A New DC Comprehensive Plan



Ever since the publication of the "DC Vision" Document in 2004, DC's Office of Planning (OP) has been working to develop a new Comprehensive Plan for the District. When approved late in 2006, it promises to be the first new plan in some 22 years. While the work has involved a "cast of thousands", and dozens of consultative meetings, the final document is the work of a small dedicated staff within OP.

Two of OP's biggest problems have been to adopt almost in tact, one completely separate effort concerning Affordable Housing, and another completely separate DC 30-year transportation plan based on a completely separate DC transportation "vision", and yet another separate tightly constrained WMATA plan for MetroRail and MetroBus.. To further complicate matters, there is by law a separate planning effort for the Federal side of the District, and a new National Capital Region Comprehensive Plan was also produced in 2004. None of the efforts share the same basic growth projections or objectives for the region or the city.

The result is a hodgepodge of different paraders, all proudly strutting their stuff to separate drummers. NARPAC has devoted hundreds, if not thousands, of hours commenting on all these separate efforts for the same reasons, and with the same near-total lack of success. This section presents our formal "testimony" concerning the next-to-final draft of DC's Comprehensive Plan. It includes allusions to other informal NARPAC comments, but we have no intention of formalizing all of them for this record.

NARPAC has concluded that many of the elements of these plans can be changed and re-directed at will with few consequences. The major exception is the ability to provide a sufficiently robust transportation infrastructure after the city has been more fully built up. If our nation's capital city continues to put the cart before the horse (and extraordinarily apt metaphor in this instance) with regard to future transportation needs, it may well create an insoluble problem for future generations.


We begin with our written testimony on the draft plan;

then present NARPAC's own preferred list of "guiding principles" ;

and offer our own version of DC's real emerging transportation infrastructure needs; and

then present our testimony to the DC Council's Committee of the Whole" , urging them not to sign off on this bland document, but give their successors a chance to improve it

(the 3-minute verbal version is included as NARPAC's June '06 Editorial)
(secondary elaboration is included in [smaller type])

NARPAC welcomes this opportunity to offer its opinions on DC's new draft comprehensive plan, as well as on those who have toiled to prepare it.

We have the utmost respect for the small but very dedicated OP staff who put together this very attractive draft and slogged through hundreds of our comments: specific, platitudinous, and snide. But NARPAC's basic focus is on four broad questions: issues not raised at any of the advisory group meetings we observed; and not included among the plan's 36 "Guiding Principles". (NARPAC's guiding principles are attached)

We are far from satisfied . To us, this plan does not adequately stress...

1. ...DC's unique urban role as the capital city of the world's greatest nation;
2. ...DC's essential role as the core city of the world's premier metro area;
3. ...DC's permanent role symbolizing the vitality of the American Dream; or
4. ...factual data, comparative forecasts, or the geographic context to support the plan.

In fact, the CompPlan seems determined to stave off the future rather than embrace and shape it. The Cropp/Williams Era clearly has no L'Enfants, or MacMillans.


[Our inputs have brought a few word changes, some paragraph insertions, even a new chapter. We appreciate being heard, even though the inconsistencies between the edits and the original intent still shine through. We are particularly disappointed that the draft contains virtually no maps of the near-metro area for which DC supposedly serves as the hub.]

[But OP has labored under constraints and an advisory group which assured they would compile a record litany of local neighborhood and agency special interests. They seem to have been limited by mostly populist advice "from above", and by fragmentation of the effort among several co-equal bureaucratic advocacy groups.]


We disagree with the excessive, homey, neighborhood emphasis. The nation's capital city must be a great deal more than the totality of its 130-odd neighborhoods. (We'd settle for 30.) Way beyond "diversity" and "inclusivity", the US capital needs prestige, urbanity, intellectual sophistication; international flavor; top-notch shopping, business, entertainment; and a first-class modern infrastructure. And DC's financial future surely isn't crippled by some "structural imbalance" imposed by the Feds or Congress.

We believe DC's real and perceived shortfalls can be solved by strong DC leadership and hard-nosed planning, particularly if that planning focuses on a unified physical infrastructure and shared roles between the city and its contiguous region. In most long-lead time areas, only DC's city government can lay the right plans, and in some of those, only with the positive support of both the region and the Federal Government.


[NARPAC will not press for one more cultural center, one more permanent reminder of the past, one more park or tree, or one more local neighborhood convenience store. We don't think DC should be the region's poor house; maintain a huge stock of outdated housing or surplus run-down schools; or match suburban family demographics.]

[Obviously, the importance of the plan varies by planning element. Planners and local activists can't really stop the region's economic growth, although they may limit the city's share of it. They cannot really force future residents to live in unattractive or unsafe places, put their kids in second-rate schools, work in places they can't conveniently get to, or give up their most beloved possessions, their cars. Planners may try to shape the behavior of those who live in, commute to, or visit their cities, but they surely can't force on them an unwanted lifestyle.]

[Planning aspects also have very different lead times. In no way does this plan indicate it is just the next twenty years of a continuing evolution with no end in sight. In some areas, policies can be changed and new directions established in months. For instance, the dictum in the current draft that "as many as possible of all DC's current row houses should be saved (forever?)" only assures that there will be plenty of room for higher residential densities if and when needed in the future. On the other hand, a dictum that says Metrorail should never be expanded, or that DC building height limits should never be relaxed beyond DC's barely visible "topographic bowl", are likely to impact on the capital city's long-term ability to keep pace with regional modernization.]


Our strongest concerns are embodied in the Transportation Element. It gives no indication of being a long lead-time, developmental precursor, infrastructure element. NARPAC has objected to its small resort town mentality since DDoT's inception. (NARPAC's general idea of long-range transportation infrastructure needs are attached).

You will have to probe the draft's fine print to find that by 2025, DC will be virtually paralyzed by traffic. By then, the superficial fixes (whatever they may be, but no doubt including street- clogging trolley tracks and bike lanes) will have been exhausted. The back-up material does not explain how much more mobility will be needed, how it is achieved, who will use it, or why it will be mainly available outside of rush hours.


[DDoT has always given off vibes of trying to retreat from DC's already marginal traffic status quo, while focusing on social engineering, urban decoration, and recreational mobility, justified by obscure consultant analyses. We disagree with all DDoT's basic tenets (as we interpret them below). They virtually assure that NARPAC's four criteria cannot be met:

o DC is an independent island-nation with no regional/metro area needs or obligations;
o DC should emphasize local neighborhood needs, discourage suburban commuters;
o DC's road network is being worn out by free-loading federal, suburban interlopers;
o DC can easily attract more middle-class residents to fill all the city's jobs, reduce city traffic;
o Metrorail has reached saturation, can't be changed, shouldn't bring in more outsiders;
o DC's road structure can't be changed from its 200-yr-old animal-powered transportation plan;
o Regional transportation inadequacies do not impact on national image or local economics;
o Plan only marginal, one-time "fixes" that leave no further growth 20 years hence;
o Don't use transportation investment to lead/guide economic development outside downtown;
o Don't implement transit-oriented development in the face of vociferous local NIMBYs;
o Avoid consideration of major new technologies such as RFIDs, segways, robotic parking;
o Bring trolleys back as a means to amuse locals and tourists, while discouraging commuters;
o Take already-clogged major arterials, and add bikers, trolleys, trucks, strolling paths, trees;
o Intermingle all traffic on major arterials in the same ground plane, and add more traffic lights;
o Focus DDoT on increasing sidewalk vitality/vibrance on heavily trafficked surface routes;
o Restrict through traffic at 23 (count 'em: 23) impressive ceremonial gateways;
o Ignore parking facilities as a major source of city revenues, supply& demand management;
o Ignore the need to maintain traffic flow in the face of local demonstrations, major traumas;
o Provide pseudo-detailed traffic improvement analyses but omit assumptions, major fixes;]

[Mayor Williams and other city leaders bought into a phony GAO report about DC's "structural imbalance" even when the errors and fallacious assumptions were included in the report's back-up material. It is still accepted as gospel in this CompPlan four years later. Their chances of finding the happy talk in this transportation back-up report are nil. This plan leaves our national capital at risk of self-strangulation.]


The mayor needs to realize that several of his major ongoing economic development projects are proceeding without the fundamental first-class transportation infrastructure upgrades that should undergird them. These include: 1) his hallmark Anacostia Riverfront Initiative, including the baseball stadium and the Southwest Riverfront; 2) the growing outward expansion of "Central Washington" to include its four surrounding DC "area elements", plus Arlington and Alexandria; and 3) his efforts to relieve the nationally-embarrassing squalor East of the Anacostia.

The failure to plan for substantial additional Metrorail -- and arterial -- infrastructure in these areas also assures that our national capital city's evacuation capabilities will remain embarrassingly inadequate (they are virtually untreated in the CompPlan). For the indefinite future, DC's Official Bird should be the Sitting Duck.

We strongly recommend that this tidy, parochial, but certainly not comprehensive, plan be finished up and then, together with the DC Council, the mayor create a real legacy:

Commission a broad-based 50-Year Infrastructure Expansion Study for the Inner National Capital Metro Area, using national and/or international urban experts that can focus beyond the nearest neighborhood and special interest.


[This opaque background analysis offers three elements, none of which can be corroborated or dissected into its component elements. First it asserts that DDoT's and WMATA's plans over the next 20 years will facilitate the "supply" of mobility by several percent, but it does not say how, nor does it admit that the present Metrorail will have over-saturated its existing infrastructure before then. Second, it asserts it will increase the efficiency of the existing surface transportation by a smaller amount, but it does not say how. Third, it says these fixes will be just about enough to keep the city's traffic problems as bad as they are now. Only in the back- up material does it admit that these unidentified fixes will keep 20 of DC's 50 major arterials "at capacity", and 20 more "over capacity" (defining neither term).]

[We 'guestimate' that DC should add, on average, one Metrorail station and one mile of underground or elevated track, and five new lane-miles of principal arteries every year. (see ahead)]
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(Not ranked by importance)

o DC has a unique and demanding role as the nation's capital city under constant global scrutiny
o DC should remain the unchallenged center of the national capital metro area, and grow with it
o DC is just as interested in assuring a stellar future as preserving its true historic past
o DC must continue to grow in both resident and daytime populations far beyond the next 20 yrs
o DC must morph into the urban core of its metro area and expect increasing density indefinitely
o DC must work with the federal government to make scarce land more productive for both
o factual data and transparent analyses should reinforce and illuminate planning objectives
o DC cannot afford to extend the historic limits of the topographic bowl to the rest of the city
o phony historic preservation designations to avoid change should be denied, old ones reversed
o Congressional (and DC) building height limits should be relaxed near DC's borders/'edge cities'
o the plan should set a range of quantitative growth goals for 2025, continuing trends thereafter
o the areas in DC capable of the most growth over the next 50 years lie East of the Anacostia
o the plan must positively encourage preferred growth, not just discourage unwanted growth
o it should plan for the future at the 30 neighborhood-cluster level, not 130 separate communities
o the city will benefit financially more from commercial business growth than residential growth
o there is little value in expanding affordable housing for demonstrably unaffordable households
o urban household demographics and lifestyles continue to evolve, changing housing demands
o a key objective in city planning is to alleviate the causes of poverty, not to perpetuate them
o urban plans must belly up to mitigating urban realities: crime; homelessness; blight; ghettos, etc
o the city need not hide the essential infrastructure elements of its service functions: flaunt 'em
o embracing commuters, visitors, and tourists is just as important as satisfying residents
o urban mobility planning must support city/regional objectives, not DDoT whims, like trolleys
o transportation planning must guide public, private, and commercial preferences, pay its way
o boutique transportation packages divorcing residential from regional mobility are not acceptable
o DDoT's primary role is improving urban mobility, not scenic boulevards or streetscapes
o urban mobility must embrace new technologies for traffic control, curb use, deliveries, etc.
o cars are a permanent part of US lifestyle: DC can make money accommodating/regulating them
o rising urban density will eventually require separation of pedestrian, vehicular, goods flow
o federal funding must be sought for major world-class infrastructure projects, incl. Metrorail
o the new class of threats to the national capital requires creative federal/municipal cooperation


New DC "Vision" Document (9/04)
Metro's Long Range Plan (2/03)
NARPAC's "Vision" for Metro (11/04)
100,000 New DC Residents? (6/03)
DC's "Structural Imbalance"? (11/03)
GAO "Structural Imbalance" Study (8/03)


Surely, the current growth in the national capital region is not a temporary phenomenon. The US will continue to thrive and grow indefinitely. The majority of Americans will continue to live in "metropolitan areas", and none will be more important than the only one hosting our national capital. The capital city must grow with the region, if only to remain economically competitive with the states that surround it. Obviously, the city must grow prudently, but as urban densities necessarily increase, the demands for mobility will also necessarily rise, but become much more difficult to satisfy. It would be foolhardy to believe that planning for enhanced mobility should stop now, particularly when commercial, residential, and government growth have already gotten well ahead of the city's ability to absorb them. Clearly, mobility infrastructure will not be more easily added when the development of additional rights of way either above, on, or below the city's surface have been further pre-empted by the very stakeholders that need that mobility.

NARPAC is in no position to recommend specific 20 year programs, but it can surely indicate order of magnitude needs for the next twenty years, based on prior analyses recorded on our web site. These are outlined below and supported by the graphics that follow.

Vehicular mobility:

DC's overall street/highway network is pretty well established, and overly protected by activists bent on protecting a 200+ year old plan laid out before the internal combustion engine was invented. DC maintains almost exactly 1000 miles of lesser roads ("minor arterials", "collectors", and "local roads" in DDoT parlance). NARPAC guesses that perhaps 40% of those lane-miles of public rights of way are devoted to parking private vehicles, and that their productivity can be improved by hard-nosed parking restrictions, not additional lanes.

DC also has just under 150 miles of "principal arterials", "freeways", and "expressways" carrying the bulk of commuters and commercial traffic into and out of the city. DDoT seems to think most of these "avenues" should be converted back into some sort of romantic boulevards. NARPAC believes they should be optimized as "bulk-traffic routes". And clearly, these city routes must be linked to extant regional (and generally higher capacity) routes serving the rest of the region.

Figure 1 shows the outline of this route structure and highlights in blue some 30 miles of major roadways that are at or over rush-hour capacity. Over the next 20 years, half of these roads could get four additional moving-vehicle lanes and half, two additional lanes, for a total of 100 "lane- miles" of new construction (widening, double-decking, grade-separation, whatever). For broad planning purposes, that equates to 5 lane-miles per year indefinitely. This is sufficient for long- range planning purposes, and can be converted into actual projects by appropriate experts.

Public Transit:

DDoT proposes to focus on fixed-guide way trolleys (much less versatile than a new generation of buses), and bicycles (why not all kinds of personal transport systems from wheelchairs to the new "segways"?) on already saturated DC streets. NARPAC is convinced that neither marginal system could be as productive as adding world-class Metrorail above or below the city's increasingly crowded ground plane. The existing regional system has grown in use faster than expected. Within the next decade or so, it is in serious danger of becoming "saturated" during the ever-lengthening rush hours. DDoT plans no further Mterorial infrastructure upgrades, while NARPAC suggests steady infrastructure expansion to solve five obvious problems:

The original (early '70s) "hub-and-spoke" design has turned out, 40 years later, to have been shortsighted. All radial lines lead through downtown with four consequences: 1) the three downtown stations through which 3-4 of all eight lines must pass are becoming clogged, with no simple means of expansion; 2) perhaps fortuitously, downtown itself is almost "built-out"(given the city's idiosyncratic determination to keep building heights well below those of its suburbs) and is now spreading into adjacent areas not well served by Metrorail; 3) there is no "inner circle line" (Such as in London) which allows passengers to shift from one radial to another without going through downtown; and 4) in a new age of real (and imagined) urban threats of violence by terrorists and/or paralysis by demonstrators, the system's usefulness for evacuation during a crisis is seriously jeopardized by those three downtown bottleneck stations.

Moreover, the existence of a metro station near a certain area does not guarantee its utility. The best current case of this is the "Navy Yard" Metrorail station which is not really within convenient walking distance of the Navy Yard, but is relatively near the new baseball stadium. Unlike the Stadium/Armory station, however, it was not designed to handle peak crowds and will eventually require expansion. Furthermore, it is on the less versatile Green Line which means that the great majority of baseball fans will have to pass through downtown, and change trains, to get there.

Arguably, Metrorail has been the greatest single precursor for economic growth in the region. The rebirth of Arlington and Alexandria are tributes to successful transit-oriented development. DC's new "infill station" at New York Avenue is transforming the economic productivity of the previously-depressed blocks immediately around it. But the 30% of DC's land area which is all economically depressed has practically no regional access by Metrorail, and none planned for the future. Instead, DDoT's 20-year transportation plan includes adding a local trolley so the area's poor can move from one depressed part of Anacostia to another. It virtually insures the area East of the Anacostia will remain indefinitely a nationally- embarrassing symbol of poor urban planning.

Again in the sense of notional planning for transportation infrastructure growth, Figure 2 (above) shows a twenty year plan to add an "inner circle" Metrorail line serving the outer portions of an expanded 'downtown' area (including Arlington and Alexandria). As shown on Figure 3 (below), it is also designed to provide a large number of alternate Metrorail routes which can either regularly, or in the event if emergency, bypass the potentially-disasterous downtown bottlenecks. The plan also provides major regionally-connected additions to Metrorail East of the Anacostia, much like the Ballston and Crystal City corridors in Arlington.

Not by accident, the notional plan adds one Metrorail station and one mile of above- or below- ground trackage for each of the next 20 years, half for expanding downtown, and half for assuring the capital city's future growth East of the Anacostia. Experts can work out the details once the broad objective has been established.

return to the top of the pageTESTIMONY BEFORE THE DC COUNCIL COMMITTEE OF THE WHOLE, September 26, 2006

This Is Not a "Comprehensive Plan"
"Ward 10 Strikes Again"

NARPAC, sometimes known as "Ward 10", wants to assure Americans outside DC that this plan will hep our national capital city will grow in stature and prestige. After all, it's our capital too, and Ward 10 taxpayers pay over 21% of your bills, 11% of your city workers, and do several of your city tasks. National functions provide well over 90% of the attractions that draw people to visit, live, or work here, and probably generate 75% of the better paying jobs. We provide 85% of DC's park space, and maintain over 100 miles of its major roads.

NARPAC finds this 6-lb "plan" little more than an endless laundry-list of platitudinous "druthers" from every known special interest. Its 833 pages are almost-typo-free, beautifully illustrated, but gloss over many local and national urban issues. There are no quantifiable goals, no preferred strategies for achieving them, and no plans of action to implement the strategies. It is a glorified Book of Rules and appears to have had little or no senior guidance.

As written, we find this plan a lousy legacy for the Cropp/Williams years, and a poor guide for the next administration. With some key exceptions, what is written is harmless, but what is not written is crucial to DC's long-term future. We urge you, the City Council, to invite DC's new leaders to answer the ten questions we raise below before making it their comprehensive plan:

1. Is increased "diversity" or "inclusiveness" a proper or measurable 20-year objective? (there is no hint here of a "21st century plan": i.e., no new L'Enfant or McMillan)

o "diversity" and "inclusiveness" are virtually meaningless themes, unquantifiable terms
o just what socio-economic demographic distribution represents the norm? (DC is off- scale!)
o "guiding principles" are theological, if not socialistic, and surely do not a strategy make
o all beatitudes and no commandments: inadequate as "corporate" development plan
o no indication of needs for changes in direction versus "more of the same"

2. Should this plan be comprised mostly of endorsements, guidelines, goals or hard plans? (the plan is primarily a compendium of on-going/near-term actions)

o 81% of 376 citywide actions are "immediate", "on-going", or "short term": 4% "long- term"
o no hint that 20-year projected growth will continue indefinitely thereafter, or to what goal
o proposed transportation "upgrades" almost certainly top out well before 20 years
o no recognition of differing lead-times for underlying infrastructure expansion
o nicely assembled "from the bottom up", but apparently unchallenged "from the top down"

3. Does the Council agree DC must be an integral, participating part of a metro area? (the plan gives no socio-economic or geographic context within which DC must prosper)

o no display of past/projected economic/demographic growth even in inner metro area
o no map of metro area, its major routes, centers of population, commerce, or even poverty
o the added "framework element" needs improvement, coupling to plan objectives
o 8 of 44 goals and guidelines, mention "regional"; 2, "national capital", 1 "national role model"
o No "guidance" on how to be US national capital or hub city of outstanding metro area

4. Do you want the plan to highlight priorities and varying lead-time requirements? (there is no differentiation between primary/secondary, near-/mid-/long-term goals )

o no ranking of 36 "guiding principles", their 5 sets, or 12 citywide elements, w/152 subheadings
o only 61 (16%) citywide actions are designated "priority", 18% of those mid/long-term
o only 55 (25%) of planning area are designated "priority", 52% mid/long-term
o no suggestion of the underlying need to expand "infrastructure-first"
o no highlighting of directional changes from "business as usual"

5. What possible use is a 20-year plan that ignores requisite revenue/expenditure streams? (the plan, like the "Vision" before it, has been developed in a total financial vacuum)

o land use is dissected into 156 separate packages, accurate to a tenth of an acre, but...
o ...municipal costs and revenues from various land uses or planning areas are not estimated at all
o the ONLY key growth option dismissed out of hand as "too expensive" is Metrorail expansion
o there is no mention whatsoever of trends in, or sources of, city revenues or expenditures
o novel "planing areas" deny use of available quantitative revenue/expenditure data by Ward

6. Does the new administration have an accepted strategy for REDUCING DC poverty? (there is no cohesive strategy for DC's sole primary problem: eliminating poverty)

o there are164 policies on art, design, open space, environment, none on poverty/blight per se
o poverty mentioned twice in 36 guiding principles, never in 12 overarching goals
o plausible pop'n and (modest?) job growth postulated: NO plan to reduce households in poverty
o the one lonely reference to firms encouraging workforce upward mobility eliminated
o continued allusions to "dumbing-down" jobs to fit DC skills, rather than upping skills to fit jobs

7. Does the new administration agree on the best land uses to raise "net revenues"? (there is no stated strategy to assure economic solvency, "structural balance")

o goal of stable, assured, economic self-sufficiency in city with federal presence not addressed
o impact of federal presence, large commuter influx not assessed: baseless 'myths' perpetuated
o no reference to net revenue-productivity advantage of commercial properties
o continued socialistic policies of city providing amenities to 'under-served" neighborhoods
o no reference to stifling impact of building height limits outside "downtown", near "edge cities"

8. Have you consciously decided not to expand DC's Metrorail or road system for 20 years? (transportation planning is totally inadequate, largely unchanged in past seven years)

o big shift in "overarching goal" to add regional hub role, NO change in policy/program content
o no hint that transportation infrastructure, like other 'utilities' is key precursor to guided growth
o many gimmicky aspects persist from '97 "vision": 'signature systems' like trolleys, water taxis
o first order restraints not highlighted: NO new roads, NO new Metrorail additions, but....
o ....big project to tunnel under Anacostia, even bigger one to eliminate SE Freeway

9. Does the Council accept the primacy of its infrastructure, including transportation? (key urban infrastructure items exclude transportation, play second fiddle to urban niceties)

o half of "policies" and "actions"are qualitative judgments: rules of engagement, not war plans
o adequacy of basic urban utilities promised for all infrastructure elements except transportation
o role of city facilities underplayed in reducing, not just accommodating, poverty's consequences o too much poetry, too little hard-nosed quantitative analysis of collective costs and/or benefits
o too much emphasis on local neighborhood convenience, too little on citywide necessities

10. Does the Council acknowledge the need for objective analysis throughout government? (the city government sorely needs some quantitative analytical capabilities)

o there are imbedded references to inappropriate, inaccurate reports and trends, such as....
o ....'structural imbalance'; federal burden; middle class flight; household size, demography, etc.
o single (sensible) reference to uncertainty in demographic projections eliminated
o no evident correlation between demographic projections, urban capacity, or city's financial base
o Council, Mayor both need program analysis capabilities to bring realism to advocacy, whimsy
(this is NOT simply a budget/accounting/comptroller function viz., GAO, OMB)

Madam Chairman, this plan is a mundane compendium of near-term extensions to "business as usual". But the path to first-class urban stature is different than the path just traveled (well traveled, we would agree) from third-class to second-class. Substantial changes in direction are required to enhance DC's role as our national capital city in its third century of evolution:

o DC must honor and relish its inescapable, unique, and elite role as our nation's capital city;

o DC must grow into its pivotal regional role as the core city of the nation's capital metro area;

o DC must accept that this core city is much more than the sum of its anomalous neighborhoods;

o DC must stop pretending that it is incapable of financing its needs, with obligatory federal help;

o DC must resist "coddling" its very poor, its very rich, and its very active, all at city expense;

o DC must plan for substantial increases in density, mobility, gentrification, commercialization.

An expanded version of this listing is provided in our September editorial

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This page was updated on Sept 15, 2006



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