Home Penn Station More thoughts on a new Penn Station

More thoughts on a new Penn Station

by Benjamin Kabak

Is this Penn Station’s future or just a fanciful rendering from SHoP?

The clock is officially ticking on the effort to plan a new Penn Station. With the City Council vote earlier this year granting Madison Square Garden only a ten-year operating permit, city politicians have challenged the various stakeholders to come up with a replacement plan that can be well under way by 2023. The Municipal Arts Society and the Regional Plan Associate have come together to form the Alliance for a New Penn Station, and while they’re on the right path, I’m not sure they’ve figured out what they want for a new Penn Station and the surrounding area.

On Thursday, MAS hosted the first day of its Summit for New York City, and this year’s sessions focus nearly exclusively around Penn Station. The speakers spent the day discussing the need for a new Penn Station and a redeveloped Midtown, and each of the architectural firms that unveiled their renderings earlier this year will discuss their plans in depth. It’s a veritable lovefest, but without commitments from Amtrak, NJ Transit, the MTA or MSG, none of this will come to pass.

The trouble with the messaging began early in the day. “Penn Station should be a city within a city,” Charles Renfro, a partner with Diller Scofidio + Renfro, said. He called it “a double destination.” From the get-go, I am skeptical. I do not expect train stations to be utilitarian and dingy as the current Penn Station is, and New York City should embrace the chance to improve upon what we have in place. But a train station is designed to be a gateway to a city, not a destination unto itself. It gets travelers to their destinations efficiently and easily.

On the East Side, Grand Central is unique in what it has meant to the city’s history and in the way its incidental spaces have been used to create a commercial destination. Do we need an inorganic, overbuilt mall atop a train station or a building that accommodates passenger flow and quick travel with the right mix of amenities? A combination of Philadelphia’s 30th St. Station and the Grand Central Terminal would be just fine, and it doesn’t require MAS, the RPA or a bunch of architects to reinvent the wheel due to New York exceptionalism.

Meanwhile, in its presentation and a new Penn 2023 policy document, the Alliance discusses its overall vision for the neighborhood. Penn Station is to be the catalyst for the revitalization of that area of Midtown. The current train station, they say, “stifles growth and limits economic opportunity in the area” because it is at capacity. But the train statin itself needn’t be a required part of a plan to spur development in Midtown.

It’s true that Penn Station’s limitations — both structurally and, equally importantly, operationally — impact capacity. A new station would solve that problem but so would through-running at a much lower initial cost. Meanwhile, to spur on growth outside of Penn Station, fix the zoning regulations. A plan to upzone the area similar to the effort underway for Midtown East and an elimination of the Special Garment Center District would be all the catalysts the area needs. A new train station could be a part of a redevelopment plan, but it’s not the necessary centerpiece.

So what’s the right approach? While I’ve been skeptical of the MSA and RPA approach over the last year, their Penn 2023 does contain the germs of the right plan. Although they prioritize a worldclass neighborhood first, their vision includes relocated MSG, completing Moynihan Station, pushing through on the Gateway and Penn South plans and rebuilding Penn Station. That’s a significant increase in transit capacity for the area, and the only thing holding back this project is money. They’ve proposed creating a Penn Station Redevelopment and Revenue Capture District, but that would fund only so much of the plan. Plus, we haven’t even looked inside the Pandora’s Box that is the MSG relocation problem.

These aren’t easy issues to grapple with, but now is the time to figure this out. As the MAS report says, this opportunity won’t knock again. “The longer we wait,” Penn 2023 reads, “the more congested the station will become, making it more difficult to make improvements.”

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David Brown October 18, 2013 - 6:53 am

I really do not care for “Artsy Types” like MAS, and the reasons are a lack of practicality, and NO comprehension of costs. That said, when it comes to practicality, it does not exist when it comes to such projects (see the PATH Station). The pretty pathetic thing is I hear a lot of stuff about “Two New York’s”, but that is essentially what the New Mayor is favoring for New York when it comes to Transportation…. such as spending TEN Billion Dollars (or more)on a New Penn Station (I am not even bringing in MSG), but if you are in the Outer Boroughs, lip service (sounds like the SAME THING he complains about Bloomberg doing). Sort of like “Meet The New Boss Same As The Old Boss” from “Won’t Get Fooled Again” by The Who. Onto the Transportation Part, if you are going to go play poker and go “All In”, what about some kind of a connection, from the (D) & (B) to the 7th Ave Line (specifically the (2) & (3) since there isn’t one in Manhattan (Because of Times Square the (N), (Q) & (R)connecting really isn’t that important)? Also while doing that, push for more transit options for the West Side, because with Hudson Yards, there will be a need for it. But those do not look like “Works Of Art”, so instead, they favor pushing the recreation of the Original Penn Station (have to make sure it passes muster at Landmarks). Sad to say, like the “Bullet Train” in California, once they start construction (unless the money runs out), this “Train” will be hard to stop, no matter the costs.

johndmuller October 18, 2013 - 8:30 am

Converting the IRT Columbus Circle stop to be also express stop is apparently the project for you. Supposedly it has been scoped out in a previous era and to some extent engineered already.

David Brown October 18, 2013 - 9:27 am

Johndmuller, of course, that would have been a good fallback option, but when the MTA redid Columbus Circle, and did not include it, essentially they let that “Train leave the Station.” What is needed in this case, is for someone in Power to come up with a transportation alternative that is viable and affordable when compared to MAS. Basically sounding like (or being) a NIMBY is not good enough. A lesson for that is the Two Trees/Domino Sugar Redevelopment Plan: The Developers did not like the Original Redevelopment Plan, so they put everything on the line by going through the ULURP again. Meanwhile, the opponents idea was yelling and complaining, and saying no, and their final idea involved planning to build an Art Museum with no funding for it set aside. Are the groups opposed to this correct? Perhaps, perhaps not. But, because they refused to get in the game and offer a REAL Alternative, than doing nothing, they got steamrolled in the process. If people want something better than another “Transportation Taj Majal” then fight for it, otherwise the taxpayers will be saddled with lots of debt, without the benefit of better train service.

johndmuller October 18, 2013 - 12:06 pm

I believe that the classic Rail Baron finance vehicle was Other-Peoples’-Money. Here in River City we have some of the world’s foremost experts in Other-Peoples’-Money. Perhaps something like this:

Step 1: Consulting with some of the world’s foremost experts, found the “Glorious Gateway Tunnel and Stupendous Railway Station” corporation.

Step 2: IPO; Sell plenty of stock. Waving around agreements with the “Four Largest Passenger Railroads in the Country” to occupy Stupendous Station and to use Glorious Gateway Tunnel, sell plenty of bonds.

Step 3: Build as much Glorious Gateway and Stupendous Station as possible before the money runs out. (Note that real robber barons would probably pocket a sizable percentage of the OPM first.)

Step 4: Go bankrupt.

Step 5: Form the “Most Glorious Gateway … More Stupendous …” corporation and repeat Steps 1-4 until building is finished and a viable operation remains.

Thank the world’s foremost experts and attend the ribbon cutting.

Nathanael October 21, 2013 - 3:00 am

This method, which I call “bankruptcy financing” or “sucker financing”, was used by Thatcher to build the Channel Tunnel.

Gary Reilly October 18, 2013 - 8:56 am

I don’t believe that to be accurate.


Gary Reilly October 18, 2013 - 8:57 am

Clarification: My 8:56 reply was to David Brown.

David Brown October 18, 2013 - 12:05 pm

Gary Reilly if you actually read De Blasio’s part on Transportation you will see nothing on Brooklyn or Queens except the ( G) Train. Stuff like reactivation of the LIRR Tracks for Woodhaven, a new Elmhurst LIRR Station, a free transfer between the ( L) and (3) at Livonia Ave, and the ( G) and the ( J) & (M) at Broadway, the ( F) Express and a rebuild of the Bergen Street Station ( each and every one of these things mentioned in this Blog), are nowhere to be found. In fact, the single biggest outlay of transportation money is related to Penn Station, and where is that located? In fact, I bet you could come close to doing all of these things for the price of that Station. As I said “Meet The New a Boss, Same As a The Old Boss.”

Bolwerk October 18, 2013 - 3:43 pm

De Blasio seems to have a three-prong caste system in mind for transportation: (1) VIPs, suburbanites, and politicians get cars, (2) people who already have trains can keep them, probably at ever greater costs, and (3) bus “rapid transit” is the consolation prize for a few people who don’t even have that.

Bolwerk October 18, 2013 - 3:27 pm

There is nothing especially wrong with paying attention to aesthetics. The type of soul-destroying urban landscape rape the modernists inflicted should be avoided just as much as the prices of Calatrava’s monstrosties.

It’s just that aesthetic appeal shouldn’t cost much, maybe a few percent of the cost of a the project over not having it. And it’s not just aesthetics driving overpricing; it’s over-engineering and rent seeking as well.

David Brown October 18, 2013 - 8:03 pm

Bolwerk, we are actually in agreement, on both of your points (this bumps the grand total up to three). Most people do not want to live in an area that reminds someone of North Korea, artistically as well as economically. A big problem is not enough people seem to get that. Republicans are just as guilty as Democrats (check out Mitch McConnell’s Olmsedt Lock and Dam Project, this transportation project makes the PATH Station seem economical (as well as its continuing funding being the very item that caused a budget agreement), as well as guys like De Blasio and their 3 pronged caste system.

Larry Littleield October 18, 2013 - 7:52 am

What their plans DO NOT include is who will become worse off in what way to pay for all of this.

3ddi3 B October 18, 2013 - 8:23 am

NYC needs a new Penn Station, but I do agree with David Brown, that the pretty parts of this project will probably get the most money out of this.
Sadly, the subway’s system funding is clearly inadequate, we get money from the feds to build a brand new $6bn Path station that, for the money spent, doesn’t address the problems underneath.
We need a world class station to connect to a world class city.
The funding needs to start coming, what can be done for the MTA to get more funding? We first, need a Governor that is committed to transit, and sadly, Cuomo is not the guy.

John-2 October 18, 2013 - 9:06 am

The reason why the original Penn Station isn’t there today is the value added realization of the current site — that is nothing above the concourse at the original Penn was making any money, as spectacular as it was to look at. That’s why MSG and 2 Penn Plaza are there now, because they added value to the site that wasn’t there before for a company that was going bankrupt.

Even with the city and feds being the lead agencies now instead of the Pennsylvania Railroad, that’s the situation the designers of whatever comes next are going to have to consider. Art or engineering design simply for the visual aesthetics are fine, but as the Calatrava PATH station shows, that’s a lot of taxpayer money just to wow people. Designing a new Penn Station that will wow people and become a destination unto itself is all well and good, but eventually the wow factor evaporates, and the station has to justify its costs based on its functionality.

If you rezone the area and create some sort of transportation district that can fund the cost of the new shiny-looking bauble based on the value added to the area over the current assessments, you might be able to recoup some of the expenditure for the new station. But if you throw MSG and the office space off the site, and expect the lost revenues there to be made up by a Shake Shack on the new concourse level, odds are that’s not going to fly very well.

Shabazz October 18, 2013 - 10:45 pm

You seem to be confusing the notion of “value” with “money making.”

The point of taxpayer dollars is to fund things that are beneficial to public, but may not necessarily turn a profit, that’s why we pool our money together in the first place, that’s the point of government!

The notion that a grand Penn station won’t be a net value add is absurd. Sure, there should be some retail (similar to Grand Central) but the point the project shouldn’t be to create revenue from the station itself, it’s effects on capacity, property values around the area, and the user experience, all things that can be quantified (if you wish) easily justify the expenditure.

John-2 October 21, 2013 - 12:26 am

But how much net value can be added if the problem addressed by a new Penn focuses on the volume of passengers that can be brought into the city through the station, versus focusing more on how it looks and not really caring about improving the Hudson River access or the century-old track layout and narrow platforms of the station?

Bump up the volume of passengers and you’re going to add value to the Penn Station area anyway. But if the designers focus 99 percent of their concerns on everything from the waiting area up instead of caring about the platform level, odds are you’ll get a Penn that adds value when new, but once the station’s ‘ooh-ahh’ factor wears off, isn’t going to fulfill it’s main purpose or help the area as much as it should have.

lawhawk October 18, 2013 - 9:26 am

This may not be directly on point, but it’s something that’s been bugging me as I watch the PATH transit hub going up (and costing $4 billion for a project that adds no capacity to a mass transit system) or the nearby Fulton Center.

What is the projected life on these new structures? We’re spending $4 billion on PATH, and $2 billion on Fulton, but how long before these structures show their age and don’t age so gracefully.

Can we expect to see them age as gracefully as Grand Central, which has survived the test of time? Or, are they likely to need refitting or rebuilding far too quickly. Does this enter into the equation?

And would this also affect the potential new Penn Station? The need to produce a dazzling entry point seems to have taken precedence over functionality – when the new station proposal doesn’t seem to remedy the ongoing issues with capacity that include lack of through-trains that could vastly improve the congestion and increase the number of trains that pass through with customers.

Upzoning around MSG doesn’t solve this, but it could produce the financial resources needed to tackle any kind of improvement at Penn, whether it’s a real improvement to the station, or the cosmetic and vastly more expensive building of a new station.

Brandon October 18, 2013 - 9:42 am

The MAS snobs want the old Penn back, and maybe, with enough money thrown at it, theyll almost get it. It would really be a tremendous waste though when there are so many potential projects out there that actually improve transit capacity or building new lines.

In reality, the Garden doesnt have to move to get a comfortable, spacious, single-concourse Penn Station.

The Theater at Madison Square Garden has to move and the back offices at concourse level have to go, and the three railroads (two of which are part of the MTA) need to learn to share a concourse, and we can have a great Penn Station with MSG on top.

Craig October 18, 2013 - 10:42 am

“The Theater at Madison Square Garden has to move and the back offices at concourse level have to go, and the three railroads (two of which are part of the MTA) need to learn to share a concourse, and we can have a great Penn Station with MSG on top.”

This is the part of the ongoing Penn Station saga that I have the hardest time understanding. We could have a pretty good Penn Station in a relatively short time at a relatively low cost if the railroads could work together.

What does it say that it’s easier for the city to take on MSG and the Dolans and their money and lawyers and lobbyists to move MSG than for Amtrak, NJ Transit, and the MTA to work together?

Nathanael October 21, 2013 - 2:58 am

It’s LIRR who is really hard to work with, by reputation. Amtrak and NJT seem to cooperate quite a lot, and Amtrak and Metro-North… do OK. And Metro-North and NJT have been cooperating too, with special trains.

LIRR doesn’t play nice with anyone. Frankly, if the administrative attitude at LIRR can’t be resolved, I say kick ’em out of Penn and make them send all their trains to their new uncooperative cavern at Grand Central.

johndmuller October 18, 2013 - 10:08 am

Well we just wasted enough money on political posturing in DC to pay for a fancy architectural statement a half a dozen times over. Personally, I’d prefer the train station/monument to the bickering/dysfunction.

Regarding the state of the current railroad operations, I thought that the consensus no longer necessarily supported thru-running as the prescription (at least for the present) for the perceived problems. Thru-running is apparently largely going on already (albeit to the storage yards) and the incoming trains are said to be clearing the track in a matter of only a few minutes. Track congestion may not be so much of a problem in the station (perhaps in the tunnels?). NJT and LIRR are presumably running a few off-peak-direction trains and one could perhaps pair them up and they could swap crews and do the 2nd leg of each other’s trips. What do you get out of this though, besides sending the equipment to strange places? Chances are, hardly any of the passengers who want to go between NJ and LI wand to go to wherever their particular train is going to go to on the other side, so they will need to transfer anyway. That’s not even to mention the electrical incompatibilities, crew issues, and inter-railroad negotiations.

If you want to have thru-running, may I suggest MN operating a run between Stamford and Croton (or between New Haven and Poughkeepsie) using dual mode diesels fitted out with overrunning 3rd rail pickups (like Amtrak uses on the Empire Corridor). Not that I think there are a lot of customers for going around the horn, but there is pent up demand for getting to Penn station from MN territory, just as getting to GCT from LIRR territory.

Personally, I don’t think it’s wrong to spring for some civic architecture from time to time. I don’t know that this is the time and place, especially coming so close on the heels of the PATH extravaganza – not to mention how we might feel about throwing more money at the Dolans to build a new Cablevision Arena. Even so, I could think of worse infrastructure projects – like rebuilding the Tappan Zee Bridge without rail (who wants to bet on whether or not the supposed transit ready features become express lanes for more cars instead?).

JMB October 18, 2013 - 10:32 am

The new Tap will be such a let down without rail. Connecting the west of hudson raillines to Manhattan via a new bridge would do wonders for those who have to deal with that miserable commute and surely their property values would increase as well. I wonder if its at all possible to keep the existing Tap and retrofit it for rail access. The grades seem rather gentle enough to allow locomotives, just curious if the bridge could handle it and whether the existing tracks could be connected to it.

johndmuller October 18, 2013 - 2:02 pm

I believe that the last plan to connect the Hudson Line was to have a big loop in a cut and cover tunnel connecting somewhere north of Irvington, although I think that one could bring it up gradually onto a trestle above the ROW to a decent height with only a moderate amount of view desecration before curving over the bridge and finishing the climb. The main span, which is unfortunately fairly close to the shore is almost 150 feet up, but I think a run up of 1.5 – 2 miles could occur at less than a 2% grade, which should be doable. BTW, I don’t know whether you have driven on it or not, but in my opinion, the grade of the main span is steeper than it seems to be when looking at it from the side.

As to repurposing the bridge, the closer to being replaced it gets, the worse its structural condition turns out to have been; now they are talking about rotting wooding pilings underlying the causeway section. Also, after the first span is completed, they plan to tear it down and put the second span there. Even if they weren’t doing that, there’s still the people who want to turn it into another High Line.

JMB October 18, 2013 - 7:09 pm

Thanks for the info John, I didn’t realize the causeway section had wooden pilings.
Its good to hear that its feasible to make a track connection, I’m just wondering if sensible heads will someday prevail and build it.

AMM October 18, 2013 - 12:02 pm

IMHO, making Penn Station “a destination” is exactly the wrong approach.

Most people who arrive in Penn Station — whether on AMTRAK or one of the communter lines — are going somewhere else, not west midtown Manhattan. But the station is very poorly set up for people going between rail lines or between rail and subway, bus, or taxi — or even the street. In my experience, it seems like it’s mostly set up to encourage an arriving passenger to just turn around in frustration and head right home again.

Digression: the same is true of GCT, especially for connections between MN and the Lex. The upper concourse is beautiful, but it’s also something of a bottleneck and an obstacle course. The lower concourse is oddly enough less of a problem, because the eateries pull the loiterers out of the main traffic lanes. Just finding your way to the street is a little like playing the Mammoth Cave Adventure game.

The station needs to be redesigned to make traffic flow between the rail lines and the subways and 7th and 8th Avenues quick and turbulence-free. You shouldn’t have to hunt around for the inscruitable signs that purport to tell you how to get where you’re going. Shops and restaurants need to be away from the main traffic lanes, and ticket windows on the way to the rail lines, but also out of the traffic lanes. It would be good if the process of going from one commuter operator’s trains to another’s were less awkward. (A shuttle bus to GCT would be _really_ nice!)

AMTRAK needs all these, but also some sort of ground transportation desk, because many of their passengers are not familiar with NYC. I would also like to see rental car desks, similar to what you seen in airports, since some passengers are going to destinations in the NYC area that are not accessible by public transportation — e.g., huge chunks of the suburbs.

Penn Station — or any major station, for that matter — should not be seen as a destination, but rather as a transfer point on the way from a passenger’s origin to his/her final destination.

anon October 18, 2013 - 12:55 pm

Would a shuttle bus get there in less than 20 minutes?

SEAN` October 18, 2013 - 2:01 pm

Oy, not in a million years.

3ddi3 B October 19, 2013 - 3:19 pm

One of the reasons why Penn St is not a destination, IS because of its transit, another is its zoning, I believe between 35-40th is zoned for the Fashion industry, some people wonder whether it should be rezoned.

Nathanael October 21, 2013 - 2:53 am

“IMHO, making Penn Station “a destination” is exactly the wrong approach.”


Penn Station needs to quickly move huge numbers of people from trains to the street and the subways. It needs to quickly move large numbers of people from trains to other trains. It needs to quickly move large numbers of people from street & subway, to waiting room, to trains. It needs to separate waiting traffic into long-distance and short-distance. It needs to separate arriving Amtrak traffic with baggage from everyone else.

And it needs to do this on top of moving trains through it.

This is a complex architectural problem — a very difficult one. It has nothing whatsoever to do with being a “destination”.

Nathanael October 21, 2013 - 2:55 am

Also agreed that rental car desks would actually be really valuable; this is true of all big-city train stations.

I know it seems a bit heretical, but there should be a way to take a train to the NY metro area and then rent a car. Perhaps it might be more sensible to establish “rental car centers” at Sunnyside and at Newark, and stop all the Amtrak trains at both locations, however. Nobody really wants to drive *in Manhattan*.

mthen February 12, 2014 - 10:48 pm

Penn Station would need to be a accessible destination in my view due to the Hudson Yards Redevelopment Project but not as a fancy architectural space.

SEAN October 18, 2013 - 12:47 pm

The trouble with the messaging began early in the day. “Penn Station should be a city within a city,” Charles Renfro, a partner with Diller Scofidio + Renfro, said. He called it “a double destination.” From the get-go, I am skeptical. I do not expect train stations to be utilitarian and dingy as the current Penn Station is, and New York City should embrace the chance to improve upon what we have in place. But a train station is designed to be a gateway to a city, not a destination unto itself. It gets travelers to their destinations efficiently and easily.


I couldn’t disagree more. A propperly designed rail station can be so much more than just a place to rush to catch a train. Charles Renfro has a point when he states “a city within a city.” Union Station in DC & GCT are both great gathering spaces while Penn Station is not. However with some foward thinking, it to can be a great space as well even if it doesn’t replicate the original Penn in look & feel.

As far as MSG goes, is it nessessary to have it directly above Penn? Personally I don’t think so & Vornado owns enough land around there to put it almost anywhere.

BruceNY October 18, 2013 - 1:16 pm

At one point I thought there was discussion about moving MSG to the back of the post office (future Moynahan Sta.), but negotiations broke down. I don’t know what happened, but couldn’t that be put back on the table? With Hudson Yards being built, the location should be considered pretty desirable.

Berk32 October 18, 2013 - 2:56 pm

That was before the MSG renovation plans and before Amtrak’s plans.

That’s no longer an option

Nathanael October 21, 2013 - 2:48 am

Bleah. A “New Penn Station” has to be thought about operationally. Form follows function. These artsy people haven’t even done their research on what goes in Penn Station, making it impossible for them to even come up with a coherent suggestion.

Consider Berlin’s Hauptbahnhof, widely acknowledged as a masterpiece of train station design. It was designed around an existing elevated railway, a planned underground railway, and the other transportation elements which needed to be there. They look like they were always supposed to be part of a grand station now… but that’s due to *design*. Design which thought about every little detail of transportation *before* design started.

Ned October 21, 2013 - 10:56 pm

Respectfully, I am one of those pie-in-the-sky architects and I have to disagree with many of these posts and some of the basic premises of Ben’s first post.

Much of this seems to represent the kind of thinking that never would have given us Grand Central in 1913 in the first place, much less the renovation of that terminal in the 1990’s. ‘Why restore it? Who needs retail? It’s simply about passenger flow and subway connections! Nobody wants to visit that neighborhood anyhow. Who needs monumentality?, etc.’ It’s not a stretch to say that Grand Central is all the things that Charles Renfro was talking about when he was describing what Penn Station COULD be, and I would ask you, why should Grand Central be any exception? This is about visionary thinking. When that terminal was built, 42nd St still had stockyards, so the idea that we should limit Penn Station to its bare necessities because west midtown isn’t worth visiting right now is specious. The Calatrava Path station has the opposite problem — it’s a monument for what is already a high-profile area, and its look-at-me-ness is way out of proportion to the number of transit users it will serve.

Consider even for an instant what Hudson Yards might mean for the west midtown area, or imagine some future city push for rezoning the area (which I’m not necessarily advocating). What I actually think hurts that neighborhood is not the station or fashion industry but the arena, which produces a kind of hectic evening itinerancy when events are on. I’m still not convinced: why can’t we move the stadium?

In 100 years, will we care why a lacklustre mid-century arena stood in the way — for so long — of building a robust and vibrant transportation hub that would be the heart of west midtown’s renewal and paid for itself many times over, as Grand Central has done (and re-done with the ’90’s restoration)?

I fully acknowledge that the main difference between 1913 and today is that Grand Central (and Penn Station) were grandiose, monumental manifestations of private, corporate interests and were their own kind of experience branding. Today, the public foots the bill, and we expect some restraint. But in New York, the land of insane real estate and a million public-private partnerships, I’m sure there’s some way to get a great station, with great functionality and great architecture, out of the equation without breaking the bank. It can happen. Just as long as WTC isn’t the model.


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