With One Paseo, Suburban Retrofitting Comes to San Diego

With One Paseo, Suburban Retrofitting Comes to San Diego

Photo by Sam Hodgson

The site of the proposed One Paseo development in Carmel Valley.

There’s an in vogue term in urban planning that calls for refashioning typical suburban features like shopping malls, office parks and big box stores into spaces more closely resembling urban areas.

“Retrofitting suburbia,” as it’s been called by author, architect and professor Ellen Dunham-Jones, “provides the opportunity to transform the most automobile-dependent landscapes into more sustainable, more urban places,” she wrote in a 2009 essay published by the Urban Land Institute, a development advocacy group.

She called the process the biggest development project of the next 50 years, and if the whole thing sounds like a stereotypical subject for a TED talk, you’re on the right track. Dunham-Jones’ talk on the importance of suburban retrofitting has been viewed over 300,000 times.

The subject has come to San Diego by way of One Paseo, the 1.4 million square foot mixed-use project on 23 acres in Carmel Valley. Since the site is only zoned for 500,000 square feet of office space, approving the project will eventually require City Council to approve an amendment to the area’s community plan.

The “suburban retrofit” concept probably won’t dissuade residents who’ve opposed One Paseo on the grounds it threatens Carmel Valley’s core character. A retrofit by definition means adaptation.

Carmel Valley, located 20 miles north of downtown San Diego, was designed and built after the city commissioned a master plan in 1974. It’s unquestionably a suburban area.

Urban planner Howard Blackson said there are two ways to think about One Paseo, and what it means for Carmel Valley.

“Either One Paseo is the last piece of the 20th century conventional suburban development pattern or it is the first step in rebuilding toward a 21st century mixed-use, walkable, infill redevelopment pattern,” said Blackson, who has done limited consulting work on the project.

In the former scenario, it’s a capstone of a young community that’s almost finished being built out. In the latter, it’s the first step to beginning a second, more urban wave of development.

Michael Stepner, San Diego’s former city architect and a faculty member at the NewSchool of Architecture and Design downtown, said it’s possible it could be both. Stepner is also a hired consultant for the project.

“One is completion of what the original community plan called for,” he said. “And at the same time, you’d hope as things evolve and change, you can think about it in both terms.”

Stepner’s description of the project as the completion of the area’s original community plan vision might strike some as odd, since the 23-acre parcel was zoned for 500,000 square feet of office space in that plan.

But he said he’s speaking of the original plan’s idea of a walkable town center within Carmel Valley, something that never really came together as the community developed.

“The opportunities are still there to deal with that, if you’re willing to look at it as a broad concept,” he said.

The sort of refashioning of a suburban community he’s talking about is where the concept of a suburban retrofit comes in.

The opportunity for suburban retrofitting, Dunham-Jones has written, came in part after the recession brought traditional sprawl development to a halt.

“(It) gives us tremendous opportunities to take our lease sustainable landscapes now, and convert them into more sustainable places, and in the process what that allows us to do is redirect a lot of our growth back into existing communities that could use a boost, and have the infrastructure in place, instead of continuing to tear down trees and tear down the green space out at the edges,” she said in her TED talk.

One Paseo isn’t a perfect embodiment of Dunham-Jones’ concept. It’d be built on an empty lot, and Dunham-Jones mostly focuses on repurposing already built suburban hallmarks like shopping malls.

But Stepner said One Paseo still fits with the big-picture effort of bringing sustainable development concepts to the suburbs.

“You have a 25-acre hole in the community that’s been there forever,” he said. “It can be a catalyst for tying everything back together. You set the example, and maybe the town center across the street can do something that ties things together when it redevelops, then you can retrofit the nearby park, and so on.”

Stepner said he got involved in One Paseo after its developer, Kilroy Realty, presented the project to a public meeting for development professionals during which he sharply criticized the concept for being too isolated, and not focused enough on integrating with the rest of the community.

Working with architect Frank Walden and Blackson, Stepner said the edges of the project have been made more inviting from the outside, the streets a continuation of the rest of the neighborhood, and turned the plazas into areas useful to the whole community, not just typical outdoor mall spaces.

He said he hopes a successful One Paseo can not only catalyze change in Carmel Valley, but serve as a template for more suburban retrofits in San Diego, like in Mission Valley. Planning Director Bill Fulton has said Mission Valley represents an opportunity for the city to plan more effectively.

“Mission Valley has a lot of things going for it: It’s connected to the trolley, but it doesn’t all tie together well,” Stepner said. “How do you tie pieces together so you aren’t just driving from one shopping center to another? Maybe One Paseo is an example, even if Mission Valley requires a totally different process.”

Correction: an earlier version of this story incorrectly stated the One Paseo project’s cost.

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Andrew Keatts

Andrew Keatts

I'm Andrew Keatts, a reporter for Voice of San Diego. Please contact me if you'd like at andrew.keatts@voiceofsandiego.org or 619.325.0529.

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34 comments
Derek Hofmann
Derek Hofmann subscribermember

"As population increases, there will be 71,400 trips per day by 2030."

Traffic predictions can never be trusted, and here's proof: http://www.ssti.us/2013/12/new-travel-demand-projections-are-due-from-u-s-dot-will-they-be-accurate-this-time/

So no, there will not be 71,400 trips per day by 2030.

"Residents can walk a few miles to get there, otherwise they must drive automobiles."

Why can't they ride bicycles?" New travel demand projections are due from U.S. DOT. Will they be accurate this time? SSTIhttp://www.ssti.us/2013/12/new-travel-demand-projections-are-due-from-u-s-dot-will-they-be-accurate-this-time/When the U.S. DOT's most recent Conditions and Performance Report to Congress hit the streets in 2012,[1] it forecast that national vehicle-miles traveled would reach 3.3 trillion that year. A few months later we learned that their estimate was almos...

Diogenes
Diogenes

In the December 12, 2013 edition of the Carmel Valley News, a letter to the editor by John Dean, a Carmel Valley Resident of 44 years and former Chair of the Carmel Valley Community Planning Board was published. His letter was entitled, "One Paseo, the Trojan horse and 'worst traffic" in San Diego."

The One Paseo traffic study projects that after the proposed project is completed in 2016, traffic at Del Mar Heights Road would be 65, 300 trips per day at the I/5 intersection where its capacity is 60,000 trips per day.

Mr. Dean then compares the SANDAG map and finds only one similar intersection, Mira Mesa Blvd. at I-15, although he finds six other similar traffic snarls, he notes that the Mira Mesa Blvd. I-15 intersection has 11 lanes vs. 6 for One Paseo.

As population increases, there will be 71,400 trips per day by 2030. Mr. Dean worries about the extreme traffic congestion.

The developer, Kilroy Realty, Inc., situated in West Los Angeles, and their various lobbyists hope that I-5 and SR-56 will eventually provide new connectors under SANDAG's latest regional plan by 2030. They also hope that a single busline will roll through the community by 2035, although that has not been funded by the City nor the developer.

SANDAG's policies call for a mix of transportation to reduce the impact of greenhouse gasses. One Paseo would not provide public transportation. Residents can walk a few miles to get there, otherwise they must drive automobiles. Since 75% of the customers for the town center shopping proposed by the project would come from outside of Carmel Valley, how does that meet or goals set forth under SANDAG's policies and mandates?

Mr. Dean concludes that, "Carmel Valley will gain the dubious distinction of having one of the worst, if not the worst, performing freeway interchanges in San Diego."

Torrey Pines Community Planning Board members have also voiced their concerns that emergency vehicles will be delays in crossing over the freeway resulting more preventable deaths from accidents, coronary events, and other emergencies where response time will be increased far beyond the current standard of care which is less than eight minutes.

"Smart Growth" by definition includes a mix of transportation. Spreckles provided a trolley line from downtown to Kennsington through Old Town. He had true vision. Kilroy Realty just wants to make a fat profit because it paid far in excess of the market value for this property. I hope that internal walkability of this proposed project is not confused with residents being able to walk there and carry groceries back for more than one-quarter mile. I live two-and-one half miles away. Most residents would have to drive their automobiles. Mitigations proposed by Kilroy Realty are also 100% automobile dependents, namely widening roads.

This proposed project looks backwards, not forwards. San Diego's future depends on public transportation. One Paseo's proponents do not look like people who walk much. I assume that they do not understand that "buzz words" are not the same as good urban and environmental planning. One Paseo will set a bad example for well-funded special interests to unduly influence policy makers and lead agencies while ignoring the mandates of SANDAG. We must become a City with a true mix of transportation.

I attended architectural school at UCLA and worked for developers there as legal counsel. I came to San Diego in 1983 to escape the high density. I have lived in Carmel Valley for over ten years and am very familiar with the impact on this beautiful community that nine-story buildings with Horton Plaza density will create. Traffic engineering cannot make traffic go away. The green wave breaks down and saturation occurs where delays can be 30 minutes immediately adjacent to the freeway on-ramp and off-ramps at I-5.

Kilroy Realty could build a smaller version. So why don't they? Their profits do not matter to sound planning.

Derek Hofmann
Derek Hofmann subscribermember

It's a chicken-and-egg problem because transit won't work very well without more communities like One Paseo.

Don Wood
Don Wood

This proposal has nothing to do with "urban retrofitting". It's about convincing politicians to upzone a property beyond what is allowed in the community plan so the developers can make a huge killing. That's what real estate development in San Diego has always been about, and always will be. Sorry to see VOSD naively sucked in by the developers propaganda.

Don Wood
Don Wood subscriber

This proposal has nothing to do with "urban retrofitting". It's about convincing politicians to upzone a property beyond what is allowed in the community plan so the developers can make a huge killing. That's what real estate development in San Diego has always been about, and always will be. Sorry to see VOSD naively sucked in by the developers propaganda.

bud
bud

It is laughable to call this anything other than suburban sprawl on steroids. It will bea magnet for cars. Tobe urban it needs transit. This will tarnish the quality of life in at least three concentric circles. Stepner sold his cred with his first paycheck.

Eric Spoerner
Eric Spoerner subscriber

May I ask what exactly a non-binding United Nations resolution on sustainable development has to do with One Paseo?

Grammie
Grammie

For a better understanding of this latest greatest push extolling the virtues of dense urban living, just google Agenda 21, and ICLEI, of which San diego is a member.

Marcela Escobar-Eck
Marcela Escobar-Eck

Erik Bruvold. You should be more transparent so your other clients know what you are doing and who is paying you to make these comments. You have done WAY more than a small amount of research for the opposition. You are working for the competing shopping center (Donahue Schriber) as a paid consultant to fight the project. In fact your comments on this article are conspicuously embedded in a letter recently sent in by Donahue Schriber's attorney.

Marcela Escobar-Eck
Marcela Escobar-Eck subscribermember

Erik Bruvold. You should be more transparent so your other clients know what you are doing and who is paying you to make these comments. You have done WAY more than a small amount of research for the opposition. You are working for the competing shopping center (Donahue Schriber) as a paid consultant to fight the project. In fact your comments on this article are conspicuously embedded in a letter recently sent in by Donahue Schriber's attorney.

Erik Bruvold
Erik Bruvold

Well no (and fair disclosure, we have done some small amount of research support for the opponents). One Paseo's biggest challenge of being the kind of space Durham-Jones is discussing is that it is almost impossible to conceive of it being "connected" to the rest of the community based upon the CMV circulation. Homes to the north are not connected directly to Del Mar Heights Road,. requiring pedestrians to proceed along a circuitous route to the center and crossing the aforementioned high speed 6 lane DMH Road. Homes to the SouthEast face the same challenges.

Sadly, San Diego missed (there have been many) one great chance at a retrofit and it can help distinguish the differences. About 15 years ago developers proposed redoing the Clairemont Village Shopping center, a smallish center located Clairemont Drive and Burgener. They wanted to remodel it to remove excess parking, add 2nd/3rd floor residential, and create pedestrial connections to the surrounding residential which is relatively well integrated to that site with the circulation patterns. Died a painful nimbly death.

Do we need more housing in this community? Absolutely! If that was the sell for One Paseo it would be a hat tip moment. But the idea that this can somehow create "a gathering place" for the community given the circulation elements in place is somewhat laughable. It really is trying to find any ornament in the box to put on the tree.

Erik Bruvold
Erik Bruvold subscribermember

Well no (and fair disclosure, we have done some small amount of research support for the opponents). One Paseo's biggest challenge of being the kind of space Durham-Jones is discussing is that it is almost impossible to conceive of it being "connected" to the rest of the community based upon the CMV circulation. Homes to the north are not connected directly to Del Mar Heights Road,. requiring pedestrians to proceed along a circuitous route to the center and crossing the aforementioned high speed 6 lane DMH Road. Homes to the SouthEast face the same challenges.

Sadly, San Diego missed (there have been many) one great chance at a retrofit and it can help distinguish the differences. About 15 years ago developers proposed redoing the Clairemont Village Shopping center, a smallish center located Clairemont Drive and Burgener. They wanted to remodel it to remove excess parking, add 2nd/3rd floor residential, and create pedestrial connections to the surrounding residential which is relatively well integrated to that site with the circulation patterns. Died a painful nimbly death.

Do we need more housing in this community? Absolutely! If that was the sell for One Paseo it would be a hat tip moment. But the idea that this can somehow create "a gathering place" for the community given the circulation elements in place is somewhat laughable. It really is trying to find any ornament in the box to put on the tree.

Derek Hofmann
Derek Hofmann

The lifeless form of suburbia we're all familiar with only exists because of over-regulation. Eliminating unnecessary regulations such as those in the video below would help us switch back to traditional development patterns which existed until the 1950s.

Derek Hofmann
Derek Hofmann subscribermember

The lifeless form of suburbia we're all familiar with only exists because of over-regulation. Eliminating unnecessary regulations such as those in the video below would help us switch back to traditional development patterns which existed until the 1950s.

john stump
john stump

The plan San Diego has followed , with success, has been to concentrate major building Downtown. The concept was to keep the core strong, prevent Balkanization, and encourage a vibrant urban lifestyle.
Planners always want to tear out a wall or redo the room configuration. The Suburbs are not a place to live, they are a middle class sanctuary for raising children, with there own kind. Life is conducted in the City. The best (sic disaster) example of bring the core to the suburbs is Detroit, Today, Detroit's the suburbs thrive and the core is a waste land [Ich bin Detroiter and my Cousin is the new Mayor].

I suggest that planners focus on implementing the proven model for Cities and develop the solutions for high speed quality rail transportation to the core. There is plenty of creative work concerning how to transition from private vehicles, to BRT, and to speed rail. Save the planet transition folks from single occupancy SUVs to a new mode of transportation. Suburbs are different from Urbs so celebrate the differences.

john stump
john stump subscriber

The plan San Diego has followed , with success, has been to concentrate major building Downtown. The concept was to keep the core strong, prevent Balkanization, and encourage a vibrant urban lifestyle.
Planners always want to tear out a wall or redo the room configuration. The Suburbs are not a place to live, they are a middle class sanctuary for raising children, with there own kind. Life is conducted in the City. The best (sic disaster) example of bring the core to the suburbs is Detroit, Today, Detroit's the suburbs thrive and the core is a waste land [Ich bin Detroiter and my Cousin is the new Mayor].

I suggest that planners focus on implementing the proven model for Cities and develop the solutions for high speed quality rail transportation to the core. There is plenty of creative work concerning how to transition from private vehicles, to BRT, and to speed rail. Save the planet transition folks from single occupancy SUVs to a new mode of transportation. Suburbs are different from Urbs so celebrate the differences.

Derek Hofmann
Derek Hofmann

"As population increases, there will be 71,400 trips per day by 2030."

Traffic predictions can never be trusted, and here's proof: http://www.ssti.us/2013/12/new-travel-demand-projections-are-due-from-u-s-dot-will-they-be-accurate-this-time/

So no, there will not be 71,400 trips per day by 2030.

"Residents can walk a few miles to get there, otherwise they must drive automobiles."

Why can't they ride bicycles?" New travel demand projections are due from U.S. DOT. Will they be accurate this time? SSTIhttp://www.ssti.us/2013/12/new-travel-demand-projections-are-due-from-u-s-dot-will-they-be-accurate-this-time/When the U.S. DOT's most recent Conditions and Performance Report to Congress hit the streets in 2012,[1] it forecast that national vehicle-miles traveled would reach 3.3 trillion that year. A few months later we learned that their estimate was almos...

Andrew Keatts
Andrew Keatts

No need to be sorry, Don. Luckily neither I nor VOSD have been naively sucked in by anyone's propaganda. I think suburban retrofitting-- and I agree the term sounds awfully Orwellian-- is a compelling idea to build more sustainable communities out of the city's already-established footprint. I don't think it's clear that One Paseo represents a clear example of suburban retrofitting, but I also don't see how it can be referred to as basic, status quo suburban sprawl either. Regardless, the most prominent discussion of shifting traditional suburban development patterns in San Diego right now is happening in the context of One Paseo. That conversation includes you and many others who've said it's a red herring to include One Paseo as an example of anti-suburban development, which is part of what makes the project worth covering.

Andrew Keatts
Andrew Keatts author

No need to be sorry, Don. Luckily neither I nor VOSD have been naively sucked in by anyone's propaganda. I think suburban retrofitting-- and I agree the term sounds awfully Orwellian-- is a compelling idea to build more sustainable communities out of the city's already-established footprint. I don't think it's clear that One Paseo represents a clear example of suburban retrofitting, but I also don't see how it can be referred to as basic, status quo suburban sprawl either. Regardless, the most prominent discussion of shifting traditional suburban development patterns in San Diego right now is happening in the context of One Paseo. That conversation includes you and many others who've said it's a red herring to include One Paseo as an example of anti-suburban development, which is part of what makes the project worth covering.

Derek Hofmann
Derek Hofmann

It's a chicken-and-egg problem because transit won't work very well without more communities like One Paseo.

John Stechschulte
John Stechschulte subscriber

Obviously the UN is an all-powerful international organization set to usurp America's sovereignty and enslave us all. I mean, just look at what they did to Syria after they used chemical weapons. That's what's in store for us if we don't bend to their iron will.

Eric Spoerner
Eric Spoerner

May I ask what exactly a non-binding United Nations resolution on sustainable development has to do with One Paseo?

Marcela Escobar-Eck
Marcela Escobar-Eck

Erik: Your conclusions are not correct but this is not the forum to debate them.

p.s. my clients are hardly a secret.

Erik Bruvold
Erik Bruvold

And you are working for Kilroy, Marcela. Pot meet Kettle. What do you want to dispute - that the center which is surrounding by high speed 6 lane arterials can be connected to the neighborhood or that we called out Kosmont for claiming that 75% of sales at the center would come FROM OUTSIDE the city of San Diego? They also made a basic math error in trying to determine sales from businesses and visitors. Basic stuff which it was right to call out and dispute. As I said, call it 600 units of housing and rightly note that we need all we can get. But the idea that it will create some bucolic town center that will be tax windfall for the City is just not true and is pretty evident on its face.

Marcela Escobar-Eck
Marcela Escobar-Eck subscribermember

Erik: Your conclusions are not correct but this is not the forum to debate them.

p.s. my clients are hardly a secret.

Erik Bruvold
Erik Bruvold subscribermember

And you are working for Kilroy, Marcela. Pot meet Kettle. What do you want to dispute - that the center which is surrounding by high speed 6 lane arterials can be connected to the neighborhood or that we called out Kosmont for claiming that 75% of sales at the center would come FROM OUTSIDE the city of San Diego? They also made a basic math error in trying to determine sales from businesses and visitors. Basic stuff which it was right to call out and dispute. As I said, call it 600 units of housing and rightly note that we need all we can get. But the idea that it will create some bucolic town center that will be tax windfall for the City is just not true and is pretty evident on its face.

Marcela Escobar-Eck
Marcela Escobar-Eck subscribermember

Erik: It appears you are asserting that your work (paid for by Donahue Schriber) was done under the umbrella of the National University Institute for Policy Research.

I will be looking forward with great interest to your upcoming lobbying reports as well as those for Donahue Schriber to see how those activities will be reported. It was reported that you had communications with High-ranking City officials on the issues. I do hope you have spent time familiarizing yourself with the lobbying requirements.

I'm sure your Chancellor will be interested in the reporting requirements also. http://www.nusinstitute.org/About/Chancellor-Page.htmlNational University System Institute for Policy Researchhttp://www.nusinstitute.org/About/Chancellor-Page.htmlDr. Michael R. Cunningham became Chancellor of the National University System effective October 10, 2013. Dr. Cunningham originally joined the National University System on July 1, 2013 as President of the System's flagship institution, National Univ...

Erik Bruvold
Erik Bruvold subscribermember

Chris that is a great suggestion and point well taken.

Erik Bruvold
Erik Bruvold subscribermember

Thanks Chris. We (NUSIPR) carries out a modest amount of sponsored research. In that way is it pretty similar, for example, to San Diego state's real estate and tourism programs that also accept outside funding to conduct analysis. We don't make any promises about results and, as noted above, the methodology and sources are transparent. You can, indeed, replicate the fiscal and economic analysis on your own. Happy to show you how.

So to answer your question(s), NUSIPR would strongly question the conclusion that 75% of shoppers to One Paseo will be from outside the City of San Diego and thus, as a consequence, we believe the net economic/fiscal impact is likely very small.

I (as an individual) would go further - the development is going to have to be VERY creative to construct connections with the rest of the community that enable it to be non auto dependent. Even when developers (see UTC and Costa Verde) have spent millions trying to tie their developments to a broader network, the suburban network gets in the way.

Erik Bruvold
Erik Bruvold subscribermember

Hi Chris...thanks for asking

We did 2 things. First, we were asked to review the economic impact analysis prepared by One P's folks. Generally OK EXCEPT (and big exception) they assumed that 75% of the retail sales and economic activity at the center would be "net new" to the City of San Diego - even though 75% of households and 73% of the wealth in the primary market area (the geography used to calculate demand and expected sales) are within the City boundaries. We suggested that was way too high. If you use a more realistic number, the net economic and fiscal impact of the largely retail development is pretty small and very much within margins of measurement error. Basically it isn't a net gain of anything - just moving sales and economic activity from other places in the City to 1 Paseo.

The second thing we did was look at the projected demand for retail in the area. It is tricky. The principal reason that the area seems like it can sustain more retail without negatively impacting the surrounding areas comes down to the (very) high wealth in households in Del mar, RSF, and Fairbanks. We just don't have good data on consumption of those households and whether, like those making around 200,000 they spend 1/3 of their income on retail. The census sadly doesn't report out that information - we just have indirect evidence that very high income families seem to have a high amounts of savings - which indirectly seems to be evidence they are not spending all their income. However that is just indirect and if they really do spend 1/3 of income on retail it is likely the area can sustain the development. What we pointed out is just how sensitive the retail market analysis is to Kilroy's assumption - and if those high income households don't spend 30%+ of income on retail goods it is likely something would give. And with the current state of development in the Primary Market area, that is likely the town center long planned for over in Torrey Highlands. Just hard to see how there would be sufficient demand in the Primary market area to sustain that and the full build out of 1 Paseo.

My comments about the problem with the circulation element comes from common sense and observing 30+ years of San Diego suburban development as a quasi-interested citizen. I simply can not think of a development that created that a "community center" even after being linked by bridges, pedestrian paths, mixed uses, etc. etc. when it faces the problems of a suburban build circulation system. A common problem seems to be the huge arterial streets that separate the centers from neighborhoods. For a variety of reasons, people simply do NOT like to walk across 6-8-10 lanes of traffic going at 50+ MPH. Maybe they should but they don't. And yet developers keep TRYING to sell that. If your memory is long enough you remember Costa Verde being sold as a community center for UTC. Ditto UTC mall. Ditto 4S Ranch Commons. Ditto the development at Mira Mesa and I-15. Ditto Spectrum in Kearny Mesa. And these are just the only ones that spring to mind. As I also noted, the one project that SEEMED to provide pedestrian connections to the surrounding community - the one in Claremont, died a dramatic death at the hands of people who proclaim a desire for smart growth in the community.

Chris Brewster
Chris Brewster subscribermember

"we have done some small amount of research support for the opponents" Who is we? You are listed as the President of the National University System Institute for Policy Research. Are they a land use consultant?

John Stechschulte
John Stechschulte

Obviously the UN is an all-powerful international organization set to usurp America's sovereignty and enslave us all. I mean, just look at what they did to Syria after they used chemical weapons. That's what's in store for us if we don't bend to their iron will.

Chris Brewster
Chris Brewster subscribermember

Mr. Bruvold: Thanks for this. I appreciate the explanation.

My suggestion, in cases like this, would be that if you decide to comment in your capacity as president of the organization you might start by stating something like: "The National University System Institute for Policy Research conducted some research into [specified] aspects of this issue that was funded by [whomever]. Our research found that [whatever]." That would be fully transparent and people could conclude what they like from the issue of who paid for it, etc.

If you want to also comment as an individual, I guess that's your privilege, but it doing so may leave people thinking that you don't think the research was adequately thorough or on point. It may also leave the reader thinking there might have been bias in the research based on views of the leader thereof.

I've faced similar challenges over the years and I have found it best to comment as the organizational representative or as an individual (where this was possible without bringing the organization into the debate), but not both.

Chris Brewster
Chris Brewster subscribermember

Mr. Bruvold: I was not expressing an opinion on this issue actually. I don’t have one. I noted that you stated in your prior comments that, “we have done some small amount of research support for the opponents.” You did not state who, “we,” are, which seemed strange to me. To clarify, is, “we,” the National University System Institute for Policy Research? Are you stating here the opinions of that entity in your role as president thereof?

In comments above, Ms. Escobar-Eck stated that, “You are working for the competing shopping center (Donahue Schriber) as a paid consultant to fight the project.” You did not dispute that assertion, but only noted that she is working in a similar role for another party. She however is apparently a private land-use consultant, while it seems that the National University Institute for Policy Research is supposed to be an independent think tank.

There seem to be some odd entanglements here between academia and advocacy.National University System Institute for Policy Research * About Ushttp://www.nusinstitute.org/About.htmlThe National University System Institute for Policy Research is an independent institute that conducts research and publishes articles, policy briefs, and other materials about regional issues, including municipal government, economic policy, housing...