WE, THE UNDERSIGNED, OWNERS OF PROPERTY WITHIN 250 FEET OF DYCHE STADIUM, MCGAW HALL, AND THE ADJACENT PROPERTY OWNED BY NORTHWESTERN UNIVERSITY, OPPOSE THE APPLICATION OF NORTHWESTERN UNIVERSITY TO  A ZONING VARIATION TO ALLOW THE USE OF SUCH PROPERTY FOR PROFESSIONAL ATHLETICS, SPORTS, OR GAMES, OR OTHER COMMERCIAL  ACTIVITIES FOR THE REASONS THAT THE VARIATION WOULD:

(A)   BE DETRIMENTAL TO THE PUBLIC WELFARE

(B)    DEPRECIATE THE VALUE OF OTHER PROPERTY IN THE NEIGHBORHOOD

(C)    ENDANGER THE PUBLIC SAFETY, AND

(D)   ALTER THE ESSENTIAL CHARACTER OF THE LOCALITY.

WE THEREFORE RESPECTFULLY PETITION THE EVANSTON BOARD OF APPEALS TO DENY SAID APPLICATION.

[John Bleveans  notarized the petition 

In November, 1981 a  concert was proposed by the Associated Student Government to be played at the Stadium, with an attendance of 25,000. This outdoor event would have been loud  and disruptive to the neighborhood. 7th Ward alderman John Bleveans circulated the above petition, in opposition to the proposal.

For an article on the subject see:

1981-2 Communications

On March 16, 1982 the group of activist residents "Citizens Zoning Committee of Evanston" sent a 15 page document explaining their opposition to NU's application for a  special use to hold a concert at Dyche Stadium, Case No. ZBA 81-48-SU (R).

Below are excerpts from the document which point out to the reasons why the athletic facilities in the 7th Ward were (and still are) not suitable for the concert, whereas the Lake Campus would  have been a more appropriate location . At the time the U districts had been rezoned into U5 and U6.  The discussions in the city regarding this rezoning are mentioned in the newspaper articles dated  September 13, 1979, October 11, 1979 and October 16, 1980.

1979-1980 U2 Ordinance Debates

Prior to the 1981 revision, the Zoning Code dealt with the Dyche Stadium area as a U-2 District. (6-6-2 (B) 1). Dyche Stadium usage was permitted as part of the "athletic facilities." A musical performance might well have been a permitted use if it did not fall afoul of the exclusion, "not including the use of any building, stadium or other facility for professional athletics, sports, or games, or other commercial purposes."

A brief history of the university district's zoning is contained in the Report of the Evanston Zoning and Amendment Committee (ZAC) dated October 14, 1980, as presented to the Mayor and the City Council. There is no need to recite here all those events occurring since 1960 when the concept was initiated. Suffice to note that there were frequent efforts by the university to use Dyche Stadium for professional football games and other commercial purposes. These efforts were protested vigorously by the surrounding residents through acting though the Committee. Without commenting on the merits of individual proposals, the City Council asked the ZAC to consider revisions of the Zoning Code which would eliminate the constant friction between NU and the neighboring residents.

ZAC held numerous hearings, took endless testimony, and struggled for many months over the resolution for the [item]. As noted on page 4 of its Report, ZAC was guided by the Comprehensive Plan for the City of Evanston which had two [main] relevant objectives:

• • (1) "To create, preserve and enhance the residential environment for people who live in the community and for future generations," and

  • (2) "To recognize the value of Evanston's many institutions and control and accommodate necessary growth and change so as to preserve their excellence yet protect adjacent neighborhoods."

The accommodation of these different, but not inconsistent, ...was the creation of the U-5 and U-6 districts. Comments at p. 6:

"The proposed creation of the U-5 University Athletic Facilities District,  encompassing  both Dyche Stadium & McGaw, expressly prohibits the uses  that were originally requested by NU Districts  and their  location on the district  did  lead  the Committee to recognize the  contrasting  nature of the main campus,  including the landfill created by NU. Whereas, the Dyche Stadium-McGaw Hall area is located in the middle of a vulnerable Single-Family Residence District which is heavily impacted by all events that attract significant crowds to the facilities, the main campus is well insulated from the adjoining residential neighborhoods by major streets, public parks, a water filtration plant, and by a less dense University District, intended to serve as a buffer. It contains many of the events that were requested as permitted uses for Dyche Stadium and McGaw hall." 

This accommodation was adopted by the City Council without significant change, with the result that a musical performance such a s is now requested by Northwestern university for the Dyche Stadium can be held without further leave on the Lakefront Campus. It can only be held in Dyche Stadium after a demonstration of particularized need and minimal impact on the surrounding neighborhoods. With the new ordinance in place, the issue is no longer whether a musical performance may be held, but rather where it may be held. The history, purpose and structure of the ordinance reflect a clear community preference that large, commercial audiences be gathered at the Lakefront Campus.

The City Council has agreed with this position. It deliberately compromised competing interests making a musical performance in Dyche Stadium a hard to obtain special use, but letting it be a permitted use on the Lakeshore Campus.

It is true that Northwestern University did not request this trade off. The statement of NU of March 27, 1981, to the members of the Planning and Development Committee of the Evanston City Council objected, at page 3:

ZAC's trade-off on Dyche McGaw was to restrict the uses there and to allow professional athletics and commercial purposes (whatever that means) in the U-3 district east of Sheridan Road. That, of course, was wholly illusory, it conferred a benefit" for which we have no sue, and P&D has wisely stricken it from the proposed ordinance. In all other respects this ordinance does not solve the problems, it creates them. We urge you to consider the NU proposal that would regulate the use of our facilities by frequency of events and numbers of spectators."

However, in fact, the P&DE and the City Council adopted the ZAC compromise. If the ordinance creates problems, then it is up to Northwestern to explain why it is more problematic or difficult for them to hold a musical performance on the Lakefront Campus, where the City has clearly indicated it would prefer it to be held, and less problematic to hold it in Dyche Stadium. The statutory assumption is, and must be, that any large gathering in Dyche Stadium will injure property values appreciably.

Again, the issue is not whether NU is going to be able to have its performance. This can be done without leave of the ZBA, because the Council has already approved the use, in 1981. The only issue before the ZBA is where the use should be. The purpose of the zoning ordinance will be subverted unless Northwestern University can demonstrate in persuasive detail why it must forsake the encouraged lakefront site for the unsuitable location of Dyche Stadium. The application provides no instruction as to why the spacious lakefront is not available, nor does it suggest that some hardship would be worked upon the University if a "Woodstock" type performance were held there.

What follows is the entire document and below that, its entire transcription

MEMORANDUM

To: Evanston Zoning Board of Appeals

From: Citizens Zoning Committee of Evanston - John T. Allen, Jr.

Re: Application of Northwestern University for special use of Dyche Stadium - Case No. ZBA 81-48-SU (R) 

Our File No.:

Date March 16, 1982

Introduction.

The Citizens Zoning Committee of Evanston is an informal organization composed primarily of neighbors of Dyche Stadium. It has been in existence for well over 20 years, originally under the guidance of the late Russell E. Q. Johnson. Mrs. Johnson's home at 2730 Broadway is still headquarters. The sole and constant purpose of its existence is to ensure that the residential area surrounding Dyche Stadium is protected as provided by Evanston Zoning Code from the unreasonable or unlawful use of the stadium by Northwestern University. This organization has made numerous appearances before the Zoning Board of Appeals. My name is John T. Allen, Jr., and I live at 2356 Ashland Ave. in Evanston. Tonight it is my privilege to address you on behalf of the Committee. 

The occasion of our appearance this evening is the application to the Evanston Zoning Board of Appeals by Northwestern University for a permit to utilize Dyche Stadium for a musical performance pursuant to the Zoning Ordinance, # 6-6-5 (c) (1) (b). This is a special use, not permitted as of right, and it is therefore incumbent upon Northwestern to demonstrate to the satisfaction of the Zoning Board:

• 1. That the standards set out by the Zoning Code for granting a special use permit are met; and that

• 2. The special use is not an excluded professional or commercial use.

Our committee suggests that more than ordinary care should be taken in considering whether both tests for special use are [met].

The examination should be made in the context of the historical background of the revised zoning code. The ruling of the Zoning Board Appeals will, and should, establish ground as for other applications which may be expected to arise in the future. Our committee requests that the permit application be denied for failure to meet the standards for a commercial use in the Dyche Stadium facility.

[A.  Issues] presented.

This is the first construction of Ordinance 23-0-81, passed on ...1 13, 1981, which substantially revised the zoning structure of University districts. The issue raised is whether the U5 University Athletic Facilities District is the appropriate [loca]tion for a musical performance on a special use basis [as] the same performance could be held in the U-6 University lake-front Campus District as a permitted use. We emphasize that the issue is not whether the Associated Student Government of Northwestern University should be able to conduct a long and ...ded musical performance on a warm spring Saturday. That can be done regardless of the decision of the Zoning Board of Appeals or the City Council of Evanston. The issue is where that musical performance shall be held. In deciding this issue two tests must be met by Northwestern:

• • 1. The special Use Standards Test. This is a test of quantity, to determine the impact of large crowds attending any Dyche Stadium function on the surrounding neighborhood.

  • 2. The Professional Event Exclusion Test. This is a test of quality, to determine the probable nature of the crowds attending Dyche Stadium functions.

Background.

Prior to the 1981 revision, the Zoning Code dealt with the Dyche Stadium area as a U-2 District. (6-6-2 (B) 1). Dyche Stadium usage was permitted as part of the "athletic facilities." A musical performance might well have been a permitted use if it did not fall afoul of the exclusion, "not including the use of any building, stadium or other facility for professional athletics, sports, or games, or other commercial purposes."

A brief history of the university district's zoning is contained in the Report of the Evanston Zoning and Amendment Committee (ZAC) dated October 14, 1980, as presented to the Mayor and the City Council of Evanston, Illinois. There is no need to recite here all those events occurring since 1960 when the concept was initiated. Suffice to note that there were frequent efforts by the university to use Dyche Stadium for professional football games and other commercial purposes. These efforts were protested vigorously by the surrounding residents through acting though the Committee. Without commenting on the merits of individual proposals, the City Council asked the ZAC to consider revisions of the Zoning Code which would eliminate the constant friction between Northwestern and the neighboring residents.

The ZAC held numerous hearings, took endless testimony, and struggled for many months over the resolution for the [item]. As noted on page 4 of its Report, ZAC was guided by the Comprehensive Plan for the City of Evanston which had two [main] relevant objectives:

• • (1) "To create, preserve and enhance the residential environment for people who live in the community and for future generations," and

  • (2) "To recognize the value of Evanston's many institutions and control and accommodate necessary growth and change so as to preserve their excellence yet protect adjacent neighborhoods."

The accommodation of these different, but not inconsistent, ...was the creation of the U-5 and U-6 districts. To quote [the] comments at page 6:

"The proposed creation of the U-5 University Athletic Facilities District,  encompassing  both Dyche Stadium and McGaw hall, expressly prohibits the uses  that were originally requested by Northwestern University Districts  and their  location on the district  did  lead  the Committee to recognize the  contrasting  nature of the main campus,  including the landfill created by Northwestern University. Whereas, the Dyche Stadium-McGaw Hall area is located in the middle of a vulnerable Single-Family Residence District which is heavily impacted by all events that attract significant crowds to the facilities, the main campus is well insulated from the adjoining residential neighborhoods by major streets, public parks, a water filtration plant, and by a less dense University District, intended to serve as a buffer. It contains many of the events that were requested as permitted uses for Dyche Stadium and McGaw hall." (emphasis added)

This accommodation was adopted by the City Council without significant change, with he result that a musical performance such as is now requested by Northwestern university for the Dyche Stadium can be held without further leave on the Lakefront Campus. it can only be held in Dyche Stadium after a demonstration of particularized need and minimal impact on the surrounding neighborhoods. With the new ordinance in place, the issue is no longer whether a musical performance may be held, but rather where it may be held. The history, purpose and structure of the ordinance reflect a clear community preference that large, commercial audiences be gathered at the Lakefront Campus.

B.  The Licensing Issue.

At this point, perhaps a brief diversion is required. Despite Northwestern's characterization of the special use permit as a license, the zoning ordinance does not create a licensing procedure with its special use provisions. (This characterization is not accidental, but of long standing, and is evidently tied to Northwestern's concept that the present zoning ordinance governs the user and not the use.  Perhaps this has some legal significance for Northwestern concerning the validity and constitutionality of the zoning ordinance). The zoning ordinance special use procedure is not a licensing procedure.  The user is not being licensed to do an act. Rather, the issue is whether, as a special privilege granted for extraordinary reasons, the user of a facility will be permitted to conduct a specific use which is not otherwise permitted. If the requirements of the zoning code prohibit the use, the ZBA has no discretion in the matter. If the proposed use falls within the range of permissible special uses, the ZBA may recommend to the City Council that a permit issue. It is not a process of arbitrarily issuing or not issuing a license to the user, but rather a discretionary consideration of the desirability of a particularized use reached upon the basis of considered community judgement utilizing objective standards agreed upon its advance. It is the use which is crucial, not who intends to promote, or benefit from that use.

C.  Special Use Standards.

Section 6-12-7-(C) of the Zoning Code, provides zoning standards to minimize impact on the neighborhoods in which the special uses would take place. Unless these standards are met, "The Board of Appeals shall not recommend a special use."

Three standards are relevant here:

• • (a) Protection of the health, safety and welfare of the public ((C) 1);

  • (b) Avoidance of appreciable injury to the value of the property in the neighborhood in which it is located ((C)2); and

  • (C) Preservation of the primary purpose of the zoning ordinance or the zoning district or area for which it is proposed ((C) 3).

These objective standards place a heavy burden of persuasion to Northwestern. It must not only demonstrate that the proposed use will cause minimal turmoil and damage in the neighborhood but also a need for the use of the Dyche Stadium premises which overcomes the legislative purpose, a clear preference that such activities take place on a lakefront campus.

Insufficient Facts.

Nothing in the application suggests that thee burdens have been met, for not enough information has been made public for examination and consideration. As of the date of filing, there was no disclosure as to the identity of the suggested performer, or even of the type of musical performance which was being suggested. The representation was made only in the negative sort of way that "it would exclude "'hard rock'". The public, and the Zoning Board of Appeals are therefore presumably to trust in the good taste and good sense of the Associated Student Government as sufficient surety for observance of the Zoning Code and the preservation of the neighborhood. Without advance commitment as to the nature of the performance and the performers, it is very difficult to determine whether the proposed protections outlined in paragraph 4(a) are in any way adequate.

1.  Health, Safety and Welfare.

To elaborate on this theme, the neighbors are concerned about the quality of the audience to be attracted by the performance. We are advised by Northwestern that the performance will be limited to 25,000 (although just how this is to be achieved was never explained). We know, however, from various portions of the application, that the event is proposed for a Saturday in may and will also for four to six hours during daylight, We also know "there can be some expected temporary inconvenience in well attended spectator events" (which presumably includes a crowd of 25,000).

Northwestern does not expand on the inconvenience to be expected, but at a minimum the following elements should be considered,:

• • • (a)  Traffic along Central Street, Sheridan Road and Green Bay will be stalled for several hours before and several hours after the performance.

    • (b) Customers will be effectively blocked from utilizing the Central Street business district during the entire 4-6 hour period of the concert plus several hours before and after.

    • (c) Fire, police and ambulance vehicles will be delayed or blocked in attending to needs in northeast Evanston. This is a serious consideration, since there is a fire station on Central Street just east of the canal Bridge, and access to Evanston Hospital would be very much affected by traffic conditions on Central Street, Sheridan Road and Ridge Avenue.

    • (d) Assuming a crowd of 25,000 for a musical performance which would appeal to students in the Spring, the track record for good behavior is unsettling.

    • (e) There will probably be a substantial cost to the city if the uniformed police officers to which the Application refers are on special duty. If not, then the rest of the city is going to be without substantial police protection.

    • (f) A crowd of 25,000 for the unspecified performance requested would probably not be substantially composed of sedate middle aged alumni. Although usually Northwestern students are well behaved, we should not forget that the concert is in May, that exams will be coming, and that it has been a long, cold winter. The combination might prove combustible. As for the "outsiders", who would be numerous, we also have personal experience at the Fourth of July celebrations with the upper deck missile problems at Dyche Stadium.

In support of these claims, the Committee submits a report presented to ZAC concerning crowd effects.

2.  Property Value Injury.

There is really no issue here. The McCann testimony of July 5, 1979, was criticized and questioned by other experts, and it is at best inconclusive. In any event, the ZAC correctly concluded that the residential area surrounding Dyche Stadium "is heavily impacted by all events that attract significant crowds to the facilities." (Emphasis added) 250000 people constitute a "significant crowd". The City Council has agreed with this position. It deliberately compromised competing interests making a musical performance in Dyche Stadium a hard to obtain special use, but letting it be a permitted use on the Lakeshore Campus.

It is true that Northwestern University did not request this trade off. The statement of Northwestern University of March 27, 1981, to the members of the Planning and Development Committee of the Evanston City Council objected, at page 3:

ZAC's trade-off on Dyche McGaw was to restrict the uses there and to allow professional athletics and commercial purposes (whatever that means) in the U-3 district east of Sheridan Road. That, of course, was wholly illusory, it conferred a benefit" for which we have no sue, and P&D has wisely stricken it from the proposed ordinance. In all other respects this ordinance does not solve the problems, it creates them. We urge you to consider the Northwestern proposal that would regulate the use of our facilities by frequency of events and numbers of spectators."

However, in fact, the Planning and Development Committee and the City Council adopted the ZAC compromise. If the ordinance creates problems, then it is up to Northwestern to explain why it is more problematic or difficult for them to hold a musical performance on the Lakefront Campus, where the City has clearly indicated it would prefer it to be held, and less problematic to hold it in Dyche Stadium. The statutory assumption is, and must be, that any large gathering in Dyche Stadium will injure property values appreciably.

3.  Subversion of the Ordinance.

Again, the Zoning Code is intended both to accommodate the University uses (6-6-1) and also to protect residential areas by minimizing the number of large crowd uses of Dyche Stadium and restricting them in quality to those compatible with the residential setting in a fragile nearby business district. Except for the permitted uses stated in 6-6-5 (B), the clear purpose of the Zoning Code is to reconcile the competing interest of the University and City by permitting large crowd uses on the Lakefront Campus and discouraging them in Dyche Stadium.

Again, the issue is not whether Northwestern is going to be able to have its performance. This can be done without leave of the ZBA, because the Council has already approved the use, in 1981. The only issue before the ZBA is where the use should be. The purpose of the zoning ordinance will be subverted unless Northwestern University can demonstrate in persuasive detail why it must forsake the encouraged lakefront site for the unsuitable location of Dyche Stadium. The application provides no instruction as to why the spacious lakefront is not available, nor does it suggest that some hardship would be worked upon the University if a "Woodstock" type performance were held there.

Whether or not circumstances may some day exist which would make Northwestern's request reasonable, the present runs counter to the City Council's recently expressed desires in the matter and the purpose of the Zoning Code. In the facts of this situation, Northwestern should show more than ordinary necessity to carry its burden of invoking the discretion of the ZBA. It has not done so in this instance.

4.  The Survey.

One final digression on community impact is in order. The application, in closing, states that "prior to the filing of this application, Northwestern students canvassed the neighborhood to determine what, if any, objections there might be to the proposed performance. A sampling of the response to the canvas are attached hereto as Applicant's Group Exhibit A."

We are unable to comment on the significance of the Northwestern responses, because we do not know what standards were used in conducting the survey. Neither do we know what full disclosure of the canvas would reveal, sine Northwestern has refused to disclose it to the neighbors, although requested to do so. Our Committee has conducted a follow-up survey, with nearly 500 signatures, all of which will be presented to the Zoning Board of Appeals tonight. Our survey strongly suggests that a majority of the surrounding residents would object to a musical performance in Dyche Stadium along the lines described. At most, the student survey provides inconclusive support for Northwestern's position. In any event, it should be noted that the Council attempted to resolve just this sort of fruitless argument by making musical performances at the stadium a special use. It is now presumed, by force of statute, that "all events that attract significant crowds to the facilities" are, without exception, objectionable.

On the basis of the foregoing analysis, our group recommends to the Zoning Board of Appeals that the application of Northwestern be denied for failure to meet Special Use Standards.

D.  The Professional Event Exclusion.

The second part of the analysis concerns whether or not the proposed performance is excluded as a special use under the Section 6-6-5 (C) 3 ("the foregoing special use shall exclude (a) professional athletics, sports, games and events or other commercial activities..." (emphasis added)  It is not clear from the application whether a professional performer will be retained for the musical performance. The Application suggests (in paragraph 7) that an amateur (unpaid) group will be used since, "all proceeds from the performance will be used for Northwestern athletic facilities." (emphasis added)

In this regard, it is useful to examine the definition of "commercial purpose" in Section 6-2-4 of the Zoning Code:

• • "An occupation, employment or enterprise which is carried on for profit, by the owner, lessee or licensee, except for activities carried on by a not-for-profit organization which utilizes the proceeds of such activities solely for the purposes for which it is organized."

Blacks Law Dictionary - 5th Edition (1979) defines "proceeds" as:

• • "Issues; income; yield; receipts; produce; money or articles or other things of value arising or obtained by the sale of property; the sum, amount or value of property sold or converted into money or into other property...Proceeds includes whatever is received when collateral or proceeds is sold, exchanged, collected or otherwise disposed of."

            This is elaborated in Webster's Third New International Dictionary, Unabridged which defines "proceeds" in part as:

• • "1a: what is produced by or derived from something... by way to total revenue; the total amount brought in...(b): The net profit made on something..."

            Since the application states that "all proceeds" will be used for the Northwestern athletic facilities, presumably no payments will be made to the performers, and no professional or commercial use would be present.

             However, it is not clear from the application that northwestern did not instead mean that only "net proceeds" would be paid to the not-for profit organization and that a professional group of musicians would indeed be paid for playing. If so, the issue must be analyzed.

            Assuming that a paid professional performer is being used, then the proposed special use is excluded, either as a 'professional Event, " or as a "community activity"." it is clear, from the history of this ordinance, that the Chicago bears cannot play a professional football game in Dyche Stadium even if provided with a figleaf of sponsorship by the Associated Student Government. A professional game, where performers are payed to play, remains professional no matter who claims credit for the role of impresario.

            The key is "play for pay". The use, a professional performance, and not the use, be it the Chicago bears or the Associated Student Government, or the University itself, is crucial. With regard to the issue of professionalism or commercialism, the City Council has spoken, as clearly as it can speak. If the Chicago bears players work for nothing and meet special use standards they may use Dyche Stadium. If they work for pay, they must use the lakefront. It is the professional use not the identity of user that disqualifies them under this leg of the test.

Again, Northwestern University has provided insufficient information ion this point to permit the ZBA to make a reasoned determination as to whether "play for pay:" is involved. Accordingly, we request the Zoning Board of Appeals to deny the petition on the basis of the probable existence of a professional or commercial event.

Respectfully submitted

CITIZENS ZONING COMMITTEE OF EVANSTON

By John T. Allen, Jr.

Below see the March 16 minutes from the ZBA Case 81-48-SU(R) about the proposed concert. 

The document is missing several pages. 

There are many passages that resonate with the 2019 NU Text amendment proposal.

Briefly:

• p. 18 & p. 33: concerts' rowdy/dangerous crowds

• p. 2326:  negative impact on Central Street businesses

• p. 32: impact on Wilmette.: Resolution 82-R-13   see also:

• p. 35: Impact on emergency services

• p. 44-47 issue of what is a commercial event.[p 47: "Gardner: I think they are beyond bounds, because I think that this is a commercial event that Northwestern is putting on through a student front. The money is going to Northwestern. There is no charitable aspect to the thing. There is no altruism. The money is going to Northwestern. It's going for things that the University would pay for if it isn't raised by the students. So that actually, what you're doing in a circular way,  is allowing the University to rent the stadium for a commercial event."] 

The ZBA  recommended denial of the concert special use application on May 18, 1982. 

The ZBA in 1982, unlike the Plan Commission in 2019, did not disregard NU's customary  lack of information regarding most details of their proposal. The ZBA took issue with NU  not providing specifics on who would be the performing artists, what type of sound system would be used,  what type of security, what exact  transportation and parking options would be provided, etc. 

"Dyche Stadium is intended primarily for intramural and intercollegiate sports events, and the impact of these events on the basically residential surrounding neighborhood is recognized by the property owners in the area. To now introduce a concert in this neighborhood without very specific controls on noise, crowds, traffic and parking would, in our opinion, be detrimental to property values.   

Further it should be recognized that such a concert would be a permitted use in the U6 University Lakefront Campus District.

The applicant failed to establish that the proposed special use will not subvert or defeat the primary purpose of the Zoning Ordinance or the zoning district or area in which it is proposed when its effect is considered in conjunction with the cumulative effect of the number of special uses of all types already located in the adjacent area an din the City as a whole."