Monday, June 30, 2014

History Bits: Pentacle Theatre, Cremains Memorial, McGilchrist Building, Virtues of Analog

Normally theater is an urban phenomenon, right? Think of Broadway and all that implies.

Transportation is erased and invisible
"Pentacle Theatre began its life in 1954 in a barn on Highway 22 across from the Oak Knoll Golf Course."

So why the heck is our theater built out in rural West Salem on a State Highway???

The Pentacle is as much a creation of Eisenhower-era autoism as is the Interstate System, and its dependence on cars and car subsidy likely as great (or greater) as its dependence on "passion, love and dedication"! Its location also robs downtown of an important source of creative, intellectual, and sidewalk life.

McGilchrist and Roth Building Renovations - Time Capsule?

Maybe there's a time capsule in the corner pier!

February 15, 1916
The renovations for the McGilchrist and Roth Buildings are nearing completion, and an eagle-eyed reader found an easter egg that might not even be known to the new owners of the building! From the paper in 1916:
In the corner pier of the McGilchrist building records were placed this morning which may in generations to come tell something of what was doing in Salem in February of the year 1916 Anno Domino....
Anyone know whether the construction work uncovered a capsule?

Sunday, June 29, 2014

Just Because it's Popular Doesn't Mean it's Good! Argument Fail on Third Bridge

With the stirring claim that "The region needs this bridge and has for decades..." today the paper once again argues circularly, assuming as a conclusion what in fact needs to be proved.

The editorial board hasn't yet engaged facts or strong claims like:
  • traffic is flat on the bridges
  • the proposed location is in a liquefaction zone and the existing bridges aren't reinforced for the "big one" earthquake
  • driving is harmful to cities and to individuals
  • funds for a mega-project might be better allocated to different things
(etc., etc.)

Anyway, things that are popular aren't always good - by itself that's not a controversial claim, right? History's littered with popular things we later learn are bad or dumb or evil.


There are also other problems here.

Saturday, June 28, 2014

A Ban the Bridge Loser: NBA Commissioner Adam Silver

Basketball's not the thing here, but new NBA Commissioner Adam Silver has twice been in the general news, this week for a touching tribute to a basketball career cut short by Marfan's Syndrome.

Adam Silver, NBA Commissioner, and Isaiah Austin -
Silver once said "Ban the Bridge"
It it interesting that by the paper's standards, Silver is also an example of a "loser."


Robert Moses and Bridge
via Wikipedia
From a Sports Illustrated profile:
In 1965 famed New York City developer Robert Moses announced plans to build a bridge connecting Long Island and Westchester. The bridge would run from Oyster Bay to Rye. Melba Silver would not have been directly affected. Her house was nowhere near the proposed entrance. But Melba was an environmentalist who hosted fund-raisers for progressive political candidates. She was concerned about the effects of pollution on her children and her hometown. She started a campaign called Ban the Bridge. Her youngest son, Adam, wore BAN THE BRIDGE buttons to elementary school. He saw his mom on TV, and he rejoiced with his family when plans for the bridge were scuttled.
This Week's Oversight Team Meeting

What kind of oversight would put a giant bridge and highway in a known liquefaction zone?

Cover Oregon kind of oversight!

Wednesday, June 25, 2014

Apotheosis of the Bike Reflector: Primal Op at Hallie Ford

Know what these are made of? You might not recognize them in a pattern like this, but you have at least a couple of them on your bike. Maybe on your mailbox or to mark your driveway, too.

Four Color Variations, circa 2005
Richard C. Elliott
They're one-, two-, and three-inch reflectors, that's what!

If you've been by Hallie Ford they might look familiar.

Hallie Ford North Exterior from State Street

Set in the marble second story are similar windows.

Detail of "Portals Through Time" on Exterior
They're by the same artist, Richard C. Elliott. And he's got a great big show at Willamette University's Hallie Ford Museum of Art right now.

Tuesday, June 24, 2014

Salem Ale Works Bike Rack, Anarchy and Pedestrian Impedance: Bits

Just in time for summer, the brewers at Salem Ale Works have announced they've got a new bike rack!

New Bike Rack at Salem Ale Works
(Photo: Salem Ale Works)
It went in maybe a month ago, and that's great news - because what's better than a frosty beer on a hot summer's day?! (Now if we could just modernize 25th street!)

Salem Ale Works off 25th and Electric
Now with bike racks!
Mixed Messaging on Crosswalk Enforcement

It was also nice to see a piece today on the summer crosswalk enforcement activities, but the tone still tilts to view people on foot as the interlopers in the street, which more naturally belongs to people in cars.

Local MPO Meets at Noon, to Hear Ride Share Update

Our local MPO meets today the 24th, and the Cherriots RideShare update from last month was postponed to this month. Otherwise this week the important meeting is the River Crossing Oversight Team on the 26th (see N3B for more).

In the minutes from last month, though, is an interesting bit on the proposed TGM grant for the Third Bridge.


From the draft minutes and meeting packet:
It is believed that involving the local neighborhood groups in refining the plan and landscaping would make this a more positive experience for them....[but] it is important that local traffic and bicyclists and pedestrians have facilities that are safe but separate, and it is important not to create problems [that neighborhood groups might create, presumably!] that will not allow treating the facility as an expressway.
SKATS Policy Committee meets at noon on Tuesday the 24th at 100 High St. SE, Suite 200, above Bar Andaluz and the former La Capitale.

Monday, June 23, 2014

City Council, June 23rd - Minto Bridge Update, Traffic Circle at Boon's

Council meets today, and on Sunday a substantial update on delay with the Minto Bridge got the headlines.
Project permitting, however, has not progressed at the rate anticipated in the June 2013 schedule. Several federal, state, and local approvals are required for the Project, including permits from the U.S. Coast Guard, U.S. Army Corps of Engineers, and the Federal Highway Administration. These approvals are required before the City can advertise for and select a contractor to begin construction work. To date, 14 of the 15 necessary permits and approvals have been received. The remaining permit, from the U.S. Coast Guard, is expected by early August. This is too late to allow for construction to occur during the allowable in-water work period for 2014. The City will determine the exact bid schedule when the U.S. Coast Guard permit is received. More competitive pricing from construction contractors is expected if the City advertises for construction bids in the final quarter of 2014....

Construction activity in and around Riverfront Park is unlikely to begin until the spring and summer of 2015. Completion of the Project is not likely until 2016. More details regarding the overall construction schedule will be available once a construction contractor is selected. The contractor will present a preferred construction approach that will address the complexity of constructing over 5,000 feet of pathways and a new bridge over a navigable waterway. The contractor approach and schedule will be impacted by federal limitations on construction activity in major waterways and wetlands. Construction in and around the Willamette Slough is allowed only from June 1 -October 30.
Traffic Circle at Boon's? And Summer Paving


A year and a half ago or so, there was a rumor about the prospect of a traffic circle at the triangular intersection of Liberty/High/Broadway. Contracts hadn't been awarded yet and folks weren't able formally to confirm anything.

At Council is a report about declaring a need for right-of-way at the intersection, and it looks like the traffic circle may be moving forward. Staff weren't able to confirm a traffic circle on Friday, so hopefully on Monday we can update the post.

A well-designed traffic circle could help circulation for people on foot, on bike, and in car here. This will be interesting to learn more about!

(Update: No traffic circle! Just a new light and reconfigured lanes.)

Also in roads...

Bikey Goodness in the Paper! Scotts Cycle and Second Chance Recycling

Two great bicycling stories in the Sunday paper.

From the piece:
Scott's Cycle is celebrating its 100th anniversary this year, no mean feat for a business that survived two world wars, the Great Depression, the boom in Internet retail and the rise of the big-box stores.

And consider this: The current owner, Larry Lewis, is just the second in the store's history and has been in the driver's seat, make that bicycle seat, of the business for 49 of those years.

So you've got to ask, when he showed up as a fresh-faced 23-year-old newly minted bike shop owner in 1965, did he think he would still be here in 2014?
This history will be the featured topic at the Salem Bicycle Club's meeting this week!
SBC General Meeting
Tuesday, June 24

The program will feature Christy Lewis from Scott's Cycle who will talk about the shop's 100 years in business -- the most in the Northwest. The meeting will be at the First United Methodist Church at the corner of State and Church Streets. Social time starts at 6:30 p.m. and the meeting starts at 7:00 p.m.
For more on Scott's see some early history here and more on the 50th anniversary here.

From the piece:
Two teens tinker with bikes hoisted onto stands while a third spins a wheel to see whether it is true.

They work independently, reaching for tools, tightening gears and checking each moving part until it sings. They could be in the back of any bicycle shop in the Mid-Valley, but they're not. Their workroom sits inside the Hillcrest Youth Correctional Facility.

High metal fences surround the property and locked doors limit movement between rooms and buildings, but the teens are masters of their own projects inside the bike shop. Every bicycle they finish provides transportation for a child or adult in need.
For more on Second Chance Bicycle Reycling, see notes here, here, and here and the Salem Weekly story here.

Update

Doh! Missed the South Salem Cycleworks recycling ad right next to the continuation on p.3 of the Scott's piece. Nice to see "transportation" and not just recreation called out!



Friday, June 20, 2014

Cherriots Comprehensive Service Analysis Out

Jarrett Walker and Associates has released the final system analysis, the Existing Conditions Report, and the Comprehensive Service Analysis.

The study usefully - if unhappily - complicates our understanding of local transit.

The scope of Cherriots' deline in funding and boarding numbers hasn't always been clear to those of us who don't follow transit closely - but this graph of employment and boardings shows how transit here is less and less an attractive choice for commuters (the graph does not, however, control for the loss of Saturday service, and so I think it overstates the decline in commuter boardings.)

That's a lot of decline in the number of boardings and customers! There are other dispiriting graphs, too.

It's a tough nut to crack.

A Giant Lacuna

There are other tough nuts.

I get that the job of Cherriots isn't to save Salem from its own terrible choices.

But I still expect a transit agency to think strategically about the folly of the Third Bridge.

In the 80pp Existing Conditions Report, the word "bridge" appears six times. In the 62pp Comprehensive Service Analysis, it appears once.

Seven times! You'd never guess that a billion dollar bridge and highway was being planned or that investments in transit might a cheaper and more cost-effective way to improve mobility.

But here's the thing: Even an inefficient transit system has to be cheaper than a giant bridge and highway!

And disinvesting in West Salem transit will only tend to increase drive-alone trips and pressure for a third bridge.

Fortunately there is a little bit of talk about land use.

The study recognizes that a lot of new development in Salem is car-dependent and "sited and designed in a way that makes them expensive and awkward to serve [by transit]." Other development is "low density and unlikely to ever generate much transit demand."

West Salem, too
Land use pattern is key, and we aren't going to make very good progress until we start integrating land use and transportation planning so that people feel realistically that they have a menu of transportation choices they can easily shift between.

We also have to be willing to talk about ending free parking and starting to toll the bridges. If we want demand for transit, we have to end the subsidies for drive-alone trips, or at least to incorporate better pricing signalling into each trip.

Maybe there will be more to say in another note.

Both this study and the flexible transit study will present to the Board on Thursday the 26th. The Board meets at 6:30pm, Courthouse Square, Senator Hearing Room, 555 Court St NE.

The Comprehensive Service Analysis and Existing Conditions Report are available as very large pdfs. Other docs here at the Board agenda.

Thursday, June 19, 2014

Sustainable Fairview Files to Demolish Six Buildings at Former Training Center

Last week it looks like on the 12th, Sustainable Fairview Associates filed for permits to demolish some of the old buildings out at the former Fairview Training Center.

One of the halls likely to be demolished
(I think this is Chamberlain)
There are six permit applications all listing 2250 Strong Road. (You can search here, but individual permits aren't linkable, alas.)

Withycombe, Smith Cottage, Chamberlain, Kozer, and "House" (x2) are listed on the permit applications.

Originally called the State Institution for the Feeble-Minded, and established in 1907, the Training Center was closed in 2000 and sold to Sustainable Fairview in 2004.

The plan for Fairview was to reuse some of the buildings, but not all of them.

Reuse Plan from Fairview Master Plan
(Click to enlarge, inset detail added)
Originally in the Master Plan, "SFA [Sustainable Fairview] intends to restore and reuse the existing buildings wherever possible," but the set of demolition permits represents a change, as the particular buildings here proposed for demolition were first identified for "full renovation within 10 years" rather than for demolition. (They are in the arc of buildings in light robins egg blue.)

So, is this a preservation moment?

Wednesday, June 18, 2014

Public Works Day will Never Tire of Bob the Builder Template

Public Works Day is tomorrow, June 19th.

Much of what was true in the past remains true this year:  With an educational component that needs to be accessible for families with kids, there's always more than a little of "Bob the Builder" about it.

That's great an all, but the emphasis is on cars, and gas- and diesel-fired heavy equipment - big toys and the infrastructure they build and maintain.

These are important things, of course, but as the City announces over-and-over new rounds of budget cuts, maybe it's time to talk about low-cost forms of infrastructure and maintenance? You know, with the TSP updates for walking and biking, public works can talk more about how cost-efficient are forms of mobility other than the drive-alone trip. Let's talk about the price of gas and of asphalt, talk about studded tires and resurfacing schedules! How about the cost of the giant bridge and highway? What about drought, climate change, and our tapwater supply?

"A Great Bridge will Lead us to Awesome Prosperity"
Landsberger Collection
We're already talking about salmon.

The Salmon from 2012 announcement
Public Works Day offers a chance to frame some new messages about efficiency and economy. (I know:  NO FUN.)

Tuesday, June 17, 2014

Economic and Housing Study Largely Ignores Transportation: EOA-HNA Meets Thursday

The Economic Opportunities Analysis (EOA) and Housing Needs Analysis (HNA) meets Thursday the 19th, but so far the analysis is missing big-time on transportation!

The "life cycle" abstracts mobility out of the picture!
Transportation and access to goods/services is invisible
(this clip occurs in several docs)
Appealing to a picture is by itself not proof, but the absence here of transportation and the movement in and out of goods and services is consistent throughout all the preliminary materials. There's an invisible teat of autoism and supply!

But of course, the bulk of the "buildable" land is on the edges of the city, distant from employers and not yet served by neighborhood and walkable businesses. It's pretty much all heavily car-dependent. Is this in fact where we want to put growth? (Tonight, in fact, the Planning Commission will hear an appeal on a 140-lot subdivision out in West Salem.)

Development and growth on the car-dependent edges
(from the May slide deck)

The Study's data on housing doesn't capture
transportation costs and trade-offs
(from the June draft analysis)
In the draft analysis, the word "transportation" appears only four times, and the authors admit "they do not capture the tradeoffs people make to hold down their housing costs."

Monday, June 16, 2014

How much Worse would a Marion Parkade Library Actually Be?

The 2011 library in Vantucky
Miller Hull Architects
So how is it that even in the land that hates light rail, they still put together a new library?
The district went to Vancouver voters three times to pass a bond measure to build the new library and replace another, the 24,175-square-foot Cascade Park Community Library that reopened in 2009. The first two fell short of the 60 percent needed – by just half a percent in 2006.

But before a third vote in 2006, the Vancouver-based Killian Pacific development company donated a downtown site for the new building and an anonymous donor put up $5 million for the project. A $43 million bond measure to build the new libraries passed with 63 percent of the vote.
Folks are getting all worked up over the idea that the current Library might be repurposed for a new Police Station. "Hands off," they say.

But again, the current library is a charmless concrete bunker.  Why not consider an opportunity to upgrade? If Vancouver can do it, surely Salem can, right?

So here are some thoughts....

Sunday, June 15, 2014

Baseball's History Here is also the History of the City

You might remember last spring when folks in NEN-SENSA met on the airport and Mission Street area.  The meeting notes had more on the old auto dealership site at 25th and Mission:
Jim Green gave an overview of his family’s vacant property on Mission Street, which was formerly an auto dealership. A 4.5-acre portion of the property has been sold to Power Mission, a car dealership, leaving 17.5 acres for sale. He provided a brief history of the property and discussed his family’s efforts to redevelop it into a variety of uses, including a Trader Joes, REI and Panera Bread. Jim said Salem’s demographics as well as difficult site access have made the property unattractive to those and other desirable users. He added that his family has turned down other uses such as a McDonald’s Restaurant and Subway Restaurant and is instead looking to create a destination at the property that enhances the city. His family has met with City and Airport officials about possible uses, including a hotel. Jim also told meeting participants that he and the City would like to see a new road be built that connects Airport Road SE and 25th Street SE; the project is proposed to be added to the City’s Transportation System Plan.
Before the Post Office and before the car dealerships, there was baseball at 25th and Mission!

Waters Field was still on the edges of the city, but at least it was only a couple of miles from downtown, and the Geer line probably served it with rail. Keizer Station and Volcanoes Stadium is oriented to I-5 rather than to any municipality's center.

From Waters Field to Volcanoes Stadium
You can read more about the Salem-Senators and Waters Field here. Mission Mill's summer exhibit on local baseball, "The Boys of Summer," opens June 20th.

When you go, think about the urban forms, urban development, and transportation history expressed in conjunction with the history of baseball.

And think about what a varied history that 25th and Mission site has seen.

(Maybe there will be more to say later after the show opens!)

Saturday, June 14, 2014

Councilor Clem LTE on Third Bridge

Councilor Clem had a letter to the editor yesterday. Others have ably commented on it at the paper, but since it and the comments will disappear into the archives, it seemed worth some duplication.

You can decide how factual or informed it is. But from here it looks like an excellent example of the way support for the bridge is more a political performance of rhetoric and wish than a policy analysis of fact and probability.

Comments are keyed to red numbering in the graphic.

(click to enlarge)
1) "Previous solutions haven’t worked (widening existing bridges or doing nothing) and aren’t seismically safe for the future."

The Salem Alternative is in a liquefaction zone
(via N3B, adapted from chapt 3.18 of the  DEIS)
2) "a funding strategy based on possible sources from local, state and federal transportation funds."

Official River Crossing FAQ on Funding:
"Will the state and feds...pay for the project? No"
3) "Transportation solutions take decades, just like transit, biking, rail and building Marion and Center Street bridges have."

Friday, June 13, 2014

Two Studies: West Salem Business District and Cherriots Flexible Transit

There's a couple of studies going on that involve West Salem, one for transit just wrapping up, the other for the Third Bridge and just starting.

Capturing the Ride - Flexible Transit Analysis

The final memo for Paradigm Planning's "Capturing the Ride" project is now out.

Nothing on the third bridge
It seems uncharitable to criticise a student project, but in at least one important way, the final project of PSU Masters students comes up short.

In Paradigm Planning's overview on West Salem, there's no mention of the Third Bridge planning process, and no mention of the way building a robust transit system in West Salem will help reduce pressure to spend hundreds of millions of dollars on a giant bridge and highway.

This is a key fact about transit in West Salem, and they ignore it.

This may not be any fault of the students, and may well arise from instructions and scope from Cherriots. But the thing is, this analysis of transit in West Salem is being driven at a low, tactical level by budget constraints, instead of being driven by high-level strategy about avoiding an extraordinarily expensive bridge and highway and growing transit in Salem.

The introduction alludes to this:
[A]uto-oriented neighborhoods are increasingly being inhabited by transit-dependent individuals with mobility restrictions due to not being able to own or operate a car. Furthermore, the Great Recession has meant significant cuts in federal and local funding, cutting transit agency budgets and leading to subsequent cuts in service. Transit agencies are now tasked with the responsibility of figuring out how to serve transit-dependent communities in auto-oriented developments with less funding.
"Serve transit-dependent communities in auto-oriented developments with less funding" sounds nervously like circling the drain, a race to the bottom, don't you think?

Thursday, June 12, 2014

Autoism's Relentless Appetite: Third Bridge, Highway 22 Crash, Hospital and Church Parking - updated

Whether it was merely in passing or was part of an assignment, at least one reporter tweeted about yesterday's rally.

Interestingly, though, it was a project about 2% the size of the giant bridge and highway that got the front page treatment today.

I think they picked the wrong rally!

Of course the problems are related, and the proposed solutions participate in the same car-logic: It's all about faster travel. Rather than accepting slower speeds, we have to engineer things to maintain or increase speeds and through-put and to engineer things in a way that "forgives" driver error, which includes speeding or errant turning.

Her husband also died
The crash was at the Doaks Ferry intersection, though the cars ended up in the restaurant parking lot and it's not clear that any of the impacted drivers were trying to turn on to Doaks Ferry. Still, with Highway 22 here as one of our worst "stroads," a dangerous hybrid of local street and high-capacity through-road, there are multiple factors that contribute to crashes. (Those who perished were 90 and 91, and it's also possible that slowed reaction times contributed. Our weak transit system also fails seniors as a strong alternative to driving.)

Howard Hall

Old City Hall (with Parking Meters!)
 on Chemeketa and High, 1959
Salem Library Historic Photos
Tonight the Historic Landmarks Commission meets to continue the Public Hearing on the Hospital's proposed demolition of Howard Hall for a parking lot. (Full document library here.)

Wednesday, June 11, 2014

New Panera Block Puts Parking in Back

The new Panera on middle Commercial opened the other day, and it is a striking 180-degree turn from the old Weathers building. Parking is in back rather than front, and outdoor cafe seating faces the sidewalk on Commercial and Liberty.

After: New Panera on middle Commercial

Before: The Old Weathers Music Store Lot
Notice parking along sidewalk
(click to enlarge)
But the building is still unsatisfying in important ways. More than anything, the set-back and expanse of bark mulch through which a mini-swale winds, creates too much separation from the sidewalk and keeps the building feeling suburban, mall-ish, and car-oriented rather than urban and fully walkable.

The Patio and Swale
It's still not integrated with the sidewalk. The outdoor seating should be an extension of the sidewalk, but instead it looks like a back yard, just rotated around 180-degrees.

Tuesday, June 10, 2014

No Third Bridge to Rally Before Wednesday Transportation Open House

Tomorrow at 4pm on Wednesday the 11th, No Third Bridge will hold a rally in conjunction with the dual Open House for the Salem River Crossing and Salem-Keizer Area Transportation Study.

SKATS/SRC Open House Announcement
(with N3B, of course!)
Rally organizers say:
We will assemble on the sidewalk in front of the Court Street entrance to Courthouse Square beginning at 4 pm. We will have remarks from NO 3rd Bridge activists beginning at 4:30. Then at 5 we will attend the Open House at Courthouse Square en masse. Please come and show your support for NO 3rd Bridge.
In addition to the festivities and "information" about the Salem Alternative and progress on the Environmental Impact Statement, there will also be information about the 2015-2020 Transportation Improvement Program.

Brochure detail with map and partial project list
There's also a handy website with a full list and some other features. (You can read commentary from April here, as well as a slightly different way of looking at bike/ped projects, some of which use bike lanes and sidewalks as a way to facilitate road widening, and from here don't really qualify as primarily bike/ped projects.)

While the bridge deserves nearly endless criticism, there are other good and necessary and even wonderful things in the project list - like the intersection work for Union and Commercial, which will complete a critical gap in the eastside approach to the Union Street Railroad Bridge and a future Union Street bikeway. (So be open to dual perspectives! It's necessary to be cranky and cheerful in rapid succession.)

East/right side of Union not included in project
One project with new detail is the Doaks Ferry realignment at Highway 22. Maybe you saw the piece in the paper yesterday.

The new alignment will go through the old town of Eola/Cincinnati.

If you haven't biked through Eola, take a moment to do so, because it will be changed. The old streetgrid is a reminder of another era.

(Also in history, in a window display on Court Street, fronting the Senator Hearing Room, I think, there's a nice historical piece on the Derby Building and its growth into the Senator Hotel - which was demolished for Courthouse Square. There are pictures from each decade or so showing the storefronts and streets.)

Monday, June 9, 2014

In the neighborhoods - Howard Hall and the Third Bridge Study

"Wildlife" at Mirror Pond!
Tonight at Council doesn't bring much of significance (maybe more on food than anything else!), so here's a few bullet points and links to staff reports.
(Maybe it was too sunny this weekend, too...)

This week's neighborhood meeting are more interesting for our purposes.

Morningside - Wednesday

On the agenda:
Madrona at 25th Intersection Improvements and Kuebler at Commercial Intersection – Gary Myzak Program Manager, Aaron Edelman, Project Manager and Steve Ward of Westech Engineering;
Project Scope on 25th and Madrona
Morningside meets Wednesday the 11th at 6:30 p.m. in the Pringle Creek Community Painters Hall, 3911 Village Center Drive SE.

SCAN - Wednesday

OSU Library, 1919 - John Bennes
The arch/dormer detail at the entry and side looks familiar?
OSU has a nice flickr stream of Bennes buildings
On the agenda:
[7] Oregon Architectural Legacy of John V. Bennes - Larry Landis, Director, Special Collections & Archives, Oregon State University Libraries; [8] Lord & Schryver/Gaiety Hollow Update;
Holy Smokes! The document truck backed up and dumped a few more loads of documents at the City site on Howard Hall. I don't envy the volunteer Commissioners, who presumably will need to read every one and come to a nuanced legal opinion. And there's going to be more! - a couple of response and rebuttal rounds, it looks like.