TO: Supervisor Aaron Peskin

FROM: Carol Roos, Sr. Legislative Analyst

RE: DOWNTOWN MEDICAL OFFICE BUILDINGS:
450 SUTTER STREET AND 490 POST STREET

SUMMARY OF REQUEST

Supervisor Peskin requested the Office of the Legislative Analyst (OLA) to determine current zoning of buildings at 450 Sutter and 490 Post Streets and explore possible policy actions and land use controls that would allow these buildings to continue their established role as centers for medical and dental services. Subsequently, the Supervisor"s office focused on market dynamics and a jurisdictional comparison, as well as asking City Attorney staff to pursue the issue of land use controls in greater detail. This report provides a summary of the different issues in play, and a comparison with several other jurisdictions. Information is generally for the first six months of 2001.

BACKGROUND

There are a number of medical office buildings (MOB"s) in San Francisco"s downtown. Prominent among them are 450 Sutter Street and 490 Post Street (also known as 470 Post Street). (Figure 1 shows the distribution of medical offices throughout the City.)

Architectural Merit. Both 450 Sutter Street and 490 Post Street buildings are Category I buildings under Planning Code Article 11, Preservation of Buildings and Districts of Architectural, Historical, and Aesthetic Importance in the C-3 Districts. Category I - Significant Buildings, are buildings which according to methodology explained in the Downtown Plan element of the General Plan: "are at least 40 years old; and are judged to be Buildings of Individual Importance; and are rated Excellent in Architectural Design or Very Good in both Architectural Design and Relationship to the Environment." Category I is the highest rating in the I-V rating series. Both buildings are in the Kearny-Market-Mason-Sutter Conservation District (described in

Article 11.) Neither building is a City Landmark. Both buildings have been surveyed and appear eligible for listing on the federal National Register (of Historic Places).¹

· In summary, both buildings are highly rated for architectural merit.

Zoning/Required Approvals. The 450 Sutter building is in the C-3-R (Downtown Retail) use district and 490 Post is in the C-3-G (Downtown General) Use District; both are within an 80-130-F Height and Bulk District.

C-3-R: Downtown Retail. According to the Planning Code (section 210.3), this district covers a compact area with a distinctive urban character, consists of uses with cumulative customer attraction and compatibility, and is easily traversed on foot. Continuity of retail and consumer service is emphasized.

C-3-G: Downtown General Commercial. According to section 210.3, the district covers the western portions of downtown and is composed of a variety of uses: retail, offices, hotels, entertainment, clubs and institutions, and high-density residential.

The Planning Code does not distinguish between medical and other office space, in the downtown core (C-3 districts). The term Offices, per section 219, includes both professional and business offices. Section 219(a) allows offices as principal permitted uses (requiring no special authorization) in all C-3 districts, if they are less than 5,000 gross square feet (gsf) in size and offer on-site services. Section 219(b) requires Conditional Use (CU) authorization for offices in the C-3-R district only, if larger than 5,000 gsf, offering on-site services; conditional use is not required for the other C-3 districts. Similarly, section 219(c) requires CU authorization only in the C-3-R, for "other professional and business offices above the ground floor. In addition to the criteria set forth in Section 303, (Conditional Uses), approval shall be given upon a determination that the use will not detract from the district"s primary function as an area for comparison shopper retailing and direct consumer services." Medical offices may be considered to provide a direct consumer service. Under Section 219(d), Other professional and business offices at or below the ground floor are not permitted in the C-3-R district, and require CU authorization in C-3-O, C-3-G and C-3-S (Downtown Support) districts.²

Section 101.1(b) of the Planning Code, establishes eight Priority Policies of the General Plan. The City may not adopt any zoning ordinance or development agreement unless it finds that the ordinance or development agreement is consistent with the Priority Policies (section 101.1(d)). Similarly, prior to issuing a permit for any project or adopting any legislation which requires an initial study under CEQA, and prior to issuing a permit for any demolition, conversion or change of use, and prior to taking any action which requires a finding of consistency with the General Plan, the City shall find that the proposed project . . . is consistent with the Priority Policies (section 101.1(e)). The following priority policy is relevant: (5) "That a diverse economic base be maintained by protecting our industrial and service sectors from displacement due to commercial office development. . . . "

ISSUES/ANALYSIS

SAN FRANCISCO

Cost, Availability of Space, and Vacancy Rates. Regarding cost and supply of medical office space downtown, and citywide, OLA contacted real estate firms that track office space, and the Citywide Policy section of the Planning Department which tracks trends and data for its downtown monitoring and commerce and industry update efforts. Data on health services establishments, from the Planning Department, for the years 1995-1999, show that the number of these establishments in the Financial district increased from 1995-1998 and declined in 1999, dropping from about 16 percent of total medical establishments citywide, to 14 percent. This represents a 7.6 percent drop. (See Table 1.)

Specific market dynamics for medical office space are difficult to determine precisely, because this market niche is relatively small enough that medical office data is not disaggregated from the broader office category, and small enough that realtors do not specialize in it (compared, for example, to law offices, a larger niche). It is generally acknowledged, that the dot.com/information technology boom with its associated skyrocketing rents and low vacancy rates has dramatically subsided, as discussed below (in the Options section).

Specific information regarding rents and vacancy rates was obtained for 450 Sutter and 490 Post, as follows.

450 Sutter Street³. The building includes about 271,000 sq.ft., and medical/dental offices range from about 800-1,200 sq.ft. in area. The rental rate structure for new tenants is in the low-to-high $5/sq.ft./month range, (about $60-70/sq.ft/year) range, in three rent tiers that increase with height in the building.⁴ The current vacancy rate is 30 percent (June 2001). The vacancy rate in the building has been 20-25 percent for most of the last 20 years; older information was not available from management. In 1990, there were 90 doctors in the building; now there are 30. Building management believes that younger doctors currently do not open single practice offices now and prefer, or are required, to locate near medical centers. The San Francisco Medical Society is not aware of such requirements. In the experience of management, as older doctors retire, younger doctors do not replace them in the building. It is more common for younger dentists to associate with older dentists and eventually take over the practice. So, there is some expansion of dental offices in the building. Building management has decided to use lower floors for general office rather than medical office use and to retain doctors on upper floors. For example, lower floors five and six, previously a surgery center were vacant, and a lease was signed with a "dot.com" firm; the lease was not implemented. Also, tenants (dentists, pharmacy, building management) on floors three and four were relocated to accommodate offices of a construction company, a Conditional Use for which was approved by the Planning Commission, February 1, 2001 (Motion No. 16085). The Conditional Use requirement was triggered by the proposed size of these offices.

According to the general manager, some doctors with five- or ten-year leases have preferred to continue on a month-to-month basis when their long-term leases expire. Management states it has complied with all that have asked for a lease. According to a representative of the building owners, management offered a referral incentive of $1,000 to any doctor or dentist in the building who refers a tenant in the medical profession who stays.⁵ Since June 2001, the building manager reports that management has done six or seven new leases, and worked with dentists wanting to expand, making larger offices available to those who want to expand.⁶A separate firm is leasing agent for non medical/dental space in the building. Rents for non medical/dental space for June 2001, were about $3.20-3.50 sq.ft./month ($38-42 sq.ft./year)⁷

Some doctors and dentists at 450 Sutter, have expressed concerns related to the failed dot.com rental and the Turner Construction office approval. Some practitioners are reluctant to come forward because of their tenant status. Based on anecdotal information from doctors/dentists, frustration was expressed by most, but not all, of those who related their experience. For example, a HIV specialist health care provider moved out in fall 2000, after a monthly increase from $6,000 to $16,000, and relocated to a California Street medical center with office rent of $6,000.⁸ Another physician reports he has a good lease, and wanted to expand (double) his space and add another physician to his practice. According to the doctor, building management offered $30/sq.ft. of the $150/sq.ft. improvement cost, leaving $120/sq.ft. to be paid by the physician. The $240,000 expense ($120 X 2,000 sq.ft.), to be amortized over a relatively short period, in addition to rent for the space, precluded the expansion. The pharmacy was relocated in the building, but not to its preferred space. A dentist reported that she was a building tenant for 20 years and voluntarily moved once. According to the dentist, she was asked in May 2000, to vacate her office to accommodate the construction company move-in, and to relocate in the building. The proposed rent was to be $65/sq.ft./year excluding tenant improvements such as specialized electrical, plumbing and cabinetry work (estimated at about $100,000, in addition to rent). The dentist looked for about one and one-half years for space elsewhere and now rents from a dentist, at 500 Sutter Street. She believes her practice has lost half its value, without space control and staff. This dentist emphasized the importance of location near 450 Sutter Street, as her patients are area employees who walk and take BART, and believes the remaining value of her practices consists of her work and her patient list. Were she to have moved further away from 450 Sutter, her patient list would have decreased in value.

On the other hand, one physician"s office ended its lease early, and its business manager reports that building management was accommodating regarding both its request to terminate its lease early, and its phased move-out. Another doctor reported that the building currently is more willing than before to work out long-term leases. Among the medical practitioners who have expressed concern, issues include the perception that management does not encourage their tenancy or accommodate their space needs, including not providing them with incentives which they consider usual practice.

490 Post⁹ This building includes about 152,000 sq.ft. The current owners acquired the building in spring 2001. According to management, the vacancy rate is 15 percent, one-half that of 450 Sutter, and Post Street management say they have not yet begun to market the building. The building is 90 percent medical/dental, and management reiterated a commitment to keep the building in medical office use. Rents are in the $4/sq.ft./month ($48/sq.ft./year) range for new renters, lower than 450 Sutter rents. Management does not feel that doctors want to relocate; most tenants rent long-term, rather than short-term. For this building, management did not see differences between doctors and dentists, but noted that 450 Sutter had more dentists than 490 Post. Management for 490 Post Street indicated it is flexible in negotiating leases and incentives to rent, including cost of improvements, and stated that leases are considered on a case-by-case basis.

Regarding medical office proximity to medical centers, California Pacific Medical Center (CPMC) has about 900 active doctors that practice at its hospitals. This year, about 475 of these doctors were located in office space at CPMC campuses, about 21 of active CPMC doctors were at 490 Post Street, and about 30 at 450 Sutter Street. The CPMC cannot accommodate all of its doctors at its campuses and relies on space in the downtown buildings.¹⁰

· In summary, 450 Sutter has a vacancy rate that is twice the vacancy rate of 490 Post, higher rents, and frustration has been expressed by some of its tenants regarding rental arrangements. Management at 450 Sutter is interested in renting to other than medical office uses, while 490 Post management expressed commitment to medical offices.

OTHER JURISDICTIONS

Seattle

The owner of 450 Sutter also owns the Seattle Medical Dental Building in downtown Seattle, an older building of some architectural merit. The building is experiencing issues like those at 450 Sutter, according to building management, with doctors in particular staying near hospitals and not coming downtown¹¹ The building includes about 351,000 sq.ft. According to Seattle management, like San Francisco, dentists are a more stable population than doctors; and, the latter migrate to larger group practices or HMO"s. Management states it would like to have more medical practices in the building, and reports a 20 percent vacancy rate, dating from the 1980"s. The building is no longer primarily medical/dental space. Beginning in 1998, this building was opened to professional offices including psychotherapists, and non profit organizations. Rents are in two tiers based on height in the building, ranging from about $2 to $2.50/sq.ft./month ($24 to $30 annually). Leases are a minimum of three years, and management would like to see five-year leases. New tenants prefer leases; older tenants are generally month-to-month.

Management of a second medical office building, the Cobb Medical Dental Building, in downtown Seattle was queried.¹² The building includes about 80,000 sq.ft. Bank of America leases about one-half of the building, with ground floor banking and offices above; the bank sublets some of the latter. Less than one-half of the building is in medical/dental use. Included are "quite a few dentists, and a few physical therapists." The building is one of six under the same management in the Metropolitan Tract area of the city. Overall, the vacancy rate in the six buildings is one percent, with the bulk of the vacancy in the Cobb Building (10 percent). Rents are in the $2/sq.ft./month ($24/year) range. Management noted that even though, "everyone who works downtown says it is incredibly convenient" to have their doctor downtown, the trend is away from the downtown, based partly on rents. Additionally, Seattle has a medical center in the outer downtown area, outside the central business district, called First Hill, and medical establishments are concentrated there.

According to city staff of the Design, Construction and Land Use division, Seattle does not regulate to protect medical offices specifically. The city has protective regulations for certain other land use classes including SRO"s (single-room occupancy hotels). The city requires 1:1 replacement, or an in lieu fee, for their elimination. The case was made that SRO residents did not have choices, their social services were located downtown and, being unable to afford new housing downtown, they would be disconnected from health care services if they were to have to relocate. As in the statement above, that downtown workers like their medical services nearby, in this case a related argument was made for poor, senior, and disabled downtown residents. This argument was also made in San Francisco regarding medical office displacement at 450 Sutter, in relation to some Tenderloin residents who used medical services there and who have fewer choices regarding going greater distances for care. Seattle also protects its industrial base south of the downtown with use restrictions in the form of a zoning overlay to preserve manufacturing and industrial uses and protect warehouses from conversion to dot.com workspaces.

· In summary, Seattle medical office buildings include other than medical offices, and Seattle has a medical center area outside the downtown core. Seattle protects certain land uses, including SRO"s (requiring 1:1 replacement, or payment of an in lieu fee), and industrial uses which are protected with a zoning overlay, from encroachment by Internet businesses.

Palo Alto¹³

Welch Road in Palo Alto is the primary location for doctor/dentist offices in the area. It is considered a prestigious address, one block from the Stanford University Medical Center. Welch Road is currently zoned OR, Office Research. Uses permitted in the district are, basically, medical, professional and general business office. General business office, is a use principally providing services to individuals, firms and entities, including but not limited to, real estate, insurance, property management, title companies, investment, personnel, travel and similar services. Professional offices include offices such as those for attorneys, architects and designers. Other kinds of office such as administrative or business office are not allowed. Research and development require Conditional Use authorization. The zoning district is intended to allow for an area that is educationally, medically, and research oriented.

In spring/summer 2000, city planning staff mentioned the possibility of exploring whether to consider the feasibility of rezoning University property used for medical, dental and other medical practitioners offices in medical office buildings on Welch Road, to allow residential use, to help address the city"s housing needs and, specifically, the housing demand of employees of a new cancer center at Stanford. Opposition was organized jointly by doctors and patients. More than 200 doctors attended a city council meeting on the issue. And, the Stanford Hospital and Clinics Medical Board, passed a resolution supporting retention of health care office zoning along Welch road. As noted, the proposed conversion of uses would require rezoning of the Welch Road area. The Santa Clara Medical Association, in its opposition to rezoning expressed concern that the issue of displacement of doctors raises non-legal issues including continuity of care, quality of care and the doctor-patient relationship. In a editorial, one Welch Road patient said," doctors who have chosen to have small practices so they can serve their patients better will be forced out of practice or moved to a distance that any of us in today"s traffic would find difficult."¹⁴ According to city planning department staff, the "proposal" never left the concept stage and is not currently under consideration.¹⁵

· In summary, when an area of concentrated medical offices was proposed to be considered for rezoning for residential use, affected medical practitioners successfully challenged the concept.

San Mateo County and the City of San Mateo

San Mateo County was hard hit by the dot.com explosion, and the San Mateo County Medical Association was one of those offices displaced. Displacement took place throughout the county, with owners offering long-term,

top dollar leases only.¹⁶ The medical society relocated at two and one-half times its existing rent, leaving its old location when rents went to four and one-half times existing rent. The old space was gutted but was not leased, as the market declined. Now the sublease market is a dominating element of the market, as it is for other affected parts of the region. In another instance described by the medical association, tenants of a medical office building faced with escalating rents and replacement by dot.com enterprises, hired legal counsel, but decided to lave the building and were able to relocate relatively nearby. The crisis in San Mateo County appears to have subsided with the downturn in the dot.com sector.

While the director of the county medical association has not noted an exodus of doctors from the area, she has observed the aging of the medical community. It is becoming harder to attract new doctors to the area. That is, physicians who are not from the area and/or trained here are less likely to come due to incurred debts, the cost of housing, and general cost of living in the Bay Area.

Housing and office space costs for doctors, and housing and transportation costs for nurses and other non-M.D. hospital staff are making it difficult to recruit new doctors, nurses and other staff throughout the San Francisco Bay Area.

Pressures from the dot.com sector also negatively affected other uses in the City of San Mateo.¹⁷ While the primary affected use was retail, not medical office, the issue was similar. In response, the city council in fall 2000, placed a moratorium on Internet-related businesses moving into ground floor space downtown, to prevent displacement of retail tenants. The Chief of Planning for the city stated, "we were afraid if we didn"t step in, it would be potentially irrevocable."¹⁸ The moratorium is in effect until October 17, 2001, and permanent controls are now being considered. The interim ordinance requires ground floor retail use, and prohibits conversion of ground floor retail to office use. Above the ground floor various uses, including Internet, real estate, and medical are allowable. For a neighborhood district (outside downtown) that was similarly affected, controls may revert to prior regulations, which set a maximum size limit of 2,500 sq.ft. for ground floor office.

OPTIONS

No Action. Allow Market Forces to Regulate Uses.

In the no action view, proponents believe that, rather than asking a landlord to favor one use out of "political" concerns, the City can instead rely on long-term adjustment and readjustment in the market as self-adjusting mechanisms that address the issues.

Currently, the market, specifically the dot.com boom and associated escalated rents that displaced some medical practitioners and threatened others, have subsided. According toWhitney Cressman, a San Francisco-based commercial real estate advisory and brokerage firm, the office vacancy rate for the Union Square submarket, in which 450 Sutter and 490 Market Street are located, was about 4 percent in October 2000, 8 percent at year end 2000, and 13 percent at the end of June 2001 a rapid increase of 9 percentage points in 9 months. For comparison, the Citywide office vacancy rate was about 2 percent in October 2000, 4 percent at year-end 2000 and 11 percent in June 2001, also an increase of about 9 percent over 9 months.

Vacancy rates reported for office use may not apply exactly to medical offices. According to Whitney Cressman staff, general office vacancy rates alone should not be used to evaluate policy for medical office buildings. The latter are limited use, expensive to convert (tenant improvement dollars may surpass $150/sq.ft.), and buildings with infrastructure such as special plumbing are designed for this specific use, medical offices have maintained fairly strong demand even during weakening markets such as the current market. So, the vacancy rates for offices in the City may not be directly applicable to medical office buildings. The vacancy rate may, however, increase or decrease pressure on medical space, when the general office vacancy rate drops or rises substantially. Because the supply of office buildings built to accommodate medical-dental use is limited, finding available space can be relatively more difficult.¹⁹

As described in the discussion of 450 Sutter and 490 Post, the vacancy rates in these buildings, are 30 percent and 15 percent, respectively, compared to 13 percent for overall office space in the Union Square submarket in which they are located.

Use of Existing Controls

Conditional Use (CU) Authorization

As discussed above, a CU is required for offices of more than 5,000 sq.ft. in area in the C-3-R district. This provides for review of conversions, if they exceed this size threshold. When the threshold is exceeded, Conditional Use is required for any office, including medical offices, which could affect doctors forming group practices, that is, expanding.

The Planning Code, particularly sections 219 and 303 could be amended in various ways to address problems related to conversion of medical to other space. Amending Section 219(b) to exempt medical offices from the potential of CU authorization could provide an incentive to retain, or encourage, small medical offices. However, joint medical practices, which are larger, could be precluded. In the C-3-R, medical offices greater than 5,000 sq.ft. in area could be made a principal permitted use, instead of requiring Conditional Use authorization.

Section 303 could also be amended to include additional criteria for offices of greater than 5,000 sq.ft. when they include conversion of medical office to other office, similar to section 303(f) Conditional Uses. Hotels and Motels. Or, there could be more focus on review of proposed conversions. For example, regarding the conversion at 450 Sutter for the offices of Turner construction, critics focused on that specific Conditional

Use action, rather than the Conditional Use process itself.

Special Use District (SUD) zoning overlay

A Special Use District could be established for some part, or all of the C-3 use districts of the Downtown. A SUD could tailor specific controls for retention of medical offices buildings downtown and prevention of conversion to other office, including in buildings of architectural merit.

Discretionary Review(DR)

The City Planning Commission could implement a DR policy for conversion of medical office space, and consider each proposed conversion on a case-by-case basis. Implementation of an SUD or DR policy, would require an accurate inventory of medical offices, or a mechanism such as requiring an applicant statement that medical office conversion is not part of a proposed conversion.

Other Aspects of Land Use Controls in Relation to these Options

Land use controls, have historically been one response to concerns about imbalance of land uses, including perceived over proliferation of, or threat to, a particular use. San Francisco has traditionally used such mechanisms, including requirements for Discretionary Review and Conditional Use authorization, Special Use Districts, moratoria, and interim controls. The citywide neighborhood commercial plan and rezoning (1986 and 1987, respectively) is an example of regulation of certain uses in certain neighborhoods, directed at maintaining balance and protecting certain uses. Planning Code Article 7, Neighborhood Commercial Districts, includes its purpose and intent in Section 701.1, including Section 701.1(c): "To provide zoning control categories which embrace the full range of land use issues in all Neighborhood Commercial Districts, in order that controls can be applied individually to each district class to address particular land use concerns in that district." [emphasis added].

Factors and potential criteria that could be considered in developing the purpose and intent, were controls to protect medical offices to be considered, include General Plan policies and objectives, such as transit first. Downtown workers and residents using downtown medical practitioners are less likely to drive and more likely to walk or use transit in this transit rich area. Trips to medical offices downtown would be more likely to include linked trips (commuting to and from work by transit for example, and in between, walk or transit trips to medical appointments, and perhaps to other downtown retail or restaurant uses, in support of downtown businesses. Fewer trips and, thus fewer vehicle miles traveled also have beneficial effects on air quality. It could be argued that such land use controls support community values, transit oriented development, and a lively downtown core. And, there are efficiencies of scale in large medical office buildings that have already been improved or constructed for such use. Efficiencies include handling of medical wastes and customized space improvements, for example. If successful, policies to retain and encourage downtown medical offices could also preserve these uses for nearby workers, as well as residents. The 450 Sutter building, especially, also serves a distinct elderly population. One doctor reported he has an 104-year-old patient and a 102-year-old patient. According to the doctor, this building is very accessible, with its garage directly adjacent to its lobby. For proponents of land use controls, rather than favoritism for a particular use due to political concerns, planning guidelines and regulations are perceived as a framework with which the market can operate. In this view, self adjusting market mechanisms cannot replace the uses (and workers and residents) that have been displaced.

Tax Credits

According to City attorney tax team staff, tax credits are not feasible for the purpose of protecting medical offices downtown. Tax credits for historically significant buildings, in the Internal Revenue Code, primarily apply for major rehabilitation projects, rather than individual office spaces. With respect to a possible credit against the payroll expense tax (which is tied to business operations rather than buildings or locations), it does not appear that the City could define what is being taxed with enough specificity to promote or protect only such land uses targeted for conversion -- medical offices in downtown buildings -- without potentially raising constitutional questions. And, property taxes are regulated by the state, with prescribed formulae for tax collection and remittance to the school district, and other recipients, and regarding monies returned to the City.

Participation

In Palo Alto, the Welch Road Tenants Association was formed out of concern about Stanford University"s potential rezoning of the area from office to residential use, and more than 200 physicians and practitioners with offices on Welch Road packed city council chambers in protest. Besides additional land use controls, local medical and dental associations could consider options, such as increasing their participation in land use decisions affecting their members.

CONCLUSION

No jurisdictions were found during this research that reported the exact situation experienced in San Francisco regarding medical offices. Some jurisdictions had experiences that were similar in some ways, however. Jurisdictions including Seattle and San Mateo enacted zoning controls in the form of a moratorium and interim controls (City of San Mateo), a replacement or in lieu fee, or a zoning overlay (Seattle), to protect valued uses from conversion to dot.com offices.

While number of establishments is a useful marker in researching trends, other factors may also be of importance in evaluating City policy. That is, even if data show a decline in number of medical offices downtown over time due to medical marketplace or real estate market trends, other factors may support policy, including land use controls, to retain medical offices in the downtown. The current market slump removes pressure to decide immediately on to how to proceed, and allows time to consider and choose among the possible options discussed above.

¹ The 450 Sutter building was also rated 5, the highest rating in the 1976 Planning Department Architectural Survey; 490 Post is rated 1 in this survey. The Foundation for San Francisco"s Architectural Heritage (Heritage) rated 450 Sutter "A" (its highest rating), and 490 Post, "B". Information from Adam Light, San Francisco Planning Department, telephone communication; July 9, 2001.

² Information primarily from Michael Li, San Francisco Planning Department, telephone communication; July 10, 2001.

³ Information in this section is primarily from Stan Mackewicz, General Manager, 450 Sutter Building, telephone communication;

June 11, 2001.

⁴ In September 2001, one doctor reported that rents have since decreased to the $4-5/sq.ft./month ($48-60/sq.ft./year) range.

⁵ Peter Sotos, Vice President, Bay Area region, Harsch Investment company. Representing the owners of 450 Sutter Street; testimony before the Planning Commission, February 1, 2001, from minutes of the Planning Commission.

⁶ Stan Macewicz, General Manager, 450 Sutter Building, telephone communication; September 10, 2001.

⁷ Leasing agent Simon Poulton, Whitney Cressman; September 10, 2001.

⁸ Vanessa Hua, San Francisco Chronicle, Reversal of Fortune; March 4, 2001.

⁹ Information in this section is generally from Barry Cowan, Manager, 490 Post Street, telephone communication; July 6, 2001.

¹⁰ Robert Passmore, Marchese Company, telephone communication; September 10, 2001.

¹¹ Information from Pat Riek, Assistant Property Manager, Harsch Investment, Seattle; telephone communication; June 11, 2001.

¹² Information from Laura Thomas, Property Manager, Unico Properties; telephone communication; July 13, 2001.

¹³ Information is primarily from Bill Parrish, CEO/Executive Director, Santa Clara County Medical Association, telephone communication; June 6, 2001, and Lisa Grote; see Footnote 15.

¹⁴ Loretta Green, editorial, San Jose Mercury News; July 14, 2000

¹⁵ Lisa Grote, Chief Planning Official, City of Palo Alto, telephone communication; September 7, 2001.

¹⁶ Information from Sue Malone, Director, San Mateo County Medical Association; telephone communication; June 7, 2001.

¹⁷ Ron Munekawa, Acting Chief of Planning, City of San Mateo; telephone communication, July 17, 2001.

¹⁸ Mary Gallagher, Chief of Planning, City of San Mateo; quoted in the article, "Reversal of Fortune". See footnote 8.

¹⁹ The preceding information is from Mike Hamasu, Director of Market Research, Whitney Cressman Ltd.; telephone communication, July 17, 2001, and communication July 20, 2001.