21st

CENTURY ALTERNATIVES to the

proposed SANTOLINA DEVELOPMENT PLAN

TABLE OF CONTENTS

INTRODUCTION: The Purpose of this Paper

The PROBLEM:
Section A. Why an Alternative Solution for Santolina? (p.2)
• Background and Context (p.3)
• Alternatives for Westside Development and Job Creation (p.3)
• The Cost of and Alternatives to Sprawl (p.4)
• Economic Assessment and the Potential for Collaboration (p.5)

Section B. Santolina Economic Considerations and Risks (p.6)
• Economic Impact of Santolina and 20 Tax Increment Development Districts (TIDDs) (p. 6)
• The “No Net Expense” Requirement (p.7)
• Land Values and WALH’s Projections (p.8)
• Analysis of Consultants' Costs and Tax Yield Projections (p.8)
• Economic Context and Site Conditions (p.10)
Map 1: 1974 USGS Survey, West Mesa Dune Conditions (p.11)
Map 2: Santolina Boundary & Roads on USGS Dune Conditions (p.12)

RECOMMENDED SOLUTIONS:
Section C. The Renewable Energy Strategy and Projections (p.13)
DRAFT

• Need for a Regional Energy Strategy (p.13)

• PV Array Development Strategy (p.14)
• Example of PV Array Design (p.15)
• Cost of the PV Array and Net Revenue (p.15)
• Projected Development Cost and Revenue Comparisons (p. 16)
• Consideration of a Public-Private Partnership (PPP) (p.17)
• Site Options Considered (p.18)
• Potential for Wind Powered Electric Generation (p.19)
• Opportunity for Tourism Revenue (p.19)

Section D: Creating a Metro-Connecting, Grid & Perimeter Transit Plan (p.19)

Section E: Achieving both County & City objectives in the CompPlan (p.20)
• Historic context (p.20)
• The “A/BC Comprehensive Plan Update” (p.22)

Section F. Benefits of the Modified Santolina & Integral CompPlan Recommendations (p.23)
• Summary of Potential Benefits and Recommendations (p.24)

Endnotes: (p.26)

Illustration 1: “A Vision for a Metro-Connecting Transit Plan” (p. 29)
Illustration 2.1: “New High Desert Design" (p. 30)
Illustration 2.2: “New High Desert Design" (p. 31)
Illustration 3: “A 21st Century Alternative to the existing design for Santolina" (p.32)


21st CENTURY ALTERNATIVES to the
proposed SANTOLINA DEVELOPMENT Plan

By Paul Lusk and Julia A. Stephens

November 13, 2018

INTRODUCTION: THE PURPOSE OF THIS PAPER

In April 2015, in presentations to the Greater Albuquerque Association of Realtors, as well as to
others, two development experts advised that: “… demand for sprawl development is generally over”
(Dr. Arthur Nelson 1), and that “Successful cities are distinctive cities.” (Ed McMahon, ULI2). Both
experts also recommended to define and emphasize the unique aspects of this area, or any area, as
the basis of well being and the catalyst for sustainable growth.

The proposed Santolina development, however well intentioned, unfortunately is a prime example of
‘continued sprawl’. It also is not a ‘distinctive development’; it could be anywhere, that is, anywhere
with nearly flat ground. If the Greater Albuquerque Metropolitan Area wants to prosper in the 21st
century, it must recognize and emphasize its unique regional and cultural advantages as the basis and
essence for its well being and growth.

The purpose of this Paper, in recognition of the importance of this advice, is to address the very large
community development project presently under review by the County, the proposed Santolina
development, and to present a choice of lower-infrastructure-cost/greater-tax-yielding/regionally
and culturally more appropriate options to the present design of this project.

If Option 1, the modified Santolina site is pursued, the primary strategic actions proposed in this
Paper, are to:

• Replace 7000 acres of the primarily low-density, 20th century, suburban-style, ‘drive-to-work’
residential area, and the undefined ‘urban center’ in the mid-portion of the present design, with a
new, high performance, single-axis, photovoltaic array, implemented in strategic coordination
with PNM or, if appropriate, other energy development partner(s). (See Section C, pp.13-19)

• Locate the 2000-acre industrial development proposed on the northern and western portions of
the Santolina site, in parallel to the area north of I-40, emphasizing high-tech and support
industries for the evolving importance of the Double Eagle II airport. (See Illustration 3, p.32)
The 2000-acre area shown in blue on the present Santolina site plan as a colored ‘bubble-diagram’
does not have a basis because there is no business plan adopted as part of the Master Plan
document. (Ref. Santolina Level A Development Agreement, 8.10.2015, Item 4.4)

• Implement a new ‘High-Desert Community’ development, including terraced, through-apartment
units, and single family, cluster and courtyard housing, a 600-acre public park, as well as
commercial, schools and other community elements on the eastern portion of the modified
Santolina site. (See Illustration 3, p.32)

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• Minimize water use for the entire site, and then biologically treat and recycle the wastewater for
irrigation of the major ‘Central Park’ and other landscape areas. Also, design the storm water
management system to minimize runoff, reduce volume and velocity, and utilize excess to irrigate
floodable landscape areas.

• Implement the ‘grid and perimeter’ transit system serving the High-Desert community area as well
as the job-intensive, 2000-acre Santolina industrial area and the areas adjacent to the Double
Eagle II airport. (See Section D, p. 19, and Illustration 1, p. 29)

Alternatively, if Option 2 is pursued, implementing the full-site PV energy generation system, it
would replace a major portion of the area of the present Santolina site plan with a larger solar energy
array serving local energy demand, as well as the existing generation units’ retirement and
replacements needs, plus a larger capacity for offering Western Energy Imbalance Market (Western
EIM) electrical energy production.

THE PROBLEM

The 13,850-acre approved Master Plan for the Santolina site (but not yet granted zoning change from
A-1 to PC zone), unfortunately, presents significant economic, environmental and planning
challenges for Bernalillo County and for its citizens. Competition among urban centers in the U.S. will
inevitably intensify in the coming years; ultimately creating cohorts of communities that will thrive
as well as communities that will struggle to compete. Some likely will become increasingly
endangered as viable local economies, due to ineffective and archaic economic planning and
development. The proposed Santolina development, as it is presently designed, represents this kind
of obsolete planning.3,4,5,6,7

The future of Albuquerque and the adjacent communities in the Middle Rio Grande Region are
integrally tied together, a dynamic that will inevitably become increasingly important in the coming
years as economic, energy, water and other 21st Century pressures intensify throughout the
Southwest and the rest of the Country. Although this Proposal does not specifically address the
critical water issues facing the Region, local water experts have spoken clearly about Santolina’s
impact that would rapidly become acute.8 (Also see Conditions of Approval, staff to CPC, 10.1.14,
#11, requiring agreement with ABCWUA prior to a Level B approval.)

In view of these exigencies, the impact of the existing arrangement of the proposed Santolina
development, on the regional economy, as well as the quality of life of the Region’s citizens and
business community, need to be carefully assessed. If a better alternative exists, it is incumbent on
community leaders and local citizens to consider such an alternative, assess its potential and
compare it to the proposed Santolina development. This Proposal is intended to serve as such an
alternative.

Section A: WHY AN ALTERNATIVE DESIGN FOR SANTOLINA?

This Proposal does not oppose development on the West Mesa. Indeed, increasing the prospects for
jobs and economic development on Albuquerque’s West Side is one of the primary objectives
inherent in this recommended modified site plan. Sustainable West Side economic development
becomes significantly more realistic and feasible when undertaken using urban/suburban growth
and development strategies that avoid highly speculative and inefficient sprawl development.
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Analysis undertaken as part of this Paper indicates that modification of the present design of the
Santolina proposal could be a key first step in a longer-term strategy -- a strategy that would be
substantially more economically advantageous to Bernalillo County than proceeding with approval
and construction of the Santolina development as presently proposed.

Background and Context
Some historical perspective is useful in setting the context for this Proposal. For decades, the City of
Albuquerque’s policy was to capture and annex all development that took place on its edges. This
deprived the County of necessary revenue, despite the fact that the County bore the brunt of some of
the increased traffic and maintenance resulting from these developments.

This aggressive City annexation strategy, and its concomitant revenue shift to the City, caused the
County to seek relief from the legislature, initially to contain the City’s capture of edge development,
and subsequently to establish Bernalillo County as an “Urban County.” Although Bernalillo is not an
“urban county”, this designation allowed the County to be its own master. One of the County’s initial
actions under this new designation was to consider a major new development called Santolina, the
largest development of its kind ever to be considered by the County.

Some County leaders may have perceived Santolina as a great economic boon and a potential source of
significant new revenue. However, further analysis suggests that the cost of the proposed Santolina
development to the County, as well as to the City and other jurisdictions in the Region, if it were to be
built, would significantly exceed the projected benefits. (See Section B, pp. 6-10)

Alternatives for West Side Development and Job Creation
Expansion of appropriately scaled industrial development in the area of the entire West Mesa,
including, in Option 1 of the modified Santolina plan, 2000 acres in the Santolina area, as well as the
area north of I-40 -- perhaps as part of an expanded Double Eagle II Airport -- is emphasized in this
modified proposal. This is in addition to developing previously approved, committed-to-be-served
areas on the West Side. This growth pattern would provide real capacity for regionally important job
creation and economic development within all three of these areas. Development in these already
approved areas, and in the alternative industrial area, as shown in Option 1, the modified Santolina
plan, would be pursued in lieu of the presently configured Santolina site plan.

This strategy would enhance the West Side’s, as well as the Metro area’s economic viability and
resilience by precluding additional, unnecessary and costly horizontal expansion and increased
suburban sprawl. This is an objective that cities throughout the world are realizing is increasingly
urgent and essential to their own long-term economic viability.9,10,11,12,13

Both strategies, i.e., new West Mesa industrial development and development of currently approved
areas on the West Side, would provide realistic opportunities for West Side job creation and
realization of other key economic and sustainability objectives at significantly lower cost.

Evolution of a more resilient vision for the Metro area builds on the assumption that Middle Rio
Grande Region citizens aspire for their communities to be unique and desirable places in which to
live. In order to realize this vision, some adjustments need to be made to the Metro area’s historic
growth and development patterns. (See “SPR2016-0001 PUBLIC HEARING: Santolina Level B.I Master
Plan”, Attachment #14, pp 11- 7914)

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The economic assessment recommended in this Paper should objectively determine whether the
alternatives proposed herein are a more realistic, economically sound and sustainable use of this
large parcel of land than the presently proposed design of the Santolina development. It also should
determine if the long-term costs incurred by local citizens, if the proposed Santolina project were
built as designed, would exceed the development costs of either of the proposed alternatives.

The alternative development patterns being proposed here are no more challenging or complex than
the likely extended litigation and extensive regulatory review and approval processes that are
currently underway, many of which could be avoided if the alternative proposed herein were to be
pursued. However, it is important that prudent and timely action be taken and that a decision be
made before the zone change entitlement requested by the Santolina site owners is granted.

The Cost of and Alternatives to Sprawl
According to contemporary urban design research, sprawl development costs the public more than
twice as much as more compact development.9 Santolina’s mid-20th century sprawl-design is
obsolete and counter-productive in terms of meeting the rapidly growing need and preference for
resilient, sustainable development and design. Examples of Santolina’s archaic design include:

• Four very large suburban areas located around a generic central “urban” business district.
The clear separation of work, housing and business areas would require most residents to
drive to work and to shopping areas.
• A 2000-acre, separated, drive-to-work industrial area at the highest point of the water zones,
• Two separated “Business Parks” and a “Town Center” facing the Freeway, not the community,
and
• A Master Plan layout with arterial roads projecting west over the steep cliffs of the Rio Puerco
escarpment, and south into the Pajarito Grant area -- as if more suburban sprawl would
continue on forever. (See Santolina Master Plan, Exhibit 7)

These Santolina site plan and design features fail to address the goals and policies stated in the A/BC
Comprehensive Plan Update.15 They also are not a good fit for the 10-15 foot high, longitudinal-dune-
covered, wind-swept West Mesa. Specific details of this inappropriate land use are described more
fully in Section B below.

The modified Santolina alternative configuration, Option1, as presented in this Paper, places the
2200-acre community development area east of the 345 KV power line and Atrisco Vista Blvd. This
area also would be accessed by the Perimeter Transit alignment (as recommended in Section D), and
located directly east of Atrisco Vista. The Community development includes ~ 800 acres of High-
Desert development (see Illustration 2 for prototype examples of High-Desert building types), and ~
700 acres of single-family, cluster and courtyard housing. Based on the potential attractiveness of
the new High-Desert designs to both builders and residents, (as well as the courtyard and cluster
designs), the use of TIDDs may not be appropriate or needed.

The new arrangement also has a ~600 acre ‘New Central Park’ area (just slightly smaller than Central
Park in NYC). The Park, spanning both sides of Sen. Dennis Chavez Blvd, would be irrigated by
recycled water -- including that is water polished in two large glazed, interior flower and garden
spaces similar to the Mazria-designed greenhouse structure at Biopark.

The 2000 acres of new industrial development and the 2200 acres of multi-use community area,
including 300 acres of commercial, 1500 acres of high and low density housing providing
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approximately 18,000 dwelling units, plus the 7000 acres of photovoltaic development -- whether in
a public, private, or a partnership arrangement -- will require, of course, a more detailed analysis.
Our estimates, though, indicate that the greatly reduced infrastructure costs, the significantly
reduced water demand, and the multiple sources of revenue would result in a substantially greater
net tax return than the present design of Santolina. This alternative is not ‘more sprawl to the west’,
but is part of a perimeter-ring of intentionally located High-Desert, transit-served development
which clearly defines the edge of current urban development. Although it is a part of the County, this
High-Desert community development marks a clear separation from the large photovoltaic area to
the west. (See Illust. 3, p.32, “A 21st CENTURY ALTERNATIVE to the existing plan for SANTOLINA”).

Economic Assessment and the Potential for Collaboration
Effectiveness in moving forward with either site Option will require collaboration between Bernalillo
County and the City of Albuquerque. Unless these two jurisdictions can succeed in collaborating on
major matters such as this, it is likely their continued bifurcation will become an increasingly
burdensome economic millstone for the citizens of both jurisdictions for many years.

The jointly adopted County/City “Planned Communities Criteria" (PCC) requires that development
agreements that impact the County economically must be reviewed and concurred in by the City.
(See: Bernalillo County Resolution (AR 158-90), page 14, Policy II.B.2.d, and Section 4, p.15-16.)

This Proposal recommends that Bernalillo County, in cooperation with and assistance from the City
of Albuquerque, undertake an objective, comprehensive fiscal analysis and risk assessment of the
long-term economic, environmental and social impact of the presently proposed Santolina design.

This analysis and assessment should include an objective, comparable assessment of the alternatives
presented in this Proposal, including their risks and potential benefits. The assessment should be
conducted by a non-politically and economically connected expertise respecting sound urban
planning and design principles and with a long-term, economically sustainable vision for this
community and region. This vision, then, should be made explicit in both the text and maps of the
updated, jointly adopted Albuquerque/Bernalillo County Comprehensive Plan.
Specifically, the assessment should include:

• An independent fiscal analysis of all Santolina-related direct and indirect costs of tax-
supported infrastructure (e.g., public roads, schools, utility and service costs both inside and
outside of Santolina’s boundaries), in addition to the long-term costs of the 20 taxpayer-
supported TIDDs (Tax Increment Development Districts), paid by all City and County citizens.
• Other direct, indirect and external costs that the County, City and State, and adjacent
jurisdictions, would incur if the currently approved design for the proposed Santolina
development were to be built.
• An economic, environmental and social cost/benefits comparison with either of these
modified arrangements, and of the implications to County costs and revenues implied.
• An assessment of the potential impact of the proposed grid and perimeter-based public
transit system, in either Option 1, or Option 2. (See Section D, p.19)
• Exploration of partner agreements among all related stakeholders to establish renewable
energy generation that serves the power needs of all of the residents of Bernalillo County and
the infrastructures that serve them.

This assessment agrees with the “Health Impact Assessment on the Proposed Santolina Development ”
report submitted to the County Planning Commission, October 1, 2014, by Bernalillo County Place
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Matters, which recommended that the County:
• Conduct an independent economic analysis of the proposed (Santolina) development costs to
the County, including State, County, City, State and Federal liabilities, and
• Conduct an independent cost-benefit analysis of the proposed (Santolina) development for
taxpayers of Bernalillo County and the City of Albuquerque.


Section B: SANTOLINA DEVELOPMENT ECONOMIC CONSIDERATIONS AND RISKS

In the process of assessing the pros & cons of the alternatives to the presently configured
Santolina development plan as described here, certain important economic aspects, risk and related
factors need to be considered by the County and, to the extent that they may be impacted, by
surrounding jurisdictions. For example:

The Economic Impact of Santolina and 20 Tax Increment Development Districts
Exploration of more feasible alternatives to the current arrangement for the Santolina development
must include a careful review of the 20 TIDDs that have been approved by the Bernalillo County
Commission (BCC). All City as well as County taxpayers would pay taxes to cover these TIDDs.

On February 29, 2016, WALH submitted an application to the Bernalillo County Commission (BCC)
for formation of an Intent Resolution for the Santolina TIDDs. Initially 40 TIDDs spanning 60 years
were requested. This request was based on a January 21, 2016 report, entitled “Fiscal and Economic
Impact Study, Santolina Master Plan (Level B)”, prepared by David Taussig & Associates, a Newport
Beach, CA based firm retained by WALH.18 Following adoption of the Intent Resolution on October
11, 2016, County Staff and WALH negotiated and agreed to amend the Application to 20 TIDDS over
50 years.

Table A (Page III/Packet, p.139) of the Taussig study projects $28,095,853 in ”Total (Annual)
Recurring Revenues for General Fund plus Dedicated Funds”, including property and gross receipts
taxes, fees, fines and other. Table A also projects $11,805,126 in “Total Recurring (Annual) Costs to
the County General Fund”, thereby projecting a net of $16,290,727 “Annual Recurring Surplus”.
Using the Taussig 60-year projection period as a basis, the average yearly net tax revenue yield to the
County would be +/-$977 million over the course of the 60-year period.

The Taussig study qualifies its findings by stating, “all calculations are based on information supplied
by WALH and Garret Development Corp”. (See p. 5, Section II. “Limitations and Accuracy of
Information.”) This qualification pertains to their projection of ~75,000 jobs, 38,000 households and
project completion by the end of the 60-year period. There does not appear to be any independent
analysis or evaluation of these assumptions by Taussig & Associates, or by any other objective
source, prior to the October 11, 2016 BCC approval of the Intent Resolution.

Subsequently, Impact DataSource, an Austin, TX based firm retained by Bernalillo County Economic
Development, prepared a report dated November 6, 2016 entitled, “A Report of Economic and Fiscal
Impact of Santolina TIDDS in Bernalillo County, New Mexico”.17 On Page 10, Table 12 of that Report,
Impact DataSource projects a total of $7,798,486,092 in “Net Tax and other Revenues”, less
$2,282,056,844 in County services cost over the course of 50 years, thereby producing a total net
benefit to the County of $5,516,429,248, or an average of $110 million/year.

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In order to compare the Taussig and Impact DataSource studies, some extrapolation between their
respective 60-year and 50-year projection periods is required. If a 50-year projection period were to
be applied to the Taussig figures, the total 50-year net benefit to the County would be +/-$815
million (vs. +/-$977mllion over 60 years). This is in contrast to the Impact DataSource projection of
+/-$5.5 billion in net benefit to the County over a 50-year period. This represents nearly a 7-fold
variance between the two projections.

It is unclear from the Impact DataSource Report how their figures were derived, or why they differ so
markedly from the Taussig figures. Once again, multiple tables of data analysis are presented, but the
basis for key assumptions and projections is missing. Therefore, it is urgent that the County
documents the basis for the assumptions and projections contained in these two studies and
reconciles the unexplained, significant variations in calculated “benefits” to the County between the
two studies.

The total cost of County services to the Santolina development related to the 20 TIDDS, as identified
in Table 6 (unnumbered 7th page) of the November 6, 2016 Impact DataSource Report, entitled, “A
Report of Economic and Fiscal Impact of Santolina TIDDs in Bernalillo County, New Mexico”, would be
$2.28 billion.19

Based on information provided by the County in the TIDD Development Plan (Bernalillo County
Resolution #2016-83, November 15, 2017), it appears that the estimated cost of constructing the
Public Improvements is $2,675,317,903 (2015 dollars), which includes $1,949,754,148 (2015
dollars) in cost associated with the “District Funded Public Improvements”.

Approval of the 20 TIDDs on October 11, 2016 occurred despite a provision on page 5, Section 5.5 of
the August 2015 "Santolina Development Agreement", signed by WALH and the County, that
states, "Nothing in this Development Agreement shall commit this current Commission and future
Commissions to public funding or financing mechanisms." (Doc #2915073125, hand-dated, “the
10th day of August 2015”)

The "No Net Expense” Requirement
Limiting identification of Santolina development costs to only those incurred by the County appears
to be in direct conflict with the requirements of the ”Planned Communities Criteria” (PCC) ordinance,
as jointly adopted by both the City and County (See discussion in Exhibit A, Attachment G of the letter
and Proposal submitted the BCC 8/7/17). The PCC identifies impacts to "governments", in the plural,
and includes "no net expense to the City" (AR 158-90, Policy II.B.2.d, p.14). (See: Bernalillo County
Resolution (AR 158-90), page 14, Policy II.B.2.d, and Section 4, p.15-16.)

Furthermore, the incurrence of these expenses ignores the requirement, as adopted in County
Resolution AR 158-90 that states, "…phasing of planned communities through development
agreements between the communities, developers and the City as well as other appropriate units of
local government should be established…to assure reasonable and equitable allocation of financial
responsibility for capitalization…” (See Bernalillo County Resolution (AR 158-90), page 14, Policy
II.B.2.d, and Section 4, p.15-16.)

The fact that the proposed development is in the County, and is under review there, does not
abrogate the requirement adopted in the PCC resolution that development agreements impacting the
City economically must be reviewed and concurred in by the City. This is a major oversight by both
the County and the City that needs to be addressed.
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Land Values and WALH's Projections
Some restraints and penalties for exceeding the “no net expense” provision were put in place for the
20 TIDDs. However, no penalties or claw-back provisions are evident in the consultants' documents
for non-performance or other failures by WAHL, or by subsequent developers to whom portions of
the area may be sold.

The projections by both the Taussig and Impact DataSource reports must be seen in the context of
the existing conditions on this portion of the West Mesa area. They are:

• The present assessed land value of the Santolina area, under Greenbelt Grazing tax status, is
$4 per acre, or +/- $55,000 for the entire 13,850-acre site.27

• The present market value for A1 zoned land on the West Mesa adjacent to the Santolina site
averages around $600/ac., or +/- $8 million for the entire site.27

• If the “Planned Community” (PC) zone-entitlement to the land were granted for the proposed
Santolina development, the present value of ~$600/acre, would likely increase significantly,
perhaps to as much as +/-$10,000/acre. This would enable the landowner to realize a
+/-$130 million increase in market value. This increase in land value would not be due to
improvements made to the land. Instead, the public, not the landowner, would create this
Increase in land value as a result of the County Commissioners, representing all of the
Bernalillo County citizens, granting PC zone status to the Santolina developer, (See Section E,
p.20). If this were to happen prior to the evaluation of the alternatives recommended here,
the option presented in this Proposal would no longer be affordable or possible, and all
prospects for pursuing either of the alternatives presented here would be eliminated.

• Both the Taussig and the Impact DataSource studies, however, present the case for the
Santolina development within the context of highly optimistic, unrealistic population &
growth scenarios that seem to have little or no relationship to the trends experienced in the
Metro area in recent years. For example:

• WALH’s projected Bernalillo County population growth by 2040 = 312,000*
• WALH’S projected Bernalillo County population growth per year for the next 20+
years = +/-13,000/yr.
• Actual Bernalillo County Net Growth for the last 10 years = 1,500/yr.*
• Comparison of the last 10 years’ actual growth to WALH’s Projection = +/-12% of
WALH’s assumption*
*SOURCE: Albuquerque Economic Development statistics used by WAHL

Analysis of Consultants' Costs and Tax Yield Projections
If PC zoning for the current arrangement of the Santolina development were approved, the citizens of
the County, including all Albuquerque residents, would be committed to a 50-year, +/- $2.28 billion
tax-payer obligation to support the 20 TIDDs (Tax Increment Development Districts) that have been
authorized to subsidize the Santolina development.28

• The County also would incur a significant loss of tax revenue as a result of a provision in
the Santolina Development Agreement that would allow Santolina to maintain Greenbelt
Grazing tax status until vertical construction begins.
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• There could be a substantial negative economic impact on inhabited parts of the City and
County as a result of resources & people being redeployed & relocated away from already
developed and committed Development Areas of the community.

• Neither of the consultants’ projections performed as part of the present Santolina proposal
include the indirect and hidden/external costs that must be included when calculating the
total economic and social impact of the proposed Santolina development. For example,
millions of dollars in unbudgeted infrastructure expense such as new freeway intersections,
arterial street widening through the South Valley, new schools, utility extensions and
maintenance, significant expansion of facilities for arsenic removal from well water, social
services, and other non-programmed services are unaddressed. Much of this cost ultimately
would be borne by the citizens of City of Albuquerque and related jurisdictions and their
constituents, as well as by the State and its constituents, despite the “no net expense”
provision in the Development Agreement, which applies ONLY to Bernalillo County. These
significant expenses also are in conflict with the requirements of the jointly adopted
County/City “Planned Communities Criteria” (PCC).

• An important, indeed urgent, issue facing the County, as well as the entire Albuquerque Metro
area and adjacent communities, is the potential damage that could be caused if the proposed
Santolina development were to be approved and then fail. Santolina is a high-risk venture
within the County’s jurisdiction, and one that also would significantly impact the City and
other jurisdictions.

• The County, and indirectly the City, would be exposed to the risk of doing business with
Western Albuquerque Land Holdings, LLC (WALH), a Delaware-based (not New Mexico
based) land holding company. This could expose both jurisdictions to inadequate relief if
the Santolina venture failed, especially without protective claw-back provisions.

• The potential risk to the County and City and their constituents is further increased due to the
lack of a business plan in the Santolina Master Plan specifying how employment
opportunities will be created. This risk is increased as a result of the highly unrealistic
population and revenue projections used in the present Santolina proposal.

• The substantial cost that would be incurred by the County and its citizens, including all
Albuquerque’s citizens, to help pay for the Santolina development through the 20 publicly
financed TIDDs, would significantly increase the County’s economic exposure due to the risk
of default, a risk that is further exacerbated by the Santolina development’s site plan and its
lack of “fit” to the land.  

• In order to meet their fiduciary responsibility, the County Commission and the ABQ City
Council need to identify ALL of the direct, as well as all of the non-programmed, unbudgeted,
indirect and hidden/external costs and risks that their constituents are likely to incur, and to
include them in an updated Santolina analysis that more accurately estimates the total impact
of the proposed Santolina development. Except for the estimated direct cost, none of these
factors are included in the “no net expense” calculations provided by the Santolina
consultants -- even the direct costs that would be incurred by the County are the only costs
considered and do not include direct, indirect and other costs that would be incurred by
the citizens of other jurisdictions.
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• If the PC zone change for the present design were granted, and if there would be default after
entitlement, it is recommended that the site be acquired through eminent domain. It is
further recommended that, should the zone change be approved, a provision be included
that the acquisition value of this land would be at its pre-entitlement land assessment or at
adjacent land market value.

Economic Context and Site Conditions
Further, the extreme physical constraints of the Santolina site would add significant, unaddressed
development and maintenance costs to the present plan for the Santolina development that would
inevitably and perpetually plague the project.29 These constraints would reduce the project's
marketability and viability. These constraints include:

! Very fine-grain Aeolian sand conditions,

! Grading for drainage of traditional suburban development would create the need in
many areas for engineered foundations even for single-story buildings,
! Lack of potable water under the entire West Mesa,
! Required arsenic treatment for water in the Don, College and adjacent well fields, and
! Physical limitations of and cost of pumping water from the Middle Rio Grande aquifer
and San Juan/Chama supplements, or alternatives. In both Option 1, the modified
development arrangement, and Option 2, the full-site PV array, as presented in this
Paper, this volume would be substantially reduced.

• Other physical conditions, including the uneven bearing capacity of the wind-deposited soils
of these 10,000-year old longitudinal dunes, and the long-term problem of maintaining the
necessary gradient of foundation stability and of piped utilities from settlement and leakage
in this unstable, sand-dune-covered area, cast further doubt on the economic feasibility and
viability of the present development configuration.

The components of the proposed Santolina development is a design that fails to address 21st Century
market preferences, as well as contemporary urban planning and environmental standards. This,
combined with the previously described undocumented and unrealistic Santolina economic and
population projections, as well as the unresolved major variations in the Santolina consultants’
economic projections, makes the Santolina project projections -- if the present design were to be
implemented -- highly questionable, thereby making Santolina's projected benefits to the County and
its citizens highly questionable as well.

In similar topographic and soil conditions, west of Los Lunas in the Huning Ranch development,
litigation related to settling foundations and cracking walls that had occurred in homes are still in
arbitration and being re-purchased by the developer, D.R. Horton. 30

Map 1: 1974 USGS Survey, West Mesa Dune Conditions (p.11), and
Map 2: Santolina boundary & Roads on USGS Dune Conditions (p.12) follow below:

10


11


12


RECOMMENDED SOLUTIONS:

Section C: THE RENEWABLE ENERGY STRATEGY AND PROJECTIONS

The primary focus of this Paper is the replacement of the proposed Santolina development with one
of a two options: Option 1: A Modified Santolina site plan combining 3 components -- a 2000-acre,
airport-related industrial area, a 2200-acre High-Desert, mixed-use Community area, and a 7000-
acre photovoltaic (PV) array. Or Option 2: a larger photovoltaic energy generation system covering
most of the Santolina site area, excluding the Major Open Space areas as designated in the A/BC
Comprehensive Plan. The following section will discuss the design characteristics of the photovoltaic
portion in either option, that is:

• The Need for a Regional Energy Strategy,
• A PV Array Design and Development Strategy,
• PV Array Economics,
• Projected Bernalillo County Revenue Yields,
• Site Acquisition and Consideration of a Public-Private Partnership (PPP),
• Potential for Wind Powered Electric Generation,
• Site Options Considered, and
• Potential for Tourism Revenue.

Need for a Regional Energy Strategy
Although the Public Service Company of New Mexico (PNM) may have been among the leaders in
the transition to renewable energy, the economic burden of what were previously adequate
generation facilities has precluded more robust progress in this effort.

Surprisingly, according to a recent U.S. Department of Energy Report, New Mexico ranks 48th out of
50 states in the percentage of electric power that is currently produced thru renewable sources.
("Renewable Energy Production by State", U.S. Department of Energy17) We obviously have failed to
maximize utilization of one of our most valuable natural resources, and to realize its potential for
producing clean, low cost electricity to the citizens of the Metro Region.

A recent Energy World article noted that the growth in consumer purchases of solar power via
community-based systems, such as the prototype described below, is accelerating throughout the
U.S. The article notes, “More consumers grasp the benefits of solar energy and more ratepayers who
cannot, or don’t want to, buy their own solar systems find out they can participate in a system on a
pro-rata basis.”16

It is timely, if not urgent, for the Albuquerque Metro Region to develop and implement a regional
energy strategy that is capable of supplying low cost, reliable electricity to local citizens over the
coming decades. The energy production strategy described below could help facilitate this
transition. It is recognized that this transition must fit the energy producer’s schedule and priorities
and must be economically feasible. The strategy explored below could achieve those objectives.

It is recommended that this proposed energy project be considered within the context of a regional
energy strategy, rather than as an isolated County project. Doing so would facilitate the engagement
and collaboration of community leaders and citizens in a most timely and important effort, i.e., the
development of a sustainable energy future that can significantly contribute to a resilient economy
13

for Bernalillo County, the City of Albuquerque, the Albuquerque Bernalillo County Water Utility
Authority (ABCWUA), and the entire Metro area would benefit as well. (See Section D, p.19)

Photo Voltaic (PV) Array Development Strategy
This Paper proposes and outlines, under Option 1, a significant modification in the configuration of
the new Santolina development pattern, by replacing the four very large suburban-type subdivision
areas in the central portion of the site (distinguished primarily by their names of colors in Spanish),
with a large photovoltaic array.

The PV array portion of Option 1 could be constructed in stages to complement and to match demand
in the metropolitan area with supply. This sequence also would be coordinated with the retirement
or decommissioning of existing electrical generating facilities, and would be in cooperation with
management of those facilities. Option 1 could also be constructed all at once, through a Public/
Private partnership (PPP) with an energy provider, and with the objective of strategically balancing
local demand with the potential entry into the Western Energy Imbalance Market (Western EIM).
Although there are number of options and variations, the prototype system outlined below suggests
a process for an affordable, environmentally superior generation facility.

It is fully recognized that this transition must fit the energy producer’s schedule and priorities and
must be economically sound. The strategy explored below, we believe, could achieve this objective.
In addition, the recommended strategy would help the community integrate this energy project with
evolving 21st Century strategies for public transit, land use, urban form, and new community
development, as well as energy resource development. These strategies then must be integrated into
the jointly adopted A/BC Comprehensive Plan.

The Option 1 example suggests building an 800 MW electric generation array, covering 7000-acres,
in a sequence using E/W tracking units in arrays ranging in scale from 100 to 250 MW. The energy
production and revenue projections in this prototype option are based on single-axis, sun-tracking
PV arrays, i.e., a coordinated set of units that follows the path of the sun through each day. In order
to compare the performance of this alternative to the economic projections of the current Santolina
proposal, the same 50-year projection period is used in the projections below, as extrapolated from
the two consultants’ reports commissioned by Bernalillo County and by WALH.

The preliminary cost and revenue assessment of the Option 1 PV array example described here, and
conducted in the course of preparing this paper, indicates this 800MW photovoltaic (PV) generating
facility located on the proposed Southwest Mesa (currently Santolina) development site, if publicly
owned by the community, could by itself produce a greater electric generation net revenue yield to
Bernalillo County over a 50 year period, potentially at far less cost to the citizens of Bernalillo County
and surrounding jurisdictions, than the projected tax yields of the entire proposed Santolina
development. (See January 21, 2016 Taussig and Associates Report, “Fiscal and Economic Impact
Study” 18). See also, Projected Development Cost and Revenue Comparisons. (p.16)

In an this alternative within this option, if the PV array were developed by PNM, or another energy
provider, the revenue produced from the IRB tax and the Solar and Tangible Capital Tax revenue
would need to be determined by the County Assessor’s Office in negotiation with the energy
provider.

In addition, based on a direct projection of the Estrella PV array located north of I-40, near the Rio
Puerco escarpment, the Option 1 alternative considered here, if developed by a public utility or co-
14

op, also would cost less than the total cost projected in the November 6, 2016 Impact DataSource
study. (See “Economic and Fiscal Impact of Santolina TIDDs in Bernalillo County, New Mexico”18). The
lack of independent evaluation of input assumptions in the Taussig Report projections, and the
absence of clearly stated assumptions or an itemized list of projected public cost-inputs in the Impact
DataSource study, however, requires more careful evaluation of both consultant's reports by the
County. (Cost of Option 1, PV Array, and Net Revenue, pp.13-16)

Example of a PV Array Design *
The energy production and revenue projections for the Option 1, 800 MW electric generation facility
as described here, are based on building this capability using sequenced, individual N/S linearly-
connected arrays of single-axis E/W sun-tracking photovoltaic units ranging from 100 to 250 MW.

The several miles-long, 10-15 foot-high E/W, Sahara-type sand dunes at the Santolina site are well
suited for energy production utilizing individual N/S linearly-connected arrays of sun-tracking
photovoltaic units. That is because the deep, vertical pin supports and low-level, East/West tracking
units of the large PV array can be easily arranged to fit on the existing landform, with a minimum of
land disturbance due to their slim, driven pilings rather than linear footings. They also could help
reduce the very high wind-erosion rates of these ancient dunes. (See article on Earth Anchors 23)
Although there are a number of possible options regarding sequence and scale, the 800 Megawatt
Photovoltaic generating facility proposed in Option 1, located on an 7000-acre portion of the
proposed Santolina site, plus a 1000-acre reserve for future capacity, potential energy storage, and, if
warranted, wind generator towers, could produce enough electricity to serve the equivalent of more
than 300,000 households -- that is more than all of the households in Bernalillo County, including the
City of Albuquerque (2016 estimate = 289,000 residences20). Or, it could be constructed all at once
and provide generating capacity to the Western EIM (Western Energy Imbalance Market) until/or if
needed for the retirement or the decommissioning of existing generating facilities.

The site’s generating capacity and potential projected local load is based on direct extrapolation from
the PNM Estrella PV tracking facility. This 100-acre, 10-MW Estrella facility is owned by PNM R & D,
and is located north of I-40, near the rim of the Rio Puerco escarpment, just north of the proposed
Southwest Mesa (Santolina) development site. The Estrella array is designed to serve the equivalent
of 3800 households.

The Estrella facility is based on the production of 1 MW per 10-acres and includes access corridors,
DC/AC conversion substations, and space for potential future expansion and energy storage capacity.
The design parameters of the proposed Southwest Mesa (modified Santolina site) PV array, would
have an increased efficiency due to the larger array, and would align with the production of the
Estrella facility and with other large-scale PV systems in the U.S.  

The potential electrical generation of the proposed wind energy component on the western edge of
the site is not included in this Proposal but, if warranted, would be an additional component of the
renewable energy strategy proposed here.

Cost of Option 1, PV Array, and Net Revenue
Based on direct extrapolation of the cost of the $19 million Estrella facility, the construction cost for
the proposed PV electrical generating facility in Option 1, is estimated to be ~$1 billion. This is in
contrast to the Impact DataSource projection of a ~$2.3 billion for cost for TIDDs and infrastructure
for the Santolina development.

15

In the Option 1 example presented here, if the SW Mesa solar array were owned and operated as a
public facility, and if the electricity generated were marketed to users at $0.08/KWH, this 800 MW
facility would generate approximately $154 million in gross revenue per year at full capacity. This is
without factoring in graduated rates, i.e., different rates for different kilowatt-use categories.

Separately, for comparison, according to PNM’s Network Operating Committee “Pajarito Report”
(Nov. 5. 2007, p.15), if a solar-thermal energy storage system were constructed here, the cost of
construction (proportionally) would be ~ $1.4 billion. In view of the multiple variables as described
therein, this arrangement is not included in the example case.

The estimated net revenue production rate for the example case, again if publically owned, is
calculated at: $0.03/KWh (public land) x 8 hr/day (E/W tracking units) x 300 days/yr (NM sun calc.)
for each phase. The four phases are cumulative: $7.2 million, $25.2 million, $43.2 million and $57.6
million for each 10-year period. The average net revenue produced in this example would be $38
million/yr. The total net revenue production for the 50-year period would be ~ $1.7 billion (this
figure is for the 43.5 year period -- the first 6.5 years are subtracted for paying back the construction
cost at the full production revenue yields of $154 million a year).

If the construction period for Option 1, for each phase were reduced to 5-year periods, the yields
would be the same except that the $57.6 million period would repeat 4 times in the second half of the
50-year period. For example, with five-year increments of building 100, 250, 250, & 200 segments,
and starting at 0, by the end of the 25th year, full production capacity is reached. For the next 25
years, four more 5-year periods producing $57.6 of net yields in each subsequent 5-year
period would occur. The average yield then would be $46.8 million/yr, and the net revenue yield
(for the 43.5 remaining years) would be just over $2 billion. The example presented in this Proposal,
however, uses the ten-year increment, the lower net-yield figure, in order to accommodate and be
phased with the aging and retirement of existing facilities.

Whether the Option 1 PV generating facility were constructed all at once to serve WIM, or
constructed in increments to meet local energy generation and replacement needs, one of the
determining factors impacting the strategy would be the rapidly evolving technology of battery
chemistry and its declining cost, especially the declining cost and greater capacity of
supercapacitors.19,20 An article in June 2018 Forbes cautions against over investment in natural gas
electric generation due to lowering renewable cost and the risk of stranded assets. 24

Prudent management, whether by a public entity, or a public/private partnership with PNM or
another energy partner, should determine the proper balance between the capacity for immediate
response, by batteries or super capacitors to changing cloud cover and/or peak loads, and the scale
and the capacity of gas-fired, other generators or battery storage for nighttime loads, including
programming for the aging and retirement of some components. This includes increasing nighttime
loads for charging a growing fleet of private and commercial electric vehicles.21,22


Projected Development Cost and Revenue Comparisons
Preliminary analyses suggest that the Option 1 example case (publicly owned PV generating facility),
located at the currently proposed Southwest Mesa (proposed Santolina) development site, could
produce greater net revenue to Bernalillo County over a 50-year period than the projected tax yields
of the proposed Santolina development (see comparison below).

16

In order to compare the performance of this Option 1 PV array strategy to the current Santolina
development plan, a consistent 50-year projection period is used in the projections below.
Projections are based on extrapolations from the two consultant reports for Santolina commissioned
by Bernalillo County and WALH, and cost extrapolations from the PNM Estrella PV facility.

The cost of debt service is not included in the following figures. This cost would be borne by either
the Santolina developer or, in this comparison, by whatever entity were to own the solar array. All
projections are in current dollars.

• Based on direct extrapolation of the $19 million Estrella facility cost, the construction cost for
the prototype PV facility is estimated to be ~$1 billion. This is in contrast to the Impact
DataSource projection of ~$2.3 billion in TIDDs and infrastructure costs for the Santolina
Development.

• Using the extrapolated 50-year projection of the David Taussig & Associates Report, the
Bernalillo County total net tax revenue generated from the proposed Santolina development is
projected to be +/-$815 million.18

• The 50-year total net tax revenue projected in the Impact DataSource study is +/-$5.5 billion.19
(Note: Numerous tables in this study are missing appropriate documentation of sources and
assumptions.)

• The 50-year total net revenue from electricity generated by a phased-in, publicly-owned PV
array at $0.03/KWH, after construction cost payback, and without factoring in graduated rates
or potential additional revenue that might be generated at the site, is ~ $1.7 billion.

• If the entire 800 MW array were built at the same time, for example as part of Western Energy
Imbalance Market (WIM) strategy, and if the electricity generated by a publicly-owned facility
were marketed to users at $0.08/KWH, it would generate an estimated gross revenue of $154
million per year at full capacity; a total gross revenue over 50 years would be $7.7 billion.

Although the cost of constructing the PV portion of the modified Santolina alternative, Option 1 (as
described in this Paper), by itself, appears to be less than the cost incurred by the County if the
projected cost for the present Santolina development were built, without specific data regarding the
cost of the proposed bonded debt service, the economic burden that would be borne by the County’s
General Fund Services could not be calculated within the scope of this Paper.

Consideration of a Public-Private Partnership (PPP)
This Proposal recommends that consideration be given to developing this new PV capability as a
citizen-owned electric co-op or, potentially, through a public-private partnership (PPP). If a PPP
were to be pursued, either in partnership with PNM or perhaps another energy production partner,
the calculations below would need to be adjusted based on the agreement that would be negotiated
with that partner. The calculations would also need to include potential IRB tax revenue, Business
Solar and Tangible Capital Tax revenue as determined by the County Assessor’s Office.

If the facility in this example, were developed as a municipal utility or as a citizen-owned electric co-
op, its cost, of course, would include payments to its energy production partner for the use and
maintenance of their distribution network, as well as for grid-tied back-up power for nighttime and
low-yield days powered thru existing energy-partner facilities. While meeting this cost requirement,
17

again, if it were developed as a publically owned facility, preliminary estimates are that the proposed
PV array, in the full built out example cited, would yield an average of $58 million in net electric
generation revenue per year.

The recent PNM agreement with the Facebook data-center development west of Los Lunas may be a
business model worth considering.   Also, in November of 2015, the City of Gallup issued an RFP for a
10 Megawatt solar photovoltaic generation facility to provide electricity for the City.26 There may be
merit in further investigating this effort as well.

Alternative organizational structures and utility partnerships need to be explored by qualified,
objective experts in order to fully assess the opportunities for Bernalillo County revenue
enhancement. Additionally, consideration of possible collaboration prospects and potential
economic benefits to the City of Albuquerque, the ABCWUA, and other jurisdictions within the Metro
area also should be evaluated.

The cost and economic performance of Option 2, the full-site generation system, was not evaluated in
this Paper because, as a system, it is more appropriate for and suited to a large-scale energy
generation system, possibly serving the Western Energy Imbalance Market (Western EIM). Although
the land could be publicly owned, the full-site PV array most likely would be developed by a private
energy provider rather than as a public array.

Site Options Considered
In the process of preparing this Proposal, consideration was given to the feasibility of developing a
geographically dispersed solar array system. Energy generation experts consulted while preparing
for this PV generation facility suggested assessing the feasibility of smaller, geographically separate
sites for PV configuration.

For example, 3 areas with 250 MW production capacity each, or 4 areas with 200 MW capacity each,
could have some advantages due to issues such as periodic cloud cover. However, locating enough
sites with such potential capacity, that also are adjacent to major transmission lines, does not appear
to be achievable in the Metro area.

A physical survey of the Metro area quadrants identified one site, a 2000-acre area at Mesa del Sol
that might meet one part of the generating requirements being proposed. However, this site is in City
of Albuquerque jurisdiction and would require modification of the City’s currently adopted platting
plan for this area.

Another area that appears to be physically available, but which also presents jurisdictional issues, is
in the northeast portion of Albuquerque, north of the municipal boundary on Sandia Pueblo land, just
south of Tramway Blvd., east of I-25.

Further, an area in the NW quadrant that could meet the criteria for land-availability and major
transmission line adjacency is the area north of the Double Eagle II airport, where Atrisco Vista turns
toward the connection to Paseo del Norte. However, this area is now annexed into Rio Rancho.

Although a “dispersed” approach may have possible advantages with respect to the scale of the PV
array arrangement and management, it would place these units in the City of Albuquerque, Sandia
Pueblo, and Rio Rancho jurisdictions, respectively, and therefore would disperse revenue away from
Bernalillo County. As a result of the above challenges, the dispersed option is not recommended.
18


The proposed Southwest Mesa (Santolina) site is the only contiguous space in the immediate
metropolitan area that is large enough to develop an 800 Megawatt, PV energy generation facility (or
the larger, full-site array) that could serve the entire Metro area. If publicly owned, it also would
provide the highest economic return to Bernalillo County because it lies entirely within the County’s
jurisdiction, which merits support for Bernalillo County to explore options to acquire this site.

Potential for Wind Powered Electric Generation
This site also has a unique potential for wind powered electrical generation. The prevailing westerly
winds, and the major storms that blow across the Rio Puerco Basin, rise up the slope, compressing
the air, thereby increasing the velocity of the wind over the rim of the Rio Puerco escarpment. The
existing PNM Estrella PV generation facility near the Rio Puerco escarpment just north of I-40
presently is recording wind data. Data from this resource could be used to assess the viability of this
proposed location regarding its wind-generating capacity and potential revenue yields.

Opportunity for Tourism Revenue
This Proposal suggests that part of the proposed array could include a dedicated area of bright-
yellow, sunflower-configured, dual-axis tracking PV generators -- units that track the position of the
sun through the seasons as well as through each day -- on the easternmost portion of the PV array
facing Atrisco Vista Blvd. This feature would provide a highly unique aspect of this solar array that
could have significant tourism prospects. Use of funds from the “1% For the Arts” Program for this
feature would be appropriate for adding innovative beauty to this project. (See Illustration 3, p.32)

Section D: CREATING A METRO-CONNECTING, GRID & PERIMETER TRANSIT
PLAN

An important component of both Option 1, the Modified Design alternative to the existing design of
Santolina, and Option 2, the larger PV array, is the development of a highly functional, ‘grid and
perimeter’ public transit system serving this area (See Illustration 1, p.29) and its potential for
associated Transit Oriented Development (TOD). The increased tax base that would be produced by
this improved public transit system makes the integrated recommendations in this Paper even more
viable.

The perimeter transit would be a catalyst for an intentional, form-defining edge to the urban area. It
also would interconnect with all the interior grid routes and Para-transit collector loops.
Incorporating this grid and perimeter transit system as a Metro-area-wide transit network in place of
the City’s existing, 1950-style, predominantly radial Transit routes, which currently serve only small
portions of the County, would provide more equitable access to all portions of the Metro area,
including many presently underserved areas, especially on the West Side, thereby creating the
potential for significant economic development.

The design and location of the proposed grid and perimeter transit system would significantly
increase the potential market value of the properties accessed by both the interior grid and the
perimeter transit routes. Further, the properties benefited by the combined grid and perimeter
transit system, including development of the existing A/BC CompPlan committed-to-be-served areas,
could accommodate a population considerably greater than the projected population for the
proposed Santolina development.

19

The increased tax revenue, and a proportional contribution by the benefitted properties, could help
pay for the cost of design and implementation of this user-friendly, integrated transit network. The
increased property tax base also could help finance development of the new Southwest Mesa site.

The appropriate technology, or mix of technological options for this interconnected grid and
perimeter transit network should not be limited by what is deemed “in vogue” by present-day norms.
Nor should it be limited by the serious errors in the public participation process and in the
unnecessary center-lane design that were committed with the Central Avenue ART transit project.

Indeed, changes such as electronic control of all vehicular travel on major arterials, including transit
vehicles, are progressing rapidly, and transportation options of quite different forms will determine
the inter-connected grid and perimeter system of our future.31 For example, the pneumatic, air-
driven, vacuum-tube-under-the-vehicle system (whether in-ground or elevated) undergoing testing
in Ukiah CA, is an option in process.32

Section E: ACHIEVING BOTH COUNTY AND CITY OBJECTIVES IN THE COMP PLAN

Consideration of the two Options presented here provides an opportunity to address some important
urban design issues in the Middle Rio Grande Region that, although unstated, are implicit in the
A/BC-Z process, and in the City’s version of the Comprehensive Plan Update.15 This is especially
timely because the County has not yet reviewed or approved the City’s Comp Plan Update. In this
approval process, the County will have the opportunity to ensure that its interests and concerns are
addressed in the jointly adopted Plan.

One of the most significant issues in the City’s Comp Plan Update is the conflict between the
Comprehensive Plan text and the “Metro-focused” and “Countywide” Vision Maps contained in the
Plan. These maps do not reflect a number of the policy statements and guidelines involving land use,
transit, energy generation and economic development in the text of the CompPlan Update.

For example, although the text statements in the Vision, Policies and Guidelines are well crafted and
forward-looking, the “Countywide” and “Metro-focused” Vision Maps 3-1 and 3-2 show a
continuation of the suburban sprawl that has dominated Albuquerque’s urban expansion over many
decades. This pattern of development of lower cost land at the edge of the City, or beyond, with the
public paying for the extension of roads, utilities, services, etc., is neither economically prudent nor
environmentally sustainable for the Albuquerque Metro area.

In addition, the Comp Plan Update does not address an important regional quality unique to the
entire Middle Rio Grande Region. That is, the Region’s historic development patterns and their
potential as a new building paradigm applicable to 21st Century urban form, as well as to building
design and to community and neighborhood patterns in the Albuquerque Metro area. It also could
serve as a model for the entire Southwest region.

Historic Context
One of the most unique and appealing aspects of the Middle Rio Grande Region to residents, tourists
and businesses, has been its historic development patterns. Many tourists come here to visit the
nearby Native American Pueblos with their dance and ceremonial plazas, as well as Albuquerque’s
Old Town Plaza. This pattern is based on the fundamental principles inherent in historic Native
American and early Hispanic development patterns.

20


Basic organizing principals of both Native American and historic “Law-of-the-Indies” Hispanic
development, whether as a ceremonial/dance space or as a cultural/civic plaza, was centered on
a “space” that was the center and focus of “community”, versus an object such as a building or a
cluster of high-rises.

These cultural resources of ancient and nearby Native American and early Hispanic development are
one of the greatest attractions and primary reasons for tourists visiting the Albuquerque region.
Incorporating these basic, high-desert ecological principles into our continued pattern of new growth
could enhance this attraction, both for visitors, and for locals who may decide to stay in Albuquerque.

A quick review of certain historic urban design trends is helpful in understanding how & why
Albuquerque has grown in the highly dispersed, and expensive-to-service-and-maintain way that it
did, especially during the last half of the 20th Century.

Early Anglo development, which spread West during the “manifest destiny” period was based mostly
on the “Jeffersonian grid”, reflecting the principles of equality as expressed in the new U.S.
Constitution, and setting much of the early urban design pattern across much of America as well as in
Albuquerque.

In the late 20th Century, “New Urbanism” was the next major development pattern imposed on
Albuquerque. It included a tighter grid and long diagonal streets, all converging on one large central
plaza, (e.g. Peter Calthorp's “Mesa del Sol” pattern is a very pure example). Although this particular
development may have potential, to date it has been slow to realize its original growth projections.
This may be at least partially due to the Region’s lagging economy, out-migration and the
concomitant slow demand for more housing and commercial space.

Unfortunately, the pattern of development that the existing Santolina design-diagram would force
upon the 10-15 ft. high, longitudinal dunes on the top of the West Mesa doesn’t qualify as a “New
Urbanism” development. The Santolina Master Plan shows four separated, primarily single-use
subdivisions, around an undefined urban center. It also shows a large, adjacent drive-to-work
“industrial area”, as well as a separated “business park” and another separated “town center” area
facing I-40, not the suburban areas.

This two-dimensional design would be superimposed on a three-dimensional, undulating, dune-
based landscape without regard to, or even evident recognition of, the exorbitant costs of grading out
this landscape to provide drainage for this traditional, 20th century suburban design.

Because of the profound and long-term impact of urban design mistakes such as this, which were
pursued in the 20th Century and ultimately failed, it is urgent, in the 21st century, that Albuquerque
and Bernalillo County, especially in the Option 1 arrangement, develop and embrace a vision for the
Metro area that aspires to be a truly unique and great place to live, while simultaneously being
conscious of the inherent climate, water, economic and other unique challenges when designing &
building, a group of buildings or a neighborhood in the high desert. (See Illust. 2 and 3, pp.30-31)

The organizing principles inherent in this ancient Pueblo and early Hispanic heritage can function at
a wide range of scales, creating identifiable, sense-of-place, single-building or multi-use development
areas, rather than endless, side-by-side single-use housing typical in suburban development areas. If
the fundamental reasons for replicating the performance, but not necessarily the forms, of these
21

historic patterns were applied to new development, particularly in conjunction with the revised grid
and perimeter public transit system described in Section E, they could be an important part of the
Region’s physical and economic growth.

These “reasons” for replication include, for example, moderated sun access, wind reduction and
creation of a more protected microclimate within the community open spaces that form the center of
these designs. These highly functional design features could make the Albuquerque Metro area a
genuinely unique and creative, culturally grounded, 21st century, millennial-keeping and tourist-
attracting place in which to live, work and visit. (See Illust. 3, “A 21st Century Alternative”, p.32)

The “new development” patterns put forward here, in Option 1, are based on, but not copies of, the
concepts and forms that created historic Native American and early Hispanic communities. They
could vary in size from small clusters to large, sometimes sculptural arrangements. By design, they
would be well served by public transit. By employing these historic principles, they could achieve the
economic, social and ecological value of the climate-protecting, security-increasing, micro-climate-
creating, and community-sharing common space forming the center of these developments.

The “A/BC Comprehensive Plan Update”
The “A/BC Comprehensive Plan Update”15, adopted by the City in March, 2017, but not yet reviewed
or adopted by the County, and the City’s zoning ordinance, “Integrated Development Ordinance”
(IDO), which applies only to the City, have the potential to guide our community toward a vital and
sustainable future, but ONLY if they incorporate and respect the unique qualities of the County
outside of the City boundaries, and distinguish those qualities from the urban-development form of
the City. If so recognized and incorporated, many of the Comp Plan Update’s graphics are valuable
and could help guide our community to become a genuinely special, culturally grounded, 21st
century, millennial-friendly, creative place to live.

The multiple, data-driven maps in the City’s A/BC Comp Plan Update present the physical locations of
a broad spectrum of measurable aspects of our area. They also lay out a functional way to distinguish
and define the urban, rural, and open areas of the Albuquerque Metro area. There is remarkable
potential for a City-County synthesis as a result of each jurisdiction manifesting the “Vision and
Guidelines” statements in the Comp Plan Update -- and then applying them as integral and important
components of a clear and intentional vision for the urban form of Albuquerque, as well as providing
an explicit articulation of the unique urban areas, the rural and agricultural areas, and the open space
network that is shared by both.

The modifications to the Comprehensive Plan, as adopted by City Council in March 2017, that would
be required to address the issues and proposed solutions described herein would be modest.
The only changes to the Comp Plan Update “Vision” maps on the West Mesa, would be to remove one
of the two tan colored, dash-line circles on the south side, and to move one of the two dash-line blue
circles to the north side of I-40.

Further, the ‘Perimeter and Internal Grid Transit Network’, as proposed in Section D, would be
located entirely on established major arterials, rather than requiring extensions of the existing radial
Transit system to serve large new areas of undeveloped land. These modifications would be in full
compliance with the text in the updated Comp Plan Update’s Policies 6-1 thru 6-8, in the
Transportation chapter (p. 6-32), and with the Urban Design Policies 7-1 thru 7-6 (p.7-1315).

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Unfortunately, parts of the Comp Plan Update, (e.g., maps showing obsolete 20th Century horizontal
growth, as well as an overly homogenized IDO zoning code), do not recognize the distinct “mesa-
slopes-valley” nature of the Albuquerque area. These negative components of the CompPlan have the
potential to continue a development pattern that, over time, has permitted and encouraged
economically unsustainable sprawl and other damaging outcomes.

These long-term, horizontal, sprawl-based growth patterns, as clearly illustrated in Figures 3-1 and
3-2 of the Comp Plan Update, not only have contributed to the Region’s historic economic challenges,
they are likely to play an even greater and more troublesome role in the local economy in the future
as the development cost per household continues to rise to an unsupportable degree, primarily due
to these long-pervasive development patterns.33 Cities throughout the world have come to realize
that efficient and attractive densification is no longer just an option. Indeed, it has become an
important component of urban economic viability.34,35,36,37,38 The Middle Rio Grande Region is no
exception.

Except for some deeply buried and encoded phrases in the “Resilience & Sustainability” chapter of
the CompPlan Update, there is little recognition of, or planning for, the impact that can be anticipated
from climate change, water availability challenges, and other rapidly evolving trends. Even these
abbreviated statements that are in the Comp Plan Update are not reflected in the City’s new IDO.

The maps presented in the A/BC Comprehensive Plan Update could provide a framework to inform
and display a more functional and economically sustainable land use pattern utilizing the many large,
available, vacant or underused land parcels in both City and County jurisdictions. These parcels
include land that lies within the boundaries of the 2003 Comprehensive Plan’s “Development Areas”
that are already served, or committed-to-be-served, with utilities.

They also should include parcels where a distribution of new ecologically, culturally and historically
relevant development could be located. This would prioritize unused, or underused and available
industrial land, especially near the Double Eagle II Airport, as well as land on the slopes east of the
West Mesa escarpment. This would facilitate essential job creation through the utilization of
performance-based zoning, and would maximize access to the transit system serving these areas, as
described in Section D above. Also, incorporating the High-Desert, mixed/higher density perimeter
rim, as described here, would help to define a clear edge and an intentional urban form articulating
the City, County, and shared Open Space areas.

F. BENEFITS OF THE MODIFIED SANTOLINA & COMPPLAN MODIFICATIONS

The 21st Century alternative to the proposed plan for Santolina presented herein offers a truly
exciting and viable vision for the future of Bernalillo County, the City of Albuquerque, and the Middle
Rio Grande Region. It supports job creation and employment hubs as well as appropriate
development, all within the context of proven high-desert urban design principles and a sound
economic development strategy.

Modifying the design, either by the current applicant, or thorough a Public/Private Partnership, or by
public acquisition of the Santolina site, could become a stimulus, as well as a vehicle, for creating a
realistic opportunity for something significantly better to evolve out of the current high-risk and
economically questionable configuration of the present Santolina proposal.

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Summary of Potential Benefits and Recommendations

Potential benefits of pursuing the Modified Santolina Plan, including the industrial, community
development, and photovoltaic array components, as presented in this Paper, include:

1) Greater net revenue to the County from the diversified tax revenue components.

2) Increased prospects for West Side jobs and economic development, thereby enhancing the Region’s
overall economic viability & resilience,

3) Production of sustainable, low cost, clean energy, in two options, for County and City residents,

4) Potentially less cost to County and City residents than if the proposed Santolina development as
presently designed were built,

5) Substantially reduced economic risk and debt burden to the County and to the City,

6) Facilitation of appropriate development within the context of historically proven high-desert design
principles, a within the context of sound economic development,

7) Reduction in land and infrastructure development costs by using primarily existing, committed or
short-extension infrastructure,

8) Provision for greater total population capacity in High-Desert, grid and perimeter development,

9) Substantial reduction in demand for limited water resources using multiple-use strategies,

10) Alignment of current County & City urban planning objectives within the context of 21st Century
urban planning principles and their committed inclusion in the A/BC Comprehensive Plan,

11) Facilitation of an urban design that would be more attractive to millennials and others, some of
whom are currently migrating to other cities,

12) Reduction of disinvestment in economically depressed and other already occupied areas of the
County and City,

13) Acquisition, dedication and preservation of part of the current Santolina site as permanent open
space, as identified in the updated A/BC Comprehensive Plan,

14) Protection of both the east- and west-sloping escarpment of the West Mesa by reducing wind and
water erosion,

15) Facilitation of a highly functional grid-based public transit system and associated transit oriented
development (TOD) opportunities, including the High-Desert Community on the eastern portion,

16) Creation of potential tourism revenue by creating an area of bright yellow, sunflower-configured,
dual-axis-tracking PV generators on the eastern portion of the array facing Atrisco Vista Blvd; they
also can visit the new ‘Pueblo-open-space and Hispanic-Plaza’ style, High-Desert development,

24


17) Avoidance of extended, expensive litigation over the currently configured Santolina proposal,

18) Creation of an opportunity for the Santolina investors/owners to quickly liquidate (or to modify) a
large, currently non-performing financial asset, and

19) Creation of potentially valuable “good will” between the County, City and the Santolina
investors/owners through collaboration in an economically and environmentally sound initiative
that will contribute to the long-term viability & resilience of our community.

The modifications, as described above, of the present Santolina Plan by the current applicant, or the
acquisition of the Santolina site by the County and/or with other interested buyers, including the
proposed modifications, would cost considerably less than the $2.3 billion commitment by the
County for the TIDDs and suburban infrastructure for the existing Santolina design. This paper’s
alternative design options, combined with development focused on properties located on the eastern
slopes of the West Mesa, and in the already approved and committed-to-be-served areas identified in
the A/BC Comprehensive Plan, could produce a significantly superior outcome for all citizens of
Bernalillo County, the City of Albuquerque and the entire Metro area.

The arrangements and estimates presented herein warrant further technical and economic
evaluation. This should include a thorough financial impact assessment by a highly qualified,
external reviewer of the ‘as-proposed Santolina development’, including an objective cost/benefit
analysis comparing the modified arrangement recommended in this Paper with the two significantly
disparate projections by the consultants for Santolina.

However, this is possible only if agreement can be reached among the parties before the pending
Planned Community (PC) zoning for the proposed Santolina development would be granted.

The next step is for the County and the City leadership to expeditiously move forward with the fiscal
assessment recommended in this Proposal. As of this date, it appears that no such comprehensive
assessment has been undertaken.

RECOMMENDATIONS

• It is recommended that the County proceed with an objective and comprehensive fiscal
analysis of all projected long-term costs that would be incurred by the County, the City,
adjacent jurisdictions, the State and the citizens thereof, if the present configuration of the
proposed Santolina development were approved. This assessment should include a
cost/benefits comparison to the alternative described in this Proposal.

• In order to preserve the County’s option(s),), it is recommended that further approvals of

the proposed Santolina development be delayed until the assessments described in this
Proposal are completed. If the Santolina development as presently designed becomes
entitled, it is further recommended that it be taxed as undeveloped, entitled land, and that
if default or non-performance occurs, the County & City be given first-option rights to buy
back portions or all of the land assets at pre-entitled assessed valuation or adjacent land
market value.

25

• If the PC zone change is granted in the present design arrangement, and if there is default
after entitlement, it is recommended that the site be acquired through eminent domain.

ENDNOTES:
1 “National real estate expert says most of ABQ’s future growth will come from the ‘new majority’” by

Arthur Nelson, 2004, https://www.bizjournals.com/albuquerque/blog/real-estate/2015/04/arthur-nelson-abq-growth-

new-majority.html?surround=etf
2 “ULI's Ed McMahon shares how unique cities can lure more business”, Albuquerque Business First,

April 16, 2015, https://www.bizjournals.com/albuquerque/news/2015/04/16/uli-ed-mcmahon-how-unique-

cities-can-lure-business.html?surround=etf&u=N4TOTIS 3H7uBvrC egd%2FQ0175eed3&t=1540406813&j=84611691
3 "Cities of the Future: Global Competition, Local Leadership", by Price Waterhouse, Coopers, 2005,
https://www.pwc.com/gx/en/government-public-sector-research/pdf/cities-final.pdf
4 "A Map of America's Future: Where Growth will be Over the Next Decade", by Joel Kotkin, Forbes,

September 4, 2013, https://www.forbes.com/sites/joelkotkin/2013/09/04/a-map-of-americas-future-where-growth-will-

be-over-the-next-decade/#3e52568a623d>
5 "5 Predictions for the Future of Our Cities", by Teemu Alexander Puutio, World Economic Forum,
February 15, 2017, https://www.weforum.org/agenda/2018/02/here-are-5-predictions-for-the-cities-of-the-
future/
6 "Urban Density After Jane Jacobs: the crucial role of diversity and emergence", by Stefano Maroni,

Springerlink, September 29, 2016, https://link.springer.com/article/10.1186/s40410-016-0041-1

7 "The Future of Cities: What is the Global Agenda?", by Emily Moir, Tim Moonen and Greg Clark, The

Business of Cities, September 2014,

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/429125/future-
cities-global-agenda.pdf
8 “Santolina’s Water Use is a Ticking Time Bomb”, by Norm Gaume, Albuquerque Journal, June 5, 2017,
https://www.abqjournal.com/1013086/santolinas-water-use-is-a-ticking-time-
bomb.html?fb_action_ids=10211013948038165&fb_action_types=og.likes&fbclid=IwAR1qzJkn3l3IoCkoQNwJ3yC28S6TU
qp0fWDmRtL0KrfGZ-_LKrBSkFRqrk4
9 “Sprawl Costs the Public More than Twice as much as Compact Development”, by Angie Schmitt,

StreetsBlogUSA, March 5, 2015, https://usa.streetsblog.org/2015/03/05/sprawl-costs-the-public-more-than-

twice-as-much-as-compact-development/
10 "Keynote on Density", by Richard Rogers, Urban Land Institute Europe Conference, February 4,

2016, https://www.youtube.com/watch?v=o6M4-u9TMqY
11 "Guidance for Good Urban Density", by Todd Litman, Planetizen, July 9, 2015,
https://www.planetizen.com/node/79342
12 "Urban Density Matters - But What Does it Actually Mean?, CityMetric, by Kim Dovey and Elek Pafka,
https://www.citymetric.com/fabric/urban-density-matters-what-does-it-actually-mean-2118
13 "Highlights of the Findings of the U.S. Global Change Research Program Climate Science Special

Report” https://science2017.globalchange.gov/chapter/executive-summary/
14 “SPR2016-0001 PUBLIC HEARING: Santolina Level B.I Master Plan”, Attachment #14, pp 11- 79,

on file at Bernalillo County website:

http://bernalillocountynm.iqm2.com/Citizens/Detail_LegiFile.aspx?Frame=&MeetingID=1843&MediaPosition=&ID=6946&CssClass
15 "A/BC Comprehensive Plan Update” & “Integrated Development Ordinance”, https://www.abc-zone.com
16 "Utilities, Customers in US Southeast Embrace Community Solar”, by Jim Pierobin, Renewable Energy

World, February 22, 2018, https://www.renewableenergyworld.com/articles/2018/02/utilities-customers-in-

us-southeast-embrace-community-solar.html
17 “Renewable Energy Production by State”, U.S. Department of Energy,
https://www.energy.gov/maps/renewable-energy-production-state
18 “Fiscal and Economic Impact Study, Santolina Master Plan (Level B)”, by David Taussig & Associates,

Newport Beach, CA (Retained by WALH), January 21, 2016

19 “A Report of Economic and Fiscal Impact of Santolina TIDDS in Bernalillo County, New Mexico”, by

26

Impact DataSource, Austin, TX, (Retained by Bernalillo County Economic Development), Nov 6, 2016.
20 Source: Bernalillo County Housing Data
21 “Alternative to traditional batteries moves a step closer after exciting progress in supercapacitor

technology”, University of Bristol, February 27, 2018,

http://www.bris.ac.uk/news/2018/february/supercapacitor.html
22 “Three Countries Show How Near a 100% Green Grid Is”
https://www.commondreams.org/views/2018/04/06/three-countries-show-how-near-100-green-grid
23 “How EPCs Can Reduce Costs in Ground Mount Solar Projects” i.e. Anchoring panels in sandy soils,

Renewable Energy World, July 13,2018, https://www.renewableenergyworld.com/articles/2018/07/how-epcs-

can-reduce-costs-in-ground-mount-solar-projects.html?cmpid=enl_rew_renewable_energy_news_2018-07-
18&pwhid=dc875d4a9093f89c74f0ea594ace8f2ee48fafa1a6ef964bb8c08f613df65a899fc8e1a30e033b2d2b3e74755ce
110506919bb21a21572c32f8db78718459528&eid=291110315&bid=2176513
24 https://www.forbes.com/sites/jeffmcmahon/2018/05/21/the-rush-to-gas-will-cost-billions-in-stranded-assets-as-

renewables-get-cheaper-institute-says/#270adc543a0d
25 “Clean Energy is Catching up to Gas”, VOX, David Roberts, October 26, 2018,

https://www.vox.com/energy-and-environment/2018/7/13/17551878/natural-gas-markets-renewable-energy
26 “Request for Competitive Sealed Proposals for: Power Purchase Agreement and Asset Purchase

Option for a 10 MW AC Solar Photovoltaic Generation Facility within City Limits of the City of
Gallup, New Mexico”, http://www.gallupnm.gov/DocumentCenter/View/1023/RFP-No--2015-2016-05P
27 Source: Bernalillo County Assessor
28 "Master TIDD Infrastructure Development and Acquisition Agreement by and between

Bernalillo County, New Mexico Santolina Tax Increment Development Districts One Through Twenty
And Western Albuquerque Land Holdings, LLC”, (Undated, 2016)
29 "Why Does Barclays Want to Build a City in the Middle of the New Mexico Desert?", The Guardian,

May 19, 2015, https://www.theguardian.com/cities/2015/may/19/barclays-city-new-mexico-desert-santolina-

urban-sprawl-albuquerque
30 Lyndoe v. D.R. Horton “Deficiencies in homes may be caused by settlement of subsurface soils”
https://law.justia.com/cases/new-mexico/court-of-appeals/2012/30-663.html
31 ”We Are on Cusp of 'Deepest, Most Consequential Disruption of Transportation in History”, by Andy

Rowell, Common Dreams, May 15, 2017 https://www.commondreams.org/views/2017/05/15/we-are-cusp-

deepest-most-consequential-disruption-transportation-history
32 “Meet the 89-Year Old Re-inventing the Train in His Backyard”, by Alex Davies, Transportation,

June 14, 2017 https://www.wired.com/story/flight-rail-vectorr-atmospheric-railway-train/

33 Building to Endure: Design Lessons of Arid Lands, by Paul Lusk & Alf Simon, University of New

Mexico Press, October 31, 2009

34"Keynote on Density", by Richard Rogers, Urban Land Institute Europe Conference, February 4,

2016, https://www.youtube.com/watch?v=o6M4-u9TMqY
35 "Cities of the Future: Global Competition, Local Leadership", by Price Waterhouse, Coopers, 2005,
https://www.pwc.com/gx/en/government-public-sector-research/pdf/cities-final.pdf
36 "A Map of America's Future: Where Growth will be Over the Next Decade", by Joel Kotkin, Forbes,

September 4, 2013, https://www.forbes.com/sites/joelkotkin/2013/09/04/a-map-of-americas-future-where-

growth-will-be-over-the-next-decade/ - 30f87e3e623d
37"5 Predictions for the Future of Our Cities", by Teemu Alexander Puutio, World Economic Forum,

February 15, 2017, https://www.weforum.org/agenda/2018/02/here-are-5-predictions-for-the-cities-of-the-

future/
38 "Urban Density After Jane Jacobs: the crucial role of diversity and emergence", by Stefano Moroni,

Springerlink, September 29, 2016, https://link.springer.com/article/10.1186/s40410-016-0041-1

27


ABOUT THE AUTHORS:

Paul Lusk is Professor Emeritus at the University of New Mexico School of Architecture & Planning. He
was Principle Planner for the City of Albuquerque & Bernalillo County and Principle Author of the first
Albuquerque/Bernalillo County Comprehensive Plan. His 50 years of urban planning & design practice
has involved Architecture, Urban Design and Community Planning in Philadelphia and Boston, including
development of the Master Plan for the Boston Metropolitan Area. Prof. Lusk is co-editor of Building to
Endure: Design Lessons of Arid Lands, addressing the impact of climate change, excessive uses of water,
energy, and other resources on patterns of human settlement and the implications for county & municipal
leaders, urban planners and designers of the built environment.

Julia A. Stephens’ work has focused on the development of economic, energy, health and social resources in
rural & urban New Mexico communities for 50 years, including leadership positions at the University of New
Mexico Health Sciences Center. She was co-founder and former Executive Director of the Rio Grande
Community Development Corporation where she applied her extensive planning & operational experience in
the establishment of the South Valley Economic Development Center in 2005 as manager and community
consultant. Stephens continues to be involved in the Middle Rio Grande Region as consultant and volunteer.


ACKNOWLEDGEMENTS:
The authors wish to thank David Vogel as well as the many other individuals who have generously
given of their knowledge and expertise in the process of preparing this Paper.

The illustrative drawings referenced in the text are on the following pages:

Illustration 1: “A Vision for a Metro-Connecting Transit Plan” (p. 29)

Illustration 2.1: “New High Desert Design" (p. 30)

Illustration 2.2: “New High Desert Design" (p. 31)

Illustration 3: “A 21st Century Alternative to the existing plan for Santolina" (p. 32)

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