CAN LOBBYIST MONEY BUY CONTROL OF SANTA MONICA LAND?

Voters face a key question in the competing ballot measures dealing with
Santa Monica Airport, a question not actually in the measures. The answer
could set a precedent.“Can lobbyist money essentially buy city-owned land
that the city and its residents don’t want to sell?”

The question arises from the massive amount of money raised by aviation
lobbies and businesses backing Measure D — $872,299 (so far).

That’s more than all other funding for local measures and candidates com-
bined. Why so much? To take control of city-owned airport land and cont-
inue pushing to make SMO a true jetport. The aviation interests are, in
a word, developers.

By contrast, Measure LC (for Local Control) has been funded locally by
residents, and would block high-density development at SMO if aviation
activity were curtailed. That’s why LC has won the endorsements of –
among other organizations – the Sierra Club, the League of Women Voters
of Santa Monica, the Residocracy advisory board, Santa Monica Coalition
for a Livable City, Los Angeles League of Conservation Voters and Santa
Monica-Malibu Council of PTAs. Nearly every Council candidate, incumbent
or challenger, is in the Yes on LC (and no on D) camp.

Measure D would block the city from administering its own property. The
city would be barred from raising the rent on its leases to aviation
businesses, which expire next year and have been below market rates for
decades. Even more important, the city could not modify the use of land
now leased by aviation businesses, even to make SMO safer or less pollut-
ing. Any such change would require approval by a majority of city voters,
creating a micro-management nightmare.

By comparison, Measure LC would keep regulation of the airport land in the
hands of its citizen-owners and their elected officials. It would guaran-
tee only low-density uses such as parks, playing fields, recreational areas
and cultural/educational facilities on the land (including those currently
in place) IF aviation activity were reduced or eliminated. The City Council
could not change that; only voters could.

By voting Yes on LC and No on D, voters have a chance NOW to ensure that
their land will remain under their regulatory care, not under that of out-
siders whose money buys scare-tactic ads and glitzy mailers.

FOR MORE INFORMATION go to ItsOurLand.org

=

ARCHITECT QUESTIONS INTEGRITY OF DESIGN AND PROCESS

RON Goldman, FAIA
subject: Millennium East Village

I am objecting to the Planning Director’s D.A. Memorandum of June 25, 2014,
where project revisions are accepted as “minor modifications” instead of
“major modifications.” The Development Agreement of March 19, 2013, section
2.4.3, defines “Major Modification” and includes the following 4 criteria:

2.4.3 a) “Reduction of any setback of the Project, as depicted on the
Project Plans, if by such reduction the applicable setback would be less
than is permitted in the applicable zoning district under the zoning
ordinance in effect on the date such modification is applied for by more
than twenty percent (20%) of the dimension of such setback.”

This project does NOT “continue to be respectful of the Colorado frontage
with stepbacks that are 236% more than the approved development” as the
developers’ attorneys suggest. 63% of the buildable width encroaches 43%
beyond code at the upper levels. And the overall development represents a substantial increase in scale from the neighbors and the public perspective
and is substantially short of the Bergamot Specific Plan requirements for
the Mixed Use Creative District. This design constitutes a major re-int-
erpretation of the previous approved plan and code and fails in “preserv-
ing the sensitive transition from the project to the adjacent neighbor-
hood” as called for in the code.

2.4.3 d) “Any reduction in the number of Affordable Units that are part
of the Rental Housing Units.”

41 Affordable Units were agreed upon in the original approved design, this
number was increased to 51 and agreed upon at the subsequent Rent Control
Board hearing, and only 38 are urrently in the modified D.A.

And Affordable Units are required to be “evenly distributed throughout the
project,” but all are now located in building C at the end of the site.
2.4.3 i) “Any variation in the design, massing or building configura-
tion, including but not limited to, floor area and building height,that
renders such aspects out of substantial compliance with the Project Plans
after ARB approval.”

The massing and building configurations have changed signif-icantly. Build-
ing heights have increased within the setback area on Colorado, with the
37% increase in height looming over and casting winter shadows across the
street.

The 57 foot building height on Colorado facing 1 and 2 story houses subs-
tantially increases the sense of height and scale, irregardless of the
“porosity” of the design. And the height and scale depicted in the street perspective is overwhelming at 40 feet above sidewalk level, and imagine
how much more this would loom over you at street level.

And building B on the New Road has increased 58% in length from 170’ to
400’ and grown from 4 stories to 5!

And the staff report suggests “the design provides skyline variation with
maximum heights pushed toward the middle and gradual reduction on edges”
which is totally unrealized!

2.4.3 j) “Any change that would materially reduce the community bene-
fits as set forth in Section 2.6. 2.6 includes significant project feat-
ures and LUCE community benefits.”

The 5th goal of LUCE Community benefits states “does the project adversely
impact or enhance the current or future open space and community gathering
space?”

Uncovered open space has been reduced by 29% and the resulting width of
courtyards are slot-like, canyon-like spaces with landscape and childrens’
play areas in shadow most, if not all day. The largest of the open court-
yards has 50% of its length measuring to 30-22 feet wide while over 57
feet high. And I don’t know of any definition of open space in any munic-
ipal code that is not open to the sky. And the public outdoor park at the
corner of New Road and Pennsylvania, specifically added by the Planning
Commission is now covered space with the open space moved eeasterly on Pennsylvania and contained within building B.

Of the 5 priority categories of Community benefits in the LUCE, #3 is
“Community Physical Improvements … additional ground level open space,
trees …”

Again, open space, landscape, and sunlight have all been reduced by 29%!

And moreover, emergency access to the large interior courtyard is part-
ially covered, and exceeds distance and code standards.

Ron Goldman FAIA
email to ARB
subject – ARB purpose and scope

ARB Members,

In light of the history and process of the Village Trailer Park/East
Village projects, I would like to remind the ARB of the scope and pur-
pose you serve for the city as stated in the municipal code chapter est-
ablishing the ARB – section 9.32.010.

“The purpose of this Chapter is to promote the public health, safety and
general welfare by establishing such procedures and providing such regu-
lations as are deemed necessary to preserve existing areas of natural
beauty, cultural importance; to assure that buildings, structures, signs
or other developments are in good taste, good design, harmonious with
surrounding developments and in general contribute to the preservation
of Santa Monica’s reputation as a place of beauty, spaciousness and
quality; to prevent the development of structures or uses which are not
of acceptable exterior design or appearance, are of inferior quality or
likely to have a depreciating effect on the local environment or sur-
rounding area by reason of appearance or value: to eliminate conditions,
structures, signs or uses which by reason of their effect tend to degrade
the health, safety or general welfare of the community; and provide a

continuing source of programs and means of improving the City’s overall
appearance.”

Will Santa Monica retain its “reputation as a place of beauty, spaciousness,
and quality” if this massive project is approved? Where is the beauty,
where is the spaciousness, where is the quality? How can one make these
findings?? And no permits may issue unless you make these findings and
approve this design!

“Unless plans, elevations, landscaping and proposed signs for building or
structures or alterations thereto have been approved by the Board or on
appeal by the Commission, no building permit shall be issued for any build-
ing, structure or other development of property or appurtenances thereto,
on any property situated in an established architectural review district,
except that the Board under authority of Section 9.32.070 of this Chapter,
may, by resolution, authorize the building officer or other official to
approve applications for building permits for minor or insignificant devel-
opment of property which would not defeat the purposes and objectives of
this chapter…”(9.32.120).

Ultimate power resides in the Board to reject designs under the criterion
set forth in Section 9.32.140, although it may be rarely exercised after
the City Council has given its blessing to the project:”

9.32.140 Criteria.

“The Board may approve, approve with conditions, or disapprove the issuance
of a building permit in any matter subject to its jurisdiction after consider-
ation of whether the following criteria are complied with:

a. The plan for the proposed building or structure is expressive
of good taste, good design, and in general contributes to the image of Santa
Monica as a place of beauty, creativity and individuality. [DOES THIS PRO-
JECT MEET THESE CRITERIA?]

b. The proposed building or structure is not of inferior quality
such as to cause the nature of the local neighborhood or environment to mat-
erially depreciate in appearance and value. [QUERY, ARE YOU RIGHT ABOUT THIS
OR WILL THE SURROUNDING NEIGHBORHOOD INCREASE IN VALUE?]

c. The proposed design of the building or structure is compatible
with developments on land in the general area. [IS A BUILDING THAT AKES AWAY
YOUR SUNLIGHT FROM ACROSS THE STREET COMPATIBLE WITH SINGLR FAMILY DEVELOP-
MENTS ALREADY IN EXISTENCE?]

d. The proposed development is in conformity with the effective
guidelines and standards adopted pursuant to this chapter and all other
applicable ordinances insofar as the location and appearance of the build-
ings and structures are involved.

If the Board finds that the above criteria are complied with, the appli-
cation shall be approved Conditions may be imposed when the proposed building
or structure does not comply with the above criteria and shall be such to
bring such building or structure into conformity therewith. If an applica-
tion is disapproved, the Board shall detail in its findings the criteria
which are not complied with or the guidelines which are violated, or both.
Any action taken by the Board in regard to a proposed development shall
include findings, and be reduced to writing, signed by the Chairman, and a
copy thereof shall be given to the applicant, in person, or by United States
mail, upon request.

A decision or order of the Board shall not become effective until the
expiration of ten (10) days after the date upon which a ruling has been
made.

The criteria established herein may be changed, from time to time, by
ordinance, upon request of the Board, or upon motion of the City Council.
(Prior code § 9512; added by Ord. No. 959CCS, adopted 7/9/74; amended by
Ord. No. 1003CCS, adopted 7/8/75).”

You have a duty to fulfill this “purpose” cited above and withhold approval
if the project does not meet your criteria for this neighborhood or for the
community of Santa Monica in general.

“The Zoning Administrator may grant an adjustment from the requirements
of this Chapter to:

(a) Allow modification of parcel coverage regulations by up to five
percent of the total lot area for additions to existing structures;

(b) Allow modification of the number of required parking spaces by
up to one percent of the number of required spaces;

(c) Allow the modification of fence heights by up to one foot;

(d) Allow the modification of side yard setback requirements by up
to six inches, but in no case resulting in a setback of less than four feet;

(e) Allow the modification of building heights by up to six inches
on parcels which have a grade differential of five feet or more, as measured
from either any point on the front parcel line to any point on the rear
parcel line, or from any point on a side parcel line to any point on the
opposing side parcel line;

(f) Allow a garage accessory building to extend up to the rear prop-
erty line of the parcel on which it is located where otherwise prohibited;

(g) Allow a building to retain nonconforming setbacks when substant-
ially remodeled provided all of the following criteria are met:

(1) The nonconformity of the setback(s) and building may not be in-
creased,

(2) At least thirty-five percent of the exterior walls of the build-
ing subject to the adjustment shall remain as defined in Section 9.04.02.030,

(3) There has been no prior addition under this Section;

(h) Allow a building to retain nonconforming setbacks when substant-
ially remodeled provided that the applicant demonstrates that all of the
following criteria are met:

(1) The exterior walls are required to be replaced due to concealed
structural damage caused by dry rot, termites, or other factors,

(2) The structural damage was unforeseeable through reasonable due
diligence prior to the issuance of a building permit for the alteration or
addition,

(3) The structural damage was only discovered during the course of construction,

(4) The structural damage was verified after inspection by the
Building Officer or designee, while the damaged exterior walls are still
in place, and

The criteria established by this subsection (h) shall be in lieu of
the findings otherwise required by Section 9.04.20.34.060. (Prior code
§ 9152.3; added by Ord. No. 1612CCS § 7, adopted 1/14/92; amended by Ord.
No. 1664CCS § 1, adopted 1/26/93; Ord. No. 1826CCS § 2, adopted 11/7/95;
and Ord. No. 2278CCS § 3, 11/25/08)

The Development Agreement recites (page 38, section 6.1) that the Council’s
approval is “subject to” ARB review and approval in accordance with exist-
ing regulations. Please don’t let others usurp your power by telling you
this is not within your purview – because it definitely is! Please take
your position and power accordingly and make your decision based on these
larger issues.

The code allows the Z.A. or planning director to make these changes as
“minor changes.” What we have here goes way beyond that – in other words,
they are major and should be reviewed as such. You are being asked to
correct the planning director’s errors in his saying these are minor changes.
It is his errors and your obligation to correct them and not give your
final approval to these plans.

It is my strong belief that this project will have a depreciating effect
both environmentally and economically on the surrounding residents. And
it is your right and core duty, in addition to merely passing on exterior
colors, textures and landscape to direct this applicant to take the best
elements of both designs and reprocess a project that is truly represent-
ative of Santa Monica’s “beauty, spaciousness, and quality.”

Ron Goldman FAIA
email to ARB
subject: ARB final thoughts

ARB Members,

In addition to the material I previously sent, the point I would add,
from my experience in designing over 10,000 multi-family units for dev-
elopers, is this developer has paid conservatively $600,000 – 750,000
and realistically well over $1 million to quote “modify” this project.

Does this expense seem minor to you when he simply could have deleted
10 of the 15 omitted units and solved your principal concern by break-
ing the long U-shaped A building in two?

Yes, 45% of the units are now single loaded, but the east elevation
of building A remains 360’ long, 20% more than the length of a football
field. The west elevation of building B has grown from 170’ to 400’
as well as matured in height from 4 floors to 5.

And height along Colorado has grown from an adolescent 36’ to a robust
57’, while true open space, open to the sky, has been reduced 29%. And
don’t forget, the primary open space requested by the Planning Commiss-
ion at the intersection of the 2 new public roads unfortunately has been
covered over.

And the 51 affordable units agreed to at the Rent Control Board is now
38! And economic value of the adjacent residential area will likewise
be reduced!

The Planning Director is saying that four large TV screens staring at
you on Colorado, massive buildings defining the perimeters, and dark
canyons in substantially reduced interior courtyards are minor?!.

Is this really what you’re willing to approve? Are city commissions
and departments becoming the unpaid staff of developers? It’s within
your domain to stand up to this challenge.

subject: Millennium East Village

I am objecting to the Planning Director’s D.A. Memorandum of June 25,
2014, where project revisions are accepted as “minor modifications”
instead of “major modifications.” The Development Agreement of March
19, 2013, section 2.4.3, defines “Major Modification” and includes
the following 4 criteria:

2.4.3 a) “Reduction of any setback of the Project, as depicted
on the Project Plans, if by such reduction the applicable setback
would be less than is permitted in the applicable zoning district
under the zoning ordinance in effect on the date such modification
is applied for by more than twenty percent (20%) of the dimension
of such setback.”

This project does NOT “continue to be respectful of
the Colorado frontage with stepbacks that are 236% more than the ap-
proved development” as the developers’ attorneys suggest. 63% of
the buildable width encroaches 43% beyond code at the upper levels.
And the overall development represents a substantial increase in
scale from the neighbors and the public perspective and is substan-
tially short of the Bergamot Specific Plan requirements for the Mixed
Use Creative District. This design constitutes a major re-interpret-
ation of the previous approved plan and code and fails in “preserv-
ing the sensitive transition from the project to the adjacent neigh-
borhood” as called for in the code.

2.4.3 d) “Any reduction in the number of Affordable Units that
are part of the Rental Housing Units.”

41 Affordable Units were agreed upon in the original
approved design, this number was increased to 51 and agreed upon at
the subsequent Rent Control Board hearing, and only 38 are currently
in the modified D.A.

And Affordable Units are required to be “evenly dis-
tributed throughout the project,” but all are now located in build-
ing C at the end of the site.

2.4.3 i) “Any variation in the design, massing or building con-
figuration, including but not limited to, floor area and building
height, that renders such aspects out of substantial compliance with
the Project Plans after ARB approval.”

The massing and building configurations have changed sig-
nificantly. Building heights have increased within the set-
back area on Colorado, with the 37% increase in height looming over and casting winter shadows across the street.

The 57 foot building height on Colorado facing 1 and 2
story houses substantially increases the sense of height and scale,
irregardless of the “porosity” of the design. And the height and scale depicted in the street perspective is overwhelming at 40 feet above
sidewalk level, and imagine how much more this would loom over you at
street level.

And building B on the New Road has increased 58% in length
from 170’ to 400’ and grown from 4 stories to 5!

And the staff report suggests “the design provides skyline
variation with maximum heights pushed toward the middle and gradual
reduction on edges” which is totally unrealized!

2.4.3 j) “Any change that would materially reduce the community
benefits as set forth in Section 2.6.
2.6 includes significant project features and LUCE community benefits.”

· The 5th goal of LUCE Community benefits states “does the
project adversely impact or enhance the current or future open space
and community gathering space?”

Uncovered open space has been reduced by 29% and the result-
ing width of courtyards are slot-like, canyon like spaces with land-
scape and childrens’ play areas in shadow most if not all day.
The largest of the open courtyards has 50% of it’s length measuring
10-22 feet wide while over 57 feet high. And I don’t know of any
definition of open space in any municipal code that is not open to
the sky. And the public outdoor park ar the orner of New Road and
Pennsylvania, specifically added by the Planning Commission, is now
covered space with the open space moved easterly on Pennsylvania
and contained within building B.

· Of the 5 priority categories of Community benefits in the LUCE,
#3 is “Community Physical Improvements … additional ground level open
space, trees …”

Again, open space, landscape, and sunlight have all been reduced
by 29%! And moreover, emergency access to the large interior courtyard
is partially covered, and exceeds distance and code standards.

Ron Goldman FAIA
email to ARB
subject – ARB purpose and scope
ARB Members,

In light of the history and process of the Village Trailer Park/East
Village projects, I would like to remind the ARB of the scope and purpose
you serve for the city as stated in the municipal code chapter establish-
ing the ARB – section 9.32.010.

“The purpose of this Chapter is to promote the public health, safety and
general welfare by establishing such procedures and providing such regula-
tions as are deemed necessary to preserve existing areas of natural beauty,
cultural importance; to assure that buildings, structures, signs or other developments are in good taste, good design, harmonious with surrounding
developments and in general contribute to the preservation of Santa Monica’s reputation as a place of beauty, spaciousness and quality; to prevent the
development of structures or uses which are not of acceptable exterior
design or appearance, are of inferior quality or likely to have a depreciat-
ing effect on the local environment or surrounding area by reason of app-
earance or value: to eliminate conditions, structures, signs or uses which
by reason of their effect tend to degrade the health, safety or general
welfare of the community; and provide a continuing source of programs and
means of improving the City’s overall appearance.”

Will Santa Monica retain its “reputation as a place of beauty, spaciousness,
and quality” if this massive project is approved? Where is the beauty,
where is the spaciousness, where is the quality? How can one make these
findings?? And no permits may issue unless you make these findings and
approve this design!

“Unless plans, elevations, landscaping and proposed signs for building or
structures or alterations thereto have been approved by the Board or on
appeal by the Commission, no building permit shall be issued for any build-
ing, structure or other development of property or appurtenances thereto, on
any property situated in an established architectural review district, ex-
cept that the Board under authority of Section 9.32.070 of this Chapter, may,
by resolution, authorize the building officer or other official to approve applications for building permits for minor or insignificant development of
property which would not defeat the purposes and objectives of this chapter…”(9.32.120).

“Ultimate power resides in the Board to reject designs under the criterion
set forth in Section 9.32.140, although it may be rarely exercised after the
City Council has given its blessing to the project:”

9.32.140 Criteria.

“The Board may approve, approve with conditions, or disapprove the
issuance of a building permit in any matter subject to its jurisdiction
after consideration of whether the following criteria are complied with:

a. The plan for the proposed building or structure is expressive
of good taste, good design, and in general contributes to the image of Santa
Monica as a place of beauty, creativity and individuality. [DOES THIS
PROJECT MEET THESE CRITERIA?]

b. The proposed building or structure is not of inferior quality
such as to cause the nature of the local neighborhood or environment to
materially depreciate in appearance and value. [QUERY, ARE YOU RIGHT ABOUT
THIS, OR WILL THE SURROUNDING NEIGHBORHOOD INCREASE IN VALUE?]

c. The proposed design of the building or structure is compatible
with developments on land in the general area. [IS A BUILDING THAT AKES
AWAY YOUR SUNLIGHT FROM ACROSS THE STREET COMPATIBLE WITH SINGLR FAMILY
DEVELOPMENTS ALREADY IN EXISTENCE?]

d. The proposed development is in conformity with the effective
guidelines and standards adopted pursuant to this chapter and all other
applicable ordinances insofar as the location and appearance of the build-
ings and structures are involved.

If the Board finds that the above criteria are complied with, the ap-
plication shall be approved Conditions may be imposed when the proposed
building or structure does not comply with the above criteria and shall be
such to bring such building or structure into conformity therewith. If an
application is disapproved, the Board shall detail in its findings the cri-
teria which are not complied with or the guidelines which are violated, or
both. Any action taken by the Board in regard to a proposed development
shall include findings, and be reduced to writing, signed by the Chairman,
and a copy thereof shall be given to the applicant, in person, or by United
States mail, upon request.

A decision or order of the Board shall not become effective until the
expiration of ten (10) days after the date upon which a ruling has been
made.

The criteria established herein may be changed, from time to time, by
ordinance, upon request of the Board, or upon motion of the City Council.
(Prior code § 9512; added by Ord. No. 959CCS, adopted 7/9/74; amended by
Ord. No. 1003CCS, adopted 7/8/75).”

You have a duty to fulfill this “purpose” cited above and withhold approval
if the project does not meet your criteria for this neighborhood or for the community of Santa Monica in general.

“The Zoning Administrator may grant an adjustment from the requirements
of this Chapter to:(a) Allow modification of parcel coverage regulations
by up to five percent of the total lot area for additions to existing struc-
tures; (b) Allow modification of the number of required parking spaces
by up to one percent of the number of required spaces;(c) Allow the modi-
fication of fence heights by up to one foot; (d) Allow the modification of
side yard setback requirements by up to six inches, but in no case resulting
in a setback of less than four feet; (e) Allow the modification of building
heights by up to six inches on parcels which have a grade differential of
five feet or more, as measured from either any point on the front parcel
line to any point on the rear parcel line, or from any point on a side par-
cel line to any point on the opposing side parcel line;(f) Allow a garage
accessory building to extend up to the rear property line of the parcel
on which it is located where otherwise prohibited; (g) Allow a building
to retain nonconforming setbacks when substantially remodeled provided all
of the following criteria are met: (1) The nonconformity of the set
back(s) and building may not be increased, (2) At least thirty-five per-
cent of the exterior walls of the building subject to the adjustment shall
remain as defined in Section 9.04.02.030,(3) There has been no prior ad-
dition under this Section;

(h) Allow a building to retain nonconforming setbacks when substantially
remodeled provided that the applicant demonstrates that all of the following
criteria are met:(1) The exterior walls are required to be replaced due to concealed structural damage caused by dry rot, termites, or other factors,
(2) The structural damage was unforeseeable through reasonable due dili-
gence prior to the issuance of a building permit for the alteration or add-
ition,

(3) The structural damage was only discovered during the course of construction,

(4) The structural damage was verified after inspection by the Build-
ing Officer or designee, while the damaged exterior walls are still in place,
and

The criteria established by this subsection (h) shall be in lieu of
the findings otherwise required by Section 9.04.20.34.060. (Prior code §
9152.3; added by Ord. No. 1612CCS § 7, adopted 1/14/92; amended by Ord. No.
1664CCS § 1, adopted 1/26/93; Ord. No. 1826CCS § 2, adopted 11/7/95; and Ord.
No. 2278CCS § 3, 11/25/08)

The Development Agreement recites (page 38, section 6.1) that the Council’s
approval is “subject to” ARB review and approval in accordance with existing regulations. Please don’t let others usurp your power by telling you this is
not within your purview – because it definitely is! Please take your posit
ion and power accordingly and make your decision based on these larger issues.

The code allows the Z.A. or planning director to make these changes as “minor changes.” What we have here goes way beyond that – in other words, they are
major and should be reviewed as such. You are being asked to correct the
planning director’s errors in his saying these are minor changes. It is his
errors and your obligation to correct them and not give your final approval
to these plans.

It is my strong belief that this project will have a depreciating effect both environmentally and economically on the surrounding residents. And it is your
right and core duty, in addition to merely passing on exterior colors, text-
ures and landscape to direct this applicant to take the best elements of both
designs and reprocess a project that is truly representative of Santa Monica’s “beauty, spaciousness, and quality.”

Ron Goldman FAIA
email to ARB
subject: ARB final thoughts
ARB Members,

In addition to the material I previously sent, the point I would add, from my experience in designing over 10,000 multi-family units for developers, is
this developer has paid conservatively $600,000 – 750,000 and realistically
well over $1 million to quote “modify” this project.

Does this expense seem minor to you when he simply could have deleted 10 of
the 15 omitted units and solved your principal concern by breaking the long
U-shaped A building in two?

Yes, 45% of the units are now single loaded, but the east elevation of build-
ing A remains 360’ long, 20% more than the length of a football field. The
west elevation of building B has grown from 170’ to 400’ as well as matured
n height from 4 floors to 5.

And height along Colorado has grown from an adolescent 36’ to a robust 57’,
while true open space, open to the sky, has been reduced 29%. And don’t fo
rget, the primary open space requested by the Planning Commission at the
intersection of the 2 new public roads unfortunately has been covered over.

And the 51 affordable units agreed to at the Rent Control Board is now 38!
And economic value of the adjacent residential area will likewise be reduced!

The Planning Director is saying that four large TV screens staring at you on Colorado, massive buildings defining the perimeters, and dark canyons in substantially reduced interior courtyards are minor?!.

Is this really what you’re willing to approve? Are city commissions and
departments becoming the unpaid staff of developers? It’s within your
domain to stand up to this challenge.

Ron Goldman FAIA

MOUTRIE REFERS COMPLAINTS AGAINST O’CONNOR TO L.A. DA

Santa Monica’s City Attorney has referred the Transparency Project’s detailed
31 Complaints, along with over 70 exhibits, against Mayor Pam O’Connor to the
Public Integrity Division of the LA District Attorney’s office.

The complaints allege repeated violations of the Oaks Initiative by O’Connor
for illegally accepting campaign contributions from developers after voting to approve their projects. City Attorney Marsha Moutrie stated that because she “report[s] directly to the City Council (of which the Mayor is a member)” her
office has a conflict of interest, as does the Santa Monica Police Department.”

The DA’s Public Integrity Division has broad powers to investigate whether Pam O’Connor committed a crime under Santa Monica law, and, based on its findings,
seek criminal sanctions. It describes its responsibility concerning public off-
icials as follows:

“Public officials are elected…to positions of public trust. In the event of any breach of this trust,the Public Integrity Division will investigate and, if appropriate, prosecute criminal misconduct by any elected…public official.”

Specifically, concerning election and campaign violations, the Division explains:

“Because the integrity of the election process is crucial to a free and democra-
tic society, the District Attorney’s Office must be vigilant in enforcing all
laws that regulate the election process. In this regard, the Public Integrity Division is charged with investigating and prosecuting allegations of…illegal campaign practices [and] illegal campaign contributions…”
See http://da.co.la.ca.us/pid.htm

These serious allegations relate to batched, coordinated contributions Pam
O’Connor accepted from those who own or are senior officers of three of the
biggest developers in Santa Monica — Hines, Macerich and Century West—after
she voted to award them a substantial public benefit.

“The Transparency Project welcomes a serious investigation by the District At-
torney of these serial violations of Santa Monica law by the Mayor. Since 2008,
Pam O’Connor’s violations have been repeated, on-going and egregious. She now attempts to trivialize the violations. In interviews with the press she has
expressed disdain for the law and portrayed herself as a public official too
busy to follow it,” said Mary Marlow, Chair of the Transparency Project. “Santa Monica residents and the Transparency Project look forward to a thorough investigation by the Public Integrity Division and the implementation of approp-
riate remedies.”

The Transparency Project is an all-volunteer group of Santa Monica residents concerned about openness and accountability in our City government and politics. Marlow said, “We believe that openness and accountability are the cornerstones
of a healthy democracy. The Transparency Project formed in 2010 after a developer-funded PAC refused to timely disclose contributor information to Santa Monica
voters. As part of our commitment, we track political contributions to city
council candidates and members. The public served by the city council must be
able to rely on their representatives to be working in their best interests.”

The members of the Transparency Project are Mary Marlow, Chair, Julie Lopez-Dad, Laurence Eubank, Zina Josephs, Carol Landsberg, Lorraine Sanchez, Elizabeth Vandenburgh and Alin Wall.

CELEBRATING THE CAMPAIGN TO REDUCE EVICTIONS IN L.A.

70,000 evictions are filed in Los Angeles County each year. 2200 of those
households are represented by free legal services via legal aid. 99% of
the tenants that go to court alone lose their cases and lose their homes.

In November, 2013, the Eviction Defense Network (EDN) pledged to close the
Access to Justice Gap for the 70,000 tenants that face eviction in LA County
each year by 2024.

In order to be accessible to working families, EDN has increased its hours
to Monday through Thursday 9AM to 9PM, Friday 9AM to 6PM. EDN staff antic-
ipates that in 2014 EDN will provide counsel, advice and brief service assis-
tance to approximately 4000 different families and represent close to 2000
of them.

Join EDN in celebrating its success.

Attend their annual celebration on 10//23/2014 at 5 PM for an evening of
music and dancing under the stars, featuring the rag-time music of the Cal-
ifornia Feet Warmers.

Heritage Square in Highland Park, 3800 Homer Street, LA 90031
Ticket: $50, Students/Low Income/Nonprofit Staff: $25

Sponsors: Champion for Justice $1000; Leader for Justice $500; Advocate for
Justice $250; Friend $100.

Elena Popp
Executive Director
Eviction Defense Network
1930 Wilshire Blvd., Suite 208
Los Angeles, CA 90057
213/385-8112
213/385-8181 (fax)
elenaipopp17@gmail.com

To reach me directly use my cell (310/704-8785). Texting works best.
Please do not give cell or email to potential clients.
Potential clients should simply walk in M-Th 9AM-9PM or Friday 9AM-6PM
(try to arrive at least an hour before closing)
No appointments
No advice over the phone

MID-CITY NEIGHBORS TACKLE BALLOT MEASURES: PRO & CON

Santa Monica Mid City Neighbors will devote much of their monthly board
meeting to a discussion of Property Transfer Tax Measures H & HH and Air-
port Measures LC & D on Monday, October 20 at Colorado Center, Community
Room, 2500 Broadway. Doors will open at 6:30 pm.. Discussion will begin
at 7

Guest Speakers: MEASURES H & HH DISCUSSION: Speakers For: Council member
Gleam Davis and Leslie Lambert. Speakers Against: Bob Seldon and Peter
Tigler

MEASURES LC & D DISCUSSION: Speakers For LC: John Fairweather -Committee
for Local Control of Airport Land Speakers For D: Stacey Falcioni, Santa
Monicans for Open and Honest Development Decisions

RSVP:Santamonicamidcityneighbors@gmail.com

Garage Parking Validated & Broadway is Free after 6:00 pm

Organization business will be addressed following the discussion, which
Stacy Dalgleish, Mid-Cities VP & Communications Officer, described as
“exciting, and potentially incendiary.”

O’DAY AND HOTELS CHOOSE O’CONNOR AND GRUBER

The Daily Press reports that “Mayor Pro Tem Terry O’Day is listed as the
principal officer on an independent expenditures political action committee
(PAC) called Responsible Leadership for a Better Santa Monica, which has
received $25,000 donations from two separate local hotel-backers.” O’Day
told the Daily Press that the PAC will support Mayor Pam O’Connor and
former Planning Commissioner Frank Gruber.

“’It’s important to get the best candidates elected to council,’” O’Day
said, in response to a question about potential political repercussions.
‘If backlash were a concern, then I wouldn’t be in politics. I believe in
doing what’s right and deal with the politics later.’”

According to the Daily Press, “On Oct. 5, The Edward Thomas Management
Company, which owns Shutters on the Beach Hotel ad Hotel Casa del Mar,
gave $25,000 to the group…Ocean Avenue LLC, owner of the Miramar Hotel…
gave another $25,000 to O’Day Thursday. The group had raised and spent
just over $9,000 as of Sept. 30.”

O’Day entered local politics in 2008, when he and Judy Abdo co-chaired
“Save Our City” and devised a campaign to defeat a residents’ ballot
measure, proposition T, which would have limited annual commercial growth
in Santa Monica. The pair spent $700,000, contributed by developers, on
a series of ads and mailers that featured well-known local people, in-
cluding then-State Senator Sheila Kuehl, making all sorts of dire and unsubstantiated claims about the damage prop T would do to the town, the
schools, and so on. Virtually everyone in City Hall, from City Council
members, whose primary role was allegedly representing residents, to the
City unions, and the City Manager opposed Prop T, and it failed.

O’Day was appointed to the Planning Commission, but resigned before his
term ended. Subsequently, he was elected to the City Council, and is now
Mayor Pro Tem. And his brand-new PAC is backing O’Connor, who’s facing
multiple complaints for violating the Oaks Initiative, and Gruber, whose
only prior experience was one term on the Planning Commission some years
ago.

“Responsible Leadership for a Better Santa Monica?” Not bloody likely.

THE THREE BEST CITY COUNCIL CANDIDATES FOR SANTA MONICA

Santa Monica Community For a Livable City (SMCLC) urges residents to vote
for a City Council that will stand with residents, not developers. Santa
Monica is our home and we are thankful o live in such a beautiful place.

Kevin McKeown, as Council member, opposed the massive Hines Project. He
opposed shutting down the Village Trailer Park and evicting its tenants
for a new mega-project. He’s fought and voted against 300-foot condo/hot-
el towers on Ocean Avenue. Kevin doesn’t take money from developers and
doesn’t defend their interests. Kevin is on our side.

Sue Himmelrich. as a Planning Commissioner, Sue voted “No” on the massive
Hines project. As an Attorney, she fought for Village Trailer Park residents
against the City Council and a developer who wanted to take their homes.Sue
is against 20-story condo/hotel towers on Ocean. She’s a fighter who fights
for us.

Richard McKinnon, as a Planning Commissioner, Richard voted NO on Hines. He
opposes condo/hotel towers on Ocean Avenue. As Richard says, “Santa Monica’s 35-year-long over-development has created water scarcity, endless traffic
jams and an unsustainable future. This cannot continue.”

THE SIERRA CLUB HAS ENDORSED KEVIN, SUE and RICHARD.

Is Pam O’Connor funded by developers? Did she take illegal campaign contribu-
tions from developers after voting for their projects? Yes and Yes. A formal multi-part complaint has been filed against her. More was added this week.

She voted to reward developers with lucrative projects who evicted tenants
and destroyed rent-controlled housing. In both 301 Ocean Avenue and the Vill-
age Trailer Park, O’Connor voted to reward developers who had evicted tenants
from their homes and destroyed rent-controlled housing by allowing them to
build with greater heights and/or density than existing code allowed.

Just in the last 4 years, she approved projects which would add 20,000 daily
car trips to our roads

There are over 40 large development projects in the pipeline,

Pam O’Connor takes money from developers both before and AFTER voting for their projects. https://www.youtube.com/watch?v=gu2twln4Gzw Question 8: Have you in
the past accepted campaign contributions from developers and their associates? Developers who donated to Pam O’Connor in 2010 BEFORE she voted on their proj-
ects (as shown on her campaign disclosure statements) include NMS, Trammell
Crow, Colorado Creative, Maxser, Roberts Company, Edward Thomas, Luzzatto Co,
Hines and Macerich. http://smclc.net/campaign

http://smclc.net/campaig

Pam O’Connor has never voted against a large development project (30,000 square
feet or more) in 20 years. Just Google her Council votes for the following pro-
jects: Target, Lantana Hines, Maguire-Thomas, Rand, St John’s, Santa Monica Place, Hines Papermate, Village Trailer Park, 710 Wilshire Hotel, and Civic Center “Village.” At “Squirm Night” on October 14, 2014, sponsored by the Daily Press,
the Daily Press reports that current Mayor O’Connor, who has served on city coun-
cil since 1994, said she could not remember the last time she voted against a development agreement. “I don’t keep track that way, no seriously, I don’t,” she
said.

http://smdp_backissues.s3.amazonaws.com/101514.pdf

“Does money buy political influence?” “In 2010, Santa Monicans for Quality Government (developer-funded group) spent $445,000 on deceptive mailers…in sup-
port of Davis, Holbrook, O’Day, and Pam O’Connor.”

DAILY PRESS: BROCK WILL RETURN DEVELOPERS’ CONTRIBUTIONS

City Council candidate Phil Brock has vowed on his website, and at gatherings
and, now, at candidate forums that he opposes development as he does “not be-
lieve that high rises, massive developments, streets that become canyons of buildings, or roads that can’t be navigated by our families are what my grand-parents moved to Santa Monica for in the 1920’s… Big business wants to take the heart out of our city, to replace it with tall, dense buildings and twenty-four
hour a day traffic jams…”

He has repeatedly promised in print and in stump speeches that he will not ac-
cept campaign contributions from developers. But, as the Daily Press reported
this week, he has now promised to return two contributions that he received
from developers.

According to disclosure statements, “Brock’s campaign accepted a $325 contribu-
tion from Jim Jacobsen, an executive member of the 26Street TOD development team, which, at the time, was trying to win council’s support to add, among other th-
ings, a hotel and office space to the Bergamot Station Art Center.

“A month after that, in September, Brock, who’d been initially critical of the project, wrote to members of council: “In discussing the potential for land use
and in keeping with the now established use of Bergamot as an art, museum and
theatre venue I believe that 26Street/TOD Partners is the best developer to en-
hance the site.

“Less than a week after that, Scott Ginsburg, who’d been another executive part-
ner on the 26Street TOD team, made a $325 contribution to Brock’s campaign. This contribution was also accepted, according to campaign disclosure statements filed with City Hall.

“A month after that, in September, Brock, who’d been initially critical of the project, wrote to members of council: “In discussing the potential for land use
and in keeping with the now established use of Bergamot as an art, museum and
theatre venue I believe that 26Street/TOD Partners is the best developer to en-
hance the site…”

According to the Daily Press chronology, “Two days later, council ignored rec-
ommendations from city staff, the Arts Commission, and Brock, selecting, instead, Jeff Worthe Real Estate Group for potential development of the site.

“Earlier this week at Squirm Night, the Daily Press’ candidates’ forum, we asked Brock about the contributions.

“He said that he’d gotten 177 individual donations, a majority from Santa Monica residents. He claimed that he didn’t know that Jacobsen had donated…

After some backing and filling, Brock emailed the Daily Press that he was plann-
ing to return the checks.

TRANSPARENCY PROJECT FILES ADDITIONAL COMPLAINTS AGAINST MAYOR

Amendment adds additional Complaints to the Taxpayer Protection Amendment of 2000 Complaints Against Mayor Pam O’Connor Filed by The Santa Monica Transparency Proj-
ct on October 8, 2014.

On October 8, 2014, the Santa Monica Transparency Project filed with the City twenty‐four (24) Complaints against Mayor Pam O’Connor alleging that she repeat-
edly violated Santa Monica law under the Oaks Initiative by accepting campaign contributions from owners, board of director members and officers of Hines, Mace-
rich and Century West partners—after voting in favor of their development projects. The Complaints called for a full, thorough and impartial investigation into all of Ms. O’Connor’s campaign contributions, and that appropriate remedies be taken for these very serious violations of Santa Monica law. See the original Complaints for more detail.

In response to the 24 Complaints filed last week, Pam O’Connor has admitted under questioning by the press that mistakes were made by her regarding her campaign financing, that “perhaps” she violated the law in accepting some of her developer donations, and that she still is checking to see about the others.

At the same time she made these admissions, her comments evidenced a disdain for being held accountable for violating the law, and a belittling of her repeated violations. Mayor O’Connor offered a slew of excuses to the press for not follow-
ing the law, and launched misguided attacks on the message and the messenger.
They range from she is too busy to follow the law (aren’t we all busy, but have
to follow the law?), to claiming that raising the issue of the Mayor of our city having violated the law must be “political” (the question is, is it correct or
not, did she violate the law or not), to that if Oaks covers the hundreds of employees of a developer, it violates their First Amendment rights (Oaks does not cover them, it only covers the owners and senior most people. See Section 2202(b).) She never raised any of these excuses when she was telling residents how she follows the Oaks Initiative before she was caught not following it. www.smgov.net; 1/28/14 City Council meeting, video at 3:46. See newspaper articles in Attachment R.

Mayor O’Connor’s dismissive comments in the press are relevant to the appropriate remedies to be taken against her. Her conduct in accepting these illegal contributions and her most recent comments show disrespect for the importance of a public official obeying Santa Monica law directed at her official activities. Mayor O’Connor’s violations demonstrate a pattern of taking illegal contributions from three of the biggest developers in Santa Monica.

These alleged violations are ongoing, starting in 2008 and continuing into 2014 as was just revealed in her latest campaign disclosure statement filed on October 6, 2014.

It is in her latest filing last week, that the Transparency Project finds yet additional violations which form the basis of this Amendment, which is brought on information and reasonable belief. These involve yet another benefit that she conferred on Century West Partners, after which she took contributions from its
three principals, including its two founders, and from a senior officer, all in violation of the Oaks Initiative.

Please see Attachment R for backup documentation.

Amendment Adding New Complaints

Factual Background for Twenty‐Fifth Through Thirty‐First Complaints The Vote Conferring the Benefit
401 Broadway project. A public benefit was conferred in contract 9821 at the October 22, 2013 City Council meeting on Century West Partners. Ms. O’Connor voted in favor of conferring the benefit, which was in excess of the Oaks’ threshold of $25,000. The contract was an amendment to the project’s original development agreement entered into between the City and the previous owners. The amendment added a third subterranean level, added parking when the original development agreement did not have parking, in order to, according to Century West, enable Century West to obtain appropriate financing for the project, and other benefits.

The Beneficiary: Century West

That Century West was the owner and developer of the project was clear. On October 8, 2013, when the project was introduced for its first reading, the applicant’s attorney, Dave Rant, introduced the Applicant “Century West Partners,” and from the audience introduced from Century West “Michael Sorochinsky, principal” and Kevin Farrell—both of whom were later to contribute to Ms. O’Connor. Mr. Rant further explained how his client Century West Partners had acquired the property after the initial development agreement had been entered into. www.smgovt.net; 10/8/13 City Council meeting, video at 3:05:45.

Additionally, this is one of the cases where the City’s on-line Taxpayer Protection Report (log) contains some of the names of individuals with the entity upon whom the benefit was

conferred, and from whom councilmembers who voted in favor of the project could not afterwards accept contributions.

The log lists three names: Michael Sorochinsky, Steve Fifield and Steve Henry—the first two of whom later contributed to Pam O’Connor. The log is incomplete, as it does not list another principal of Century West Partners: Randy Fifield. It also does not list an officer of Century West, Kevin Farrell, who is either the Executive Vice President or Senior Vice President of Century West. Ms. O’Connor also improperly accepted contributions from both of these individuals.

The City’s on-line log is at most one step in a due diligence process—it is incomplete with whole years missing and data categories, such as the vital names of the owners, officers and board of directors, often blank. This is manifestly clear after a basic review of the log.

The Contributions Afterwards. City council candidate O’Connor’s campaign disclosure statement e‐filed last week, October 6, 2014 lists a number of donations from people related to Century West. These batched contributions were received by Mayor O’Connor’s campaign in July and August, 2014, nine and ten months after she voted to confer a benefit on Century West for the 401 Broadway downtown development project, amendment to its development agreement. The campaign statement states that she executed it on October 6th, as the candidate for office.

The list of donations include contributions from both founders, another principal of the company and an officer of Century West, and other individuals associated with them and a trust, the Michael and Lauren Sorochinsky Family Trust (several of the contributions are made by the Trust.) All of the contributions were made in a similar pattern and in unusual sums: with two donations each being made by four individuals, each of the four making one contribution for $99 and one for $226, totaling the maximum total donation permitted by law. Moreover, with three other individuals, only a donation of $226 was listed—the City should review if there were also $99 donations made by these individuals and not disclosed in the Campaign Statement.
On July 25, 2014, Pam O’Connor received a contribution for $226 from Randy Fifield (managing director and principal of Century West); on the same day she received a second contribution from Randy Fifield for $99; on the same day Mayor O’Connor received a donation for $99 from Steven Fifield (founder and principal of Century West); on the same day she received a second donation of $226 from Steven Fifield; on the same day Pam O’Connor received a contribution for $99 from Lauren Sorochinsky (listed as Homemaker, and believed to be the wife or other relative of Century West Co-­‐Founder Michael Sorochinsky and a Trustee of the Michael and Lauren Sorochinsky Family Trust); on the same day Mayor O’Connor received a donation of $99 from Michael Sorochinsky (Co-­‐ Founder and principal of Century West.)

Additionally, on August 14, 2014, Candidate Pam O’Connor received a contribution of $226 from Lauren Sorochinsky; on the same day she received a contribution also for $226 from Michael Sorochinsky; on the same day Mayor O’Connor received a contribution of $226 from Aaron Sorochinsky; further on the same day she received a donation for $226 from Kevin Farrell (Senior or Executive Vice President of Century West.)
Finally, on July 22, 2014 Pam O’Connor received a contribution from Greg Goldman in the amount of $226 (believed to be Century West project manager.)
As with the original Complaints, the Amended Complaints below are only brought as to campaign contributors who were principals of Century West, including its two founders, or officers: Michael Sorochinsky, Steve Fifield, Randy Fifield and Kevin Farrell. Others with a connection to Century West who made contributions to Ms. O’Connor are mentioned above to show the coordinated, batched nature of the contributions, but are not alleged as Oaks violations.
Please see Attachment S.

Twenty-­‐Fifth Complaint
On July 25, 2014, Pam O’Connor received a campaign contribution in the amount of
$226 from Randy Fifield, managing director and principal of Century West Partners, upon whom she conferred and voted to confer a benefit valued at over $25,000 on October 22, 2013.

She did not return the contribution within 10 days. All, in violation of the Oaks Initiative. Please see Attachment O to the original Complaint.
Twenty-­‐Sixth Complaint
On July 25, 2014, Pam O’Connor received a campaign contribution in the amount of
$99 from Randy Fifield, managing director and principal of Century West Partners, upon whom she conferred and voted to confer a benefit valued at over $25,000 on October 22, 2013.
She did not return the contribution within 10 days. All, in violation of the Oaks Initiative. Please see Attachment O to the original Complaint.
Twenty-­‐Seventh Complaint
On July 25, 2014, Pam O’Connor received a campaign contribution in the amount of
$99 from Steven Fifield, founder and principal of Century West Partners, upon whom she conferred and voted to confer a benefit valued at over $25,000 on October 22, 2013. She did not return the contribution within 10 days. All, in violation of
the Oaks Initiative.
Please see Attachment N to the original Complaint.

Twenty-Eighth Complaint
On July 25, 2014, Pam O’Connor received a campaign contribution in the amount of
$226 from Steven Fifield, founder and principal of Century West Partners, upon whom she conferred and voted to confer a benefit valued at over $25,000 on October 22, 2013. She did not return the contribution within 10 days. All, in violation of the Oaks Initiative.
Please see Attachment N to the original Complaint.
Twenty-‐Ninth Complaint
On July 25, 2014, Pam O’Connor received a campaign contribution in the amount of
$99 from Michael Sorochinsky, founder and principal of Century West Partners (and Trustee of the M & L Sorochinsky Family Trust) upon whom she conferred and voted to confer a benefit valued at over $25,000 on October 22, 2013. She did not return the contribution within 10 days. All, in violation of the Oaks Initiative.
Please see Attachments N to the original Complaint.
Thirtieth Complaint
On August 18, 2014, Pam O’Connor received a campaign contribution in the amount of $226 from Michael Sorochinsky, founder and principal of Century West Partners (and Trustee of the M & L Sorochinsky Family Trust) upon whom she conferred and voted to confer a benefit valued at over $25,000 on October 22, 2013. She did not return the contribution within 10 days. All, in violation of the Oaks Initiative.
Please see Attachments N to the Original Complaint.
Thirty-­‐First Complaint
On August 18, 2014, Pam O’Connor received a campaign contribution in the amount of $226 from Kevin Farrell, an officer, Senior Vice President or Executive Vice President, of Century West Partners, upon whom she conferred and voted to confer a benefit valued at over $25,000 on October 22, 2013. She did not return the contribution within 10 days. All, in violation of the Oaks Initiative.
Please see Attachment P to the original Complaint.

The Santa Monica Transparency Project

/s/ Mary Marlow
Mary Marlow, Chair. Dated: October 16, 2014.

Appendix -­‐-­‐-­‐ Chart of Key Dates

-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐
=401 Broadway Project – Century West ( Complaints 25-­‐31)
Benefit Conferred: October 22, 2013

Contributions Afterwards: July 25, 2014 and August 18, 2014.
-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐-­‐