Labels: , , , , , , , , , , , ,

Saturday, October 01, 2022

The Shocking Cost for All-electronic Tolling at HCTRA

(This week we have part 2 of 2 always-excellent blog posts by guest author Oscar Slotboom - see part 1 here)
In part 1 we examined the strong post-covid revenue recovery and the rapidly escalating admin cost. Today we'll look at transfers out and the cost of conversion to all-electronic tolling.
Transfers Out
HCTRA has a longstanding practice of diverting toll funds out of HCTRA. The five-year average prior to 2020 was $132 million per year, but in 2020 the diversion was increased to $545 million, and funds were no longer being used solely for county road projects. See last year's review for more details.
In 2021 the diversion was $254 million. This is 72.6% of 2021 net income of $346.9 million. (Reference page 55, which is document page 64)
In last year's review I included "opportunities for improvement", and the first item was "More details about the specific use of funds transferred out."
No additional information is provided. The annual report still has the historically-used standard statement that the transfers are "to pay or finance costs of roads, streets, highways, or other related facilities that are not part of the Authority’s toll road system."
Conversion to All-Electronic Tolling
HCTRA stopped manual collection of tolls in March 2020 during the Covid emergency to avoid exposing toll booth workers. The system was effectively all-electronic at that point, but of course the tolling infrastructure remains on toll roads constructed more than 20 years ago. All new toll facilities opened since 2004 are designed to be all-electronic, including the Westpark Tollway, Fort Bend Parkway, Tomball Tollway and the northeast section of the Sam Houston Tollway.
The annual report lists conversion to all-electronic tolling as one of HCTRA's three major initiatives. It alludes to the cost of this initiative in the commentary about expenses, saying the $21 million increase in the $164 million expenditure for services and fees "is primarily due to an increase in service contracts related to the Toll Road’s effort in transitioning to a cashless environment and an all-electronic tolling plan." There has been a steady stream of consultant contracts in Harris County agendas, including $7.3 million on September 27.
The annual report cover includes a depiction of what appears to be an electronic toll gantry which will replace an existing plaza.
However, the annual report does not provide the cost of the conversion. Another document available at the HCTRA site, the state-mandated FY 2022 HB 803 Report (page 5), drops the bomb about the cost of this effort.
Estimated cost: $494 million
This is especially shocking since the demolition and construction work applies only to the older parts of the toll road system, mainly the original three sections of the Sam Houston Tollway, from I-69 Southwest Freeway to I-45 North Freeway, and the Hardy Toll Road. This work will apparently include demolition of the legacy toll plazas, and demolition work is usually a relatively small cost compared to construction.
The $494 million cost is 141% of the 2021 system profit, or (stated another way) consumes 1.4 years of system profit.
This plot compares the $494 million cost to recent and ongoing major construction projects, all costing less than the electronic conversion. (Sources 1, 2)
The similarly-sized North Texas Turnpike Authority in Dallas-Fort Worth converted to all-electionic tolling starting in 2008 with manual toll collection ended in December 2010. A July 2010 Dallas Morning News report stated that NTTA had spent $92 million on the effort. That number may not be the final total cost (for which information is not readily available), but the total cost is surely vastly below $494 million. While inflation has increased construction costs since 2010, major elements of electronic tolling, including cameras, software, and communication equipment, are surely lower today compared to 2010.
This certainly creates the perception HCTRA is charging tolls to pay for the collection of tolls, especially since it is likely that most of the conversion cost applies to the original three sections of the Sam Houston Tollway, which are huge revenue generators and have paid for themselves many times over. Sorry Sam Houston Tollway users, you need to pay $494 million so tolls can be collected indefinitely on sections which have long paid for themselves.
Let's hope HCTRA will provide a detailed accounting of this sky-high cost for electronic tolling.
Final Notes
The Hardy Toll Road Downtown Extension was suspended by Harris County Commissioners Court in May 2020, and the long-anticipated main lane construction has been on hold. The 2022 annual report says Commissioners Court "continues to move forward" with the project, and there is no mention of any changes in scope. The HB 203 report lists $226 million in expenditures for 2023-2026, which is consistent with the cost of completing the main lanes.
HCTRA's annual reports are on an unconventional fiscal year from March 1 to Feb 28/29. In January 2021, Commissioners Court approved changing to a fiscal year ending on September 30. The period from March 1 to September 30, 2022, was a transitional seven-month fiscal year, and on October 1 the first 12-month fiscal year on the new schedule began.

Labels: ,

Monday, September 19, 2022

Spiraling admin costs + strong toll revenue recovery at HCTRA

(This week we have part 1 of 2 always-excellent blog posts by guest author Oscar Slotboom)
The Harris County Toll Road Authority recently posted its annual report for the 2022 fiscal year, which ended February 28. Of course, fiscal year 2021 (plotted as year 2020 in the charts) was heavily impacted by Covid, with revenue down 35.5%.
Anyone who drives the toll roads (including me) knows that the traffic recovery has been strong. Toll revenue rebounded to $808.9 million, 5.4% below the $855 million peak in 2019 and 13.7% below the peak using inflation-adjusted dollars.
The Katy Managed Lanes had a very strong revenue recovery from 2020's $8.9 million, posting $18.6 million in revenue, which is 17% below the 2018 peak in actual dollars and 26% below 2018 using inflation-adjusted dollars.
However, if you look at Schedule 1 on page 53 and schedule 5 on page 57, you'll see that 10 of 14 toll system segments showed a higher traffic count and higher revenue in 2022 (2021 in the charts) compared to 2020 (2019 in the charts), including a new record high for any segment in a year, $129 million on the Sam Houston Tollway North (US 290 to IH-45 North). The four segments with lower revenue were only slightly down. So why is overall toll revenue 5.4% below 2020?
The answer: A massive increase in administration cost.
Administration costs sustained a $109.9 million dollar swing from 2019 to 2021, going from a positive (i.e. revenue-increasing) $42.3 million in 2019, to -$33.2 million (revenue-decreasing) in 2020 and then to -$67.2 million in 2021. (reference schedule 5 on page 57).
If administration costs are removed from toll revenue, we can see that 2021 had record revenue of $876.1 million, 7.8% above 2019's $812.5 million, although still 2.7% below the 2018 peak using inflation-adjusted dollars.
So what is the cause of this massive increase in administration cost? There is no explanation in the 2022 annual report. The only clues we can gather are from the notes attached to the administration line item. In the 2020 annual report page 62 (corresponding to year 2019 in the chart), when administration was still a substantial positive on the bottom line, the note is
Consist of EZ tag sales fees, toll violation (VEC) revenue (excluding tolls), net of an allowance for uncollectible accounts, reimbursements to patrons for overpaid toll(s), collector/vault adjustments, and other miscellaneous revenues.
The note for 2020 and 2021 says
During the COVID-19 emergency declaration, administrative fees associated to violations were waived and no related revenue was generated. This line consists of allowance for uncollectible accounts on toll violation (VEC) revenue administrative fees (excluding tolls), EZ tag sales fees, and other miscellaneous revenues.
This prompts the following questions in my mind:
Why are we seeing a $34 million increase in administration cost in 2021 compared to 2020?
Covid-related financial impacts should have been recognized in 2020, since that's when the covid "emergency" occurred. Does 2021 include deferred recognition of losses incurred in 2020?
Should we expect administration to return to revenue-increasing status with the current fiscal year, since Covid is no longer a factor?
Is HCTRA no longer attempting to collect unpaid tolls?
Does lower operational efficiency for traditional billing tasks have any influence on this high administration cost?
Total headcount at HCTRA decreased from a peak of 1181 in Feb. 2000 to 890 in Feb. 2022, as we would expect with the end of manual toll collection. It seems like the end of manual toll collection should lower administrative cost.
In part 2 we take a closer look at toll diversions and the cost of converting the HCTRA system to be 100% electronic tolling.

Labels: ,

Wednesday, September 14, 2022

Countering the “Freeway Fighters”

I'm back from taking a summer break from the blog with a quick re-publishing of a great piece by Bob Poole from Reason's Surface Transportation Newsletter. I'm hoping to get back into regular weekly posts again, or something close to it. This piece gets at a growing dangerous anti-freeway movement in America which will have many negative ramifications for the economies of metro areas. Not only will the poor be unable to afford to live in the areas with jobs (already the case in many metros), but they will also no longer be able to commute to them either as freeways get removed. I predict it will be seen as another in a long string of faddish urban planning failures right up there with "slum clearance" (destroyed vibrant working class neighborhoods) and "smart growth" (destroyed housing affordability).


An anti-highway group called last month released “10 Recommendations for Freeway Fighters,” described as answering the need for ammunition by those working on “the relocation or removal of highways in American cities.” Author Jay Arzu provides brief descriptions of the 10 points, which I summarize here so that state transportation departments and other members of the highway community can know what may be coming at them.

  1. Rule #1: “Highway-to-boulevard projects should focus on neighborhood reconnection and reinvestment for current residents of the area,” Arzu writes. This seems to assume that the current residents are the same ones there when the freeway was built 40 years ago; it is mainly an argument against “gentrification”—i.e., keeping the residents in place rather than offering them buyouts so that economic development can occur (assuming the freeway is actually removed).
  2. Rule #2: “Any plan to remove a highway must include the input of local residents, and must employ Diversity, Equity, and Inclusion in design, implementation, and construction,” StrongTowns says. DEI is the current buzzword used by some for social planning, rather than letting residents make their own decisions on what is best for them. He also recommends letting a social-activist group speak for all the residents, rather than finding out what individuals, families, and business owners prefer.
  3. Rule #3: “Traffic data will always be used as an excuse for why a highway shouldn’t be removed,” says Arzu. As if disrupting urban area travel patterns would have no impact on thousands or millions of other people? And commercial vehicles?
  4. Rule 4: “Trust your city’s street grid.” Street grids can increase or restrict mobility depending on how they are configured and managed. There is nothing inherently better in whatever the current grid happens to be.
  5. Rule 5: “Create visuals/renderings showcasing the opportunities for your city if the highway was [sic] removed.” Pretty pictures are designed to be persuasive, but they may not reflect what is actually doable or affordable.
  6. Rule 6: “When you remove a highway, traffic will not come!” This is a mantra of the Congress for a New Urbanism, and the historic examples it cites are not removals of entire freeways but tear-downs of stubs of freeways that were never completed (e.g. the stub of Central Freeway in San Francisco and the stub of the Park Freeway in Milwaukee). Those making this argument—that if you remove capacity the traffic will disappear—also argue that the “iron law of freeway congestion” says that if you add lanes, they will quickly fill up and be congested. Neither is generally true, and one claim contradicts the other.
  7. Rule 7: “Get the development community on your side.” In this telling, developers are the friends of teardowns. Yet most developers want to build profitable projects (i.e., gentrify under-developed areas).
  8. Rule 8. “Land trusts/banks are a huge asset.” Land trusts and land banks require financial and development expertise that is unlikely to be present in “community-based organizations.” And what is left out of this recommendation is the owners of the properties in the relevant area, who probably don’t want their properties turned over to a land trust or land bank.
  9. Rule 9: “In the long term, take control of MPOs and DOTs.” Well, MPOs and DOTs, don’t say you weren’t warned!
  10. Rule 10: “No highway is permanent!” True, highways wear out and need to be rebuilt, the same as bridges, water and sewer systems, etc. His example of the removal of Harbor Drive in Portland is highly misleading since it was replaced by brand new I-5, which runs parallel to former Harbor Drive, which was turned into Waterfront Park.


Tuesday, August 02, 2022

Metro needs to rethink the University Line

In 2019 Metro convinced 68% of voters to support their $7.5B MetroNEXT plan, which I also cautiously supported. Since then we've had a global pandemic and the rise of remote work along with a transit ridership crash and anemic recovery, so Metro is stepping back to rethink everything... 

Just kidding! Nope, they're plowing right ahead like nothing happened in the last three years, currently focused on the Universities Line.

I have to give them credit for switching it from crazy-expensive light rail to just plain expensive bus rapid transit (BRT) for the referendum, but now the ugly rubber is meeting the pothole-patched road as they transition from nice lines on a map to actual detailed planning, and a hornet's nest of opposition is stirring up:

“The experience of Metro projects is that they carry the same number of riders,” said Neal Meyer, 56, a critic of the agency who has written skeptically of transit plans for years. “They’re not worth it.” ...

“I really don’t know if there is any real strategy that can be implemented that will attract more people to take transit,” he said. “For the whole project and all the mega-projects that they want us to pay for, I just have serious doubts.”

It is the same skepticism raised when Metro expanded its light rail lines. Extending the Red Line trains north and building the Green and Purple Lines took Metro more than six years and $2.1 billion. Along the Purple Line, officials at the time they applied for $450 million in federal funds estimated the route would carry 28,800 riders daily by 2030. Its highest average daily ridership, in October 2019, was 7,581. Currently it is about 3,550. ...

Even where faster, more reliable transit is welcomed, however, the project’s specifics will weigh heavily on neighbors who have seen Metro’s light rail lines gobble homes and green space, cripple businesses through years of street-choking construction and frustrate residents living in a work zone.

Plans for the University Line rely on dedicated bus lanes past Texas Southern University, along Ennis from Elgin to Blodgett through Third Ward. Now a cracked and uneven four-lane street, renderings prepared by Metro show Ennis at Wheeler with six lanes — including the two bus lanes — and wide sidewalks with painted crosswalks.

What it fails to show is where that extra space is going to come from.

“It is pretty, but it is not accurate,” said state Rep. Jolanda Jones, a Houston Democrat whose family has been in the area for decades. “They are going to take homes and that is not going to happen. Not if I have anything to do with it.” ...

Other neighborhoods have similar concerns, though the likelihood of losing homes is more concentrated in certain areas, including Third Ward and the East End. Along Richmond, business and property owners who lived through the fight over light rail along the avenue 15 years ago are mobilizing again. Daphne Scarborough, a long-time Metro critic who fought the light rail plans, said the buses are not much different and will cause problems for traffic where Richmond is narrowed to one lane east of Shepherd.

It's that last point on Richmond getting narrowed to one lane each direction that really concerns me. Given the constraints and bottlenecks on Westheimer, W. Alabama, and Bissonet, Richmond is the only surface street with significant east-west capacity from Upper Kirby to Montrose and Midtown - it absolutely needs to keep a *minimum* of two general traffic lanes each direction all the way through. As more people and businesses find out about the one-lane plan, I expect opposition to continue to mount. 

Even the Chronicle Editorial Board felt the need to acknowledge the critics and rally support for Metro:

And yet the promise of the University Line hasn’t swayed its consistent critics. The Chronicle’s Dug Begley reported last week that many transit opponents are raising a stink that Metro system’s relatively modest ridership has failed to justify the project’s high cost. They worry that construction of the University Line will snarl traffic, invite unwelcome development and cripple local businesses.

What neither Metro nor the Chronicle mention is that at a 10mph average speed this route will take *more than two hours* to ride end-to-end over 25 miles and 40 stops! I base that on the Post Oak Silver BRT line taking a half-hour to go 5 miles with 10 stops, so 4-5x that. Will people really ride that? And is it much time savings vs. existing bus routes?

What's my suggestion? Given the disruption and cost involved, as well as changes around remote work and autonomous Ubers, it would be better for the University Line to start as an express Quickline service *without* dedicated lanes to see if it can build ridership before spending $1.5 billion (easily $2 billion with inflation) on a BRT. Frequent Quickline service would be a relatively easy, cheap test without the disruption and lost lanes. It would also allow experimentation with the exact route and stops to find the best mix *before* sealing it in concrete. If it proves to be popular with growing ridership justifying more capacity, *then* let's revisit the possibility of upgrading it to BRT. By then we'll also have a lot more clarity on the future of remote work and autonomous taxis so we don't build another underutilized white elephant just like the Green, Purple, and Silver Lines. How about it Metro?

Labels: , , ,

Tuesday, July 26, 2022

Houston #1 standard of living globally, HTX vs LA, 713 Day video, NYT on Houston's homeless success, and more

I'm back in town clearing out a backlog of smaller items:

“Knowledge workers like me, who move out of the city, make urban spaces more affordable for essential workers who staff hospitals and restaurants. Meanwhile, small towns and cities that were hollowed out by deindustrialization over the last 30 years get an influx of new residents to support their tax base. Again, the majority of jobs don’t allow for remote work, but a great deal of wealth is concentrated among the jobs that do. Empowering or even encouraging those workers to live wherever they want could have a positive impact on the affordability of cities and the economic health of rural communities.”
Finally, a short funny video well worth your time on Houston vs. LA. It's awesome and actually well-balanced. Matches my experience with CA vs. TX (and particularly Houston) as well. My blog readers will particularly appreciate the 3:55 (traffic) and 16:19 points (feeders) ;-) but I really appreciated the point about the purple political diversity. Hat tip to George.

Labels: , , , , , , , , , ,

Tuesday, July 12, 2022

New book: Houston as the bold case against zoning

This week we have excerpts from an excellent Fast Company article: A bold case against zoning - In a new book, M. Nolan Gray cites Houston as a model for rethinking zoning. These excerpts are great, but I highly recommend reading the whole thing, and even the book if you can!


"When the zoned American lands in Houston, they are liable to be struck by parking lots reinventing themselves as apartment buildings, by postwar subdivisions transforming into dense new townhouse districts, by old strip malls being reimagined as new satellite business districts. In the zoned city, any one of these developments would be a major ordeal, the subject of endless permitting and raucous public hearings—in Houston, it just happens.
Thanks in part to a lack of zoning, Houston builds housing at nearly three times the per capita rate of cities like New York City and San Jose. It isn’t all just sprawl either: In 2019, Houston built roughly the same number of apartments as Los Angeles, despite the latter being nearly twice as large. This ongoing supernova of housing construction has helped to keep Houston one of the most affordable big cities in the U.S., offering new arrivals modest rents and accessible home prices even amid seemingly endless demand.
Zoning critics rightly dispensed with the comforting myths surrounding zoning—that its purpose was to merely rationalize land use—and zeroed in on its tendency to restrict new housing construction, limit access to opportunity, institutionalize segregation, and force growth outward. Far from being duped, Houston’s working-class residents exhibited a subtler understanding of the purposes of zoning than many contemporary planners and rejected it accordingly.
Is this system of publicly enforced deed restrictions “basically zoning,” as some might argue? On the one hand, deed restrictions—like zoning—demarcate specified areas subject to a distinct set of stricter land-use rules. Both zoning and deed restrictions in Houston are enforced by the government, principally with the aim of propping up home values and maintaining a certain quality of life. Many deed restrictions even have rules banning apartments and enforcing a strict two-and-a-half-story height limit.
Yet, the similarities end there, and Houston’s system of deed restrictions is a significant improvement over zoning. For starters, deed restrictions only cover an estimated quarter of the city, largely in areas with low-rise, detached, single-family housing. Industrial areas, commercial corridors, mixed-use and multifamily neighborhoods, urban vacant lots, and yet-to-be-developed greenfields are virtually never subject to their provisions. This means that roughly three-quarters of Houston—including its more dynamic sections—are largely free to grow without anything even resembling zoning holding them back."

Labels: , , , , , ,