History Of Cities And City Planning

By Cliff Ellis

Introduction

The building of cities has a long and complex history. Although city planning as an organized profession has existed for less than a century, all cities display various degrees of forethought and conscious design in their layout and functioning.

Early humans led a nomadic existence, relying on hunting and gathering for sustenance. Between 8,000 and 10,000 years ago, systematic cultivation of plants and the domestication of animals allowed for more permanent settlements. During the fourth millennium B.C., the requirements for the "urban revolution" were finally met: the production of a surplus of storable food, a system of writing, a more complex social organization, and technological advances such as the plough, potter's wheel, loom, and metallurgy.

Cities exist for many reasons, and the diversity of urban forms can be traced to the complex functions that cities perform. Cities serve as centers of storage, trade, and manufacture. The agricultural surplus from the surrounding countryside is processed and distributed in cities. Cities also grew up around marketplaces, where goods from distant places could be exchanged for local products. Throughout history, cities have been founded at the intersections of transportation routes, or at points where goods must shift from one mode of transportation to another, as at river and ocean ports.

Religious elements have been crucial throughout urban history. Ancient peoples had sacred places, often associated with cemeteries or shrines, around which cities grew. Ancient cities usually had large temple precincts with monumental religious buildings. Many medieval cities were built near monasteries and cathedrals.

Cities often provide protection in a precarious world. During attacks, the rural populace could flee behind city walls, where defence forces assembled to repel the enemy. The wall served this purpose for millennia, until the invention of heavy artillery rendered walls useless in warfare. With the advent of modern aerial warfare, cities have become prime targets for destruction rather than safe havens.

Cities serve as centers of government. In particular, the emergence of the great nation-states of Europe between 1400 and 1800 led to the creation of new capital cities or the investing of existing cities with expanded governmental functions.

Washington, D.C., for example, displays the monumental buildings, radial street pattern, and large public spaces typical of capital cities.

Cities, with their concentration of talent, mixture of peoples, and economic surplus, have provided a fertile ground for the evolution of human culture: the arts, scientific research, and technical innovation. They serve as centers of communication, where new ideas and information are spread to the surrounding territory and to foreign lands.

Constraints on City Form

Cities are physical artifacts inserted into a preexisting natural world, and natural constraints must be respected if a settlement is to survive and prosper. Cities must conform to the landscape in which they are located, although technologies have gradually been developed to reorganize the land to suit human purposes. Moderately sloping land provides the best urban site, but spectacular effects have been achieved on hilly sites such as San Francisco, Rio de Janeiro, and Athens.

Climate influences city form. For example, streets have been aligned to take advantage of cooling breezes, and arcades designed to shield pedestrians from sun and rain. The architecture of individual buildings often reflects adaptations to temperature, rainfall, snow, wind and other climatic characteristics.

Cities must have a healthy water supply, and locations along rivers and streams, or near underground watercourses, have always been favored. Many large modern cities have outgrown their local water supplies and rely upon distant water sources diverted by elaborate systems of pipes and canals.

City location and internal structure have been profoundly influenced by natural transportation routes. Cities have often been sited near natural harbors, on navigable rivers, or along land routes determined by regional topography.

Finally, cities have had to survive periodic natural disasters such as earthquakes, hurricanes, tornados, and floods. The San Francisco earthquake of 1906 demonstrated how natural forces can undo decades of human labor in a very short time.

Elements of Urban Structure

City planners must weave a complex, ever-changing array of elements into a working whole: that is the perennial challenge of city planning. The physical elements of the city can be divided into three categories: networks, buildings, and open spaces. Many alternative arrangements of these components have been tried throughout history, but no ideal city form has ever been agreed upon. Lively debates about the best way to arrange urban anatomies continue to rage, and show no signs of abating.

Networks

Every modern city contains an amazing array of pathways to carry flows of people, goods, water, energy, and information. Transportation networks are the largest and most visible of these. Ancient cities relied on streets, most of them quite narrow by modern standards, to carry foot traffic and carts. The modern city contains a complex hierarchy of transportation channels, ranging from ten-lane freeways to sidewalks. In the United States, the bulk of trips are carried by the private automobile, with mass transit a distant second. American cities display the low-density sprawl characteristic of auto-centered urban development. In contrast, many European cities have the high densities necessary to support rail transit.

Modern cities rely on complex networks of utilities. When cities were small, obtaining pure water and disposing of wastes was not a major problem, but cities with large populations and high densities require expensive public infrastructure. During the nineteenth century, rapid urban growth and industrialization caused overcrowding, pollution, and disease in urban areas. After the connection between impure water and disease was established, American and European cities began to install adequate sewer and water systems. Since the late nineteenth century, cities have also been laced with wires and conduits carrying electricity, gas, and communications signals.

Buildings

Buildings are the most visible elements of the city, the features that give each city its unique character. Residential structures occupy almost half of all urban land, with the building types ranging from scattered single-family homes to dense high-rise apartments. Commercial buildings are clustered downtown and at various subcenters, with skyscrapers packed into the central business district and low-rise structures prevailing elsewhere, although tall buildings are becoming more common in the suburbs. Industrial buildings come in many forms ranging from large factory complexes in industrial districts to small workshops.

City planners engage in a constant search for the proper arrangement of these different types of land use, paying particular attention to the compatibility of different activities, population densities, traffic generation, economic efficiency, social relationships, and the height and bulk of buildings.

Open Spaces

Open space is sometimes treated as a leftover, but it contributes greatly to the quality of urban life. "Hard" spaces such as plazas, malls, and courtyards provide settings for public activities of all kinds. "Soft" spaces such as parks, gardens, lawns, and nature preserves provide essential relief from harsh urban conditions and serve as space for recreational activities. These "amenities" increasingly influence which cities will be perceived as desirable places to live.

Evolution of Urban Form

The first true urban settlements appeared around 3,000 B.C. in ancient Mesopotamia, Egypt, and the Indus Valley. Ancient cities displayed both "organic" and "planned" types of urban form. These societies had elaborate religious, political, and military hierarchies. Precincts devoted to the activities of the elite were often highly planned and regular in form. In contrast, residential areas often grew by a slow process of accretion, producing complex, irregular patterns that we term "organic." Two typical features of the ancient city are the wall and the citadel: the wall for defense in regions periodically swept by conquering armies, and the citadel -- a large, elevated precinct within the city -- devoted to religious and state functions.

Greek cities did not follow a single pattern. Cities growing slowly from old villages often had an irregular, organic form, adapting gradually to the accidents of topography and history. Colonial cities, however, were planned prior to settlement using the grid system. The grid is easy to lay out, easy to comprehend, and divides urban land into uniform rectangular lots suitable for development.

The Romans engaged in extensive city-building activities as they consolidated their empire. Rome itself displayed the informal complexity created by centuries of organic growth, although particular temple and public districts were highly planned. In contrast, the Roman military and colonial towns were laid out in a variation of the grid. Many European cities, like London and Paris, sprang from these Roman origins.

We usually associate medieval cities with narrow winding streets converging on a market square with a cathedral and city hall. Many cities of this period display this pattern, the product of thousands of incremental additions to the urban fabric. However, new towns seeded throughout undeveloped regions of Europe were based upon the familiar grid. In either case, large encircling walls were built for defense against marauding armies; new walls enclosing more land were built as the city expanded and outgrew its former container.

During the Renaissance, architects began to systematically study the shaping of urban space, as though the city itself were a piece of architecture that could be given an aesthetically pleasing and functional order. Many of the great public spaces of Rome and other Italian cities date from this era. Parts of old cities were rebuilt to create elegant squares, long street vistas, and symmetrical building arrangements. Responding to advances in firearms during the fifteenth century, new city walls were designed with large earthworks to deflect artillery, and star-shaped points to provide defenders with sweeping lines of fire. Spanish colonial cities in the New World were built according to rules codified in the Laws of the Indies of 1573, specifying an orderly grid of streets with a central plaza, defensive wall, and uniform building style.

We associate the baroque city with the emergence of great nation-states between 1600 and 1750. Ambitious monarchs constructed new palaces, courts, and bureaucratic offices. The grand scale was sought in urban public spaces: long avenues, radial street networks, monumental squares, geometric parks and gardens. Versailles is a clear expression of this city-building model; Washington, D.C. is an example from the United States. Baroque principles of urban design were used by Baron Haussmann in his celebrated restructuring of Paris between 1853 and 1870. Haussmann carved broad new thoroughfares through the tangled web of old Parisian streets, linking major subcenters of the city with one another in a pattern which has served as a model for many other modernization plans.

Toward the latter half of the eighteenth century, particularly in America, the city as a setting for commerce assumed primacy. The buildings of the bourgeoisie expand along with their owners' prosperity: banks, office buildings, warehouses, hotels, and small factories. New towns founded during this period were conceived as commercial enterprises, and the neutral grid was the most effective means to divide land up into parcels for sale. The city became a checkerboard on which players speculated on shifting land values. No longer would religious, political, and cultural imperatives shape urban development; rather, the market would be allowed to determine the pattern of urban growth. New York, Philadelphia, and Boston around 1920 exemplify the commercial city of this era, with their bustling, mixed-use waterfront districts.

Transition to the Industrial City

Cities have changed more since the Industrial Revolution than in all the previous centuries of their existence. New York had a population of about 313,000 in 1840 but had reached 4,767,000 in 1910. Chicago exploded from 4.000 to 2,185,000 during the same period. Millions of rural dwellers no longer needed on farms flocked to the cities, where new factories churned out products for the new markets made accessible by railroads and steamships. In the United States, millions of immigrants from Europe swelled the urban populations. Increasingly, urban economies were being woven more rightly into the national and international economies.

Technological innovations poured forth, many with profound impacts on urban form. Railroad tracks were driven into the heart of the city. Internal rail transportation systems greatly expanded the radius of urban settlement: horsecars beginning in the 1830s, cable cars in the 1870s, and electric trolleys in the 1880s. In the 1880s, the first central power plants began providing electrical power to urban areas. The rapid communication provided by the telegraph and the telephone allowed formerly concentrated urban activities to disperse across a wider field.

The industrial city still focused on the city center, which contained both the central business district, defined by large office buildings, and substantial numbers of factory and warehouse structures. Both trolleys and railroad systems converged on the center of the city, which boasted the premier entertainment and shopping establishments. The working class lived in crowded districts close to the city center, near their place of employment.

Early American factories were located outside of major cities along rivers which provided water power for machinery. After steam power became widely available in the 1930s, factories could be located within the city in proximity to port facilities, rail lines, and the urban labor force. Large manufacturing zones emerged within the major northeastern and midwestern cities such as Pittsburgh, Detroit, and Cleveland. But by the late nineteenth century, factory decentralization had already begun, as manufacturers sought larger parcels of land away from the congestion of the city. Gary, Indiana, for example, was founded in 1906 on the southern shore of Lake Michigan by the United States Steel Company.

The increasing crowding, pollution, and disease in the central city produced a growing desire to escape to a healthier environment in the suburbs. The upper classes had always been able to retreat to homes in the countryside. Beginning in the 1830s, commuter railroads enabled the upper middle class to commute in to the city center. Horsecar lines were built in many cities between the 1830s and 1880s, allowing the middle class to move out from the central cities into more spacious suburbs. Finally, during the 1890s electric trolleys and elevated rapid transit lines proliferated, providing cheap urban transportation for the majority of the population.

The central business district of the city underwent a radical transformation with the development of the skyscraper between 1870 and 1900. These tall buildings were not technically feasible until the invention of the elevator and steel-frame construction methods. Skyscrapers reflect the dynamics of the real estate market; the tall building extracts the maximum economic value from a limited parcel of land. These office buildings housed the growing numbers of white-collar employees in banking, finance, management, and business services, all manifestations of the shift from an economy of small firms to one of large corporations.

The Form of the Modern City in the Age of the Automobile

The city of today may be divided into two parts:

The central business districts of American cities have become centers of information processing, finance, and administration rather than manufacturing. White-collar employees in these economic sectors commute in from the suburbs on a network of urban freeways built during the 1950s and 1960s; this "hub-and-wheel" freeway pattern can be observed on many city maps. New bridges have spanned rivers and bays, as in New York and San Francisco, linking together formerly separate cities into vast urbanized regions.

Waves of demolition and rebuilding have produced "Manhattanized" downtowns across the land. During the 1950s and 1960s, urban renewal programs cleared away large areas of the old city, releasing the land for new office buildings, convention centers, hotels, and sports complexes. Building surges have converted the downtowns of American cities into forests of tall office buildings. More recently, office functions not requiring a downtown location have been moved to huge office parks in the suburbs.

Surrounding the central business area lies a large band of old mixed-use and residential buildings which hose the urban poor. High crime, low income, deteriorating services, inadequate housing, and intractable social problems plague these neglected areas of urban America. The manufacturing jobs formerly available to inner city residents are no longer there, and resources have not been committed to replace them.

These inner city areas have been left behind by a massive migration to the suburbs, which began in the late nineteenth century but accelerated in the 1920s with the spread of the automobile. Freeway building after World War II opened up even larger areas of suburban land, which were quickly filled by people fleeing central city decline. Today, more people live in suburbs than in cities proper. Manufacturers have also moved their production facilities to suburban locations which have freeway and rail accessibility.

Indeed, we have reached a new stage of urbanization beyond the metropolis. Most major cities are no longer focused exclusively on the traditional downtown. New subcenters have arisen round the periphery, and these subcenters supply most of the daily needs of their adjacent populations. The old metropolis has become a multi-centered urban region. In turn, many of these urban regions have expanded to the point where they have coalesced into vast belts of urbanization -- what the geographer Jean Gottman termed "megalopolis." The prime example is the eastern seaboard of the United States from Boston to Washington. The planner C.A. Doxiadis has speculated that similar vast corridors of urbanization will appear throughout the world during the next century. Thus far, American planners have not had much success in imposing a rational form on this process. However, New Town and greenbelt programs in Britain and the Scandinavian countries have, to some extent, prevented formless sprawl from engulfing the countryside.

The Economics of Urban Areas

Since the 1950s, city planners have increasingly paid attention to the economics of urban areas. When many American cities experienced fiscal crises during the 1970s, urban financial management assumed even greater importance. Today, planners routinely assess the economic consequences of all major changes in the form of the city.

Several basic concepts underlie urban and regional economic analysis. First, cities cannot grow if their residents simply provide services for one another. The city must create products which can be sold to an external purchaser, bringing in money which can be reinvested in new production facilities and raw materials. This "economic base" of production for external markets is crucial. Without it, the economic engine of the city grinds to a halt.

Once the economic base is established, an elaborate internal market can evolve. This market includes the production of goods and services for businesses and residents within the city. Obviously, a large part of the city's physical plant is devoted to facilities for internal transactions: retail stores of all kinds, restaurants, local professional services, and so on.

Modern cities are increasingly engaged in competition for economic resources such as industrial plants, corporate headquarters, high-technology firms, and government facilities. Cities try to lure investment with an array of features: low tax rates, improved transportation and utility infrastructure, cheap land, and skilled labor force. Amenities such as climate, proximity to recreation, parks, elegant architecture, and cultural activities influence the location decisions of businesses and individuals. Many older cities have difficulty surviving in this new economic game. Abandoned by traditional industries, they're now trying to create a new economic base involving growth sectors such as high technology.

Today, cities no longer compete in mere regional or national markets: the market is an international one. Multinational firms close plants in Chicago or Detroit and build replacements in Asia or Latin America. Foreign products dominate whole sectors of the American consumer goods market. Huge sums of money shift around the globe in instantaneous electronic transactions. Cities must struggle for survival in a volatile environment in which the rules are always changing. This makes city planning even more challenging than before.

Modern City Planning

Modern city planning can be divided into two distinct but related types of planning. visionary city planning proposes radical changes in the form of the city, often in conjunction with sweeping changes in the social and economic order. Institutionalized city planning is lodged within the existing structures of government, and modifies urban growth processes in moderate, pragmatic ways. It is constrained by the prevailing alignment of political and economic forces within the city.

Visionary or Utopian City Planning

People have imagined ideal cities for millennia. Plato's Republic was an ideal city, although lacking in the spatial detail of later schemes. Renaissance architects designed numerous geometric cities, and ever since architects have been the chief source of imaginative urban proposals. In the twentieth century, Le Corbusier, Frank Lloyd Wright, Paolo Soleri, and dozens of other architects have designed cities on paper. Although few have been realized in pure form, they have influenced the layout of many new towns and urban redevelopment projects.

In his "Contemporary City for Three Million People" of 1922 and "Radiant City" of 1935, Le Corbusier advocated a high-density urban alternative, with skyscraper office buildings and mid-rise apartments placed within park-like open spaces. Different land uses were located in separate districts, forming a rigid geometric pattern with a sophisticated system of superhighways and rail transit.

Frank Lloyd Wright envisioned a decentralized low-density city in keeping with his distaste for large cities and belief in frontier individualism. The Broadacre City plan of 1935 is a large grid of arterials spread across the countryside, with most of the internal space devoted to single-family homes on large lots. Areas are also carefully set aside for small farms, light industry, orchards, recreation areas, and other urban facilities. A network of superhighways knits the region together, so spatially dispersed facilities are actually very close in terms of travel time. In many ways, Wright's Broadacre City resembles American suburban and exurban developments of the post-WWII period.

Many other utopian plans could be catalogued, but the point is that planners and architects have generated a complex array of urban patterns from which to draw ideas and inspiration. Most city planners, however, do not work on a blank canvas; they can only make incremental changes to an urban scene already shaped by a complicated historical process.

Institutionalized City Planning

The form of the city is determined primarily by thousands of private decisions to construct buildings, within a framework of public infrastructure and regulations administered by the city, state, and federal governments. City planning actions can have enormous impacts on land values. From the point of view of land economics, the city is an enormous playing field on which thousands of competitors struggle to capture value by constructing or trading land and buildings. The goal of city planning is to intervene in this game in order to protect widely shared public values such as health, safety, environmental quality, social equality, and aesthetics.

The roots of American city planning lie in an array of reform efforts of the late nineteenth century: the Parks movement, the City Beautiful movement, campaigns for housing regulations, the Progressive movement for government reform, and efforts to improve public health through the provision of sanitary sewers and clean water supplies. The First National Conference on City Planning occurred in 1909, the same year as Daniel Burnham's famous Plan of Chicago. That date may be used to mark the inauguration of the new profession. The early city planners actually came from diverse backgrounds such as architecture, landscape architecture, engineering, and law, but they shared a common desire to produce a more orderly urban pattern.

The zoning of land became, and still is, the most potent instrument available to American city planners for controlling urban development. Zoning is basically the dividing of the city into discrete areas within which only certain land uses and types of buildings can be constructed. The rationale is that certain activities of building types don't mix well; factories and homes, for example. Illogical mixtures create nuisances for the parties involved and lower land values. After several decades of gradual development, land-use zoning received legal approval from the Supreme Court in 1926.

Zoning isn't the same as planning: it is a legal tool for the implementation of plans. Zoning should be closely integrated with a Master Plan or Comprehensive Plan that spells out a logical path for the city's future in areas such as land use, transportation, parks and recreation, environmental quality, and public works construction. In the early days of zoning this was often neglected, but this lack of coordination between zoning and planning is less common now.

The other important elements of existing city planning are subdivision regulations and environmental regulations. Subdivision regulations require that land being subdivided for development be provided with adequate street, sewers, water, schools, utilities, and various design features. The goal is to prevent shabby, deficient developments that produce headaches for both their residents and the city. Since the late 1960s, environmental regulations have exerted a stronger influence on patterns of urban growth by restricting development in floodplains, on unstable slopes, on earthquake faults, or near sensitive natural areas. Businesses have been forced to reduce smoke emissions and the disposal of wastes has been more closely monitored. Overall, the pace of environmental degradation has been slowed, but certainly not stopped, and a dismaying backlog of environmental hazards remains to be cleaned up. City planners have plenty of work to do as we move into the twenty-first century.

Conclusion: Good City Form

What is the good city? We are unlikely to arrive at an unequivocal answer; the diversity of human needs and tastes frustrates all attempts to provide recipes or instruction manuals for the building of cities. However, we can identify the crucial dimensions of city performance, and specify the many ways in which cities can achieve success along these dimensions.

A most useful guide in this enterprise is Kevin Lynch's A Theory of Good City Form (Cambridge, MA, MIT Press, 1981). Lynch offers five basic dimensions of city performance: vitality, sense, fit, access, and control. To these he adds two "meta-criteria," efficiency and justice.

For Lynch, a vital city successfully fulfils the biological needs of its inhabitants, and provides a safe environment for their activities. A sensible city is organized so that its residents can perceive and understand the city's form and function. A city with good fit provides the buildings, spaces, and networks required for its residents to pursue their projects successfully. An accessible city allows people of all ages and background to gain the activities, resources, services, and information that they need. A city with good control is arranged so that its citizens have a say in the management of the spaces in which they work and reside.

Finally, an efficient city achieves the goals listed above at the least cost, and balances the achievement of the goals with one another. They cannot all be maximized at the same time. And a just city distributes benefits among its citizens according to some fair standard. Clearly, these two meta-criteria raise difficult issues which will continue to spark debates for the foreseeable future.

These criteria tell aspiring city builders where to aim, while acknowledging the diverse ways of achieving good city form. Cities are endlessly fascinating because each is unique, the product of decades, centuries, or even millennia of historical evolution. As we walk through city streets, we walk through time, encountering the city-building legacy of past generations. Paris, Venice, Rome, New York, Chicago, San Francisco -- each has its glories and its failures. In theory, we should be able to learn the lessons of history and build cities that our descendants will admire and wish to preserve. That remains a constant challenge for all those who undertake the task of city planning.


Micropolis, Unix Version.

This game was released for the Unix platform in or about 1990 and has been modified for inclusion in the One Laptop Per Child program. Copyright © 1989 - 2007 Electronic Arts Inc. If you need assistance with this program, you may contact: http://wiki.laptop.org/go/Micropolis or email micropolis@laptop.org.

This program is free software: you can redistribute it and/or modify it under the terms of the GNU General Public License as published by the Free Software Foundation, either version 3 of the License, or (at your option) any later version.

This program is distributed in the hope that it will be useful, but WITHOUT ANY WARRANTY; without even the implied warranty of MERCHANTABILITY or FITNESS FOR A PARTICULAR PURPOSE. See the GNU General Public License for more details. You should have received a copy of the GNU General Public License along with this program. If not, see http://www.gnu.org/licenses/.

ADDITIONAL TERMS per GNU GPL Section 7

No trademark or publicity rights are granted. This license does NOT give you any right, title or interest in the trademark SimCity or any other Electronic Arts trademark. You may not distribute any modification of this program using the trademark SimCity or claim any affliation or association with Electronic Arts Inc. or its employees.

Any propagation or conveyance of this program must include this copyright notice and these terms.

If you convey this program (or any modifications of it) and assume contractual liability for the program to recipients of it, you agree to indemnify Electronic Arts for any liability that those contractual assumptions impose on Electronic Arts.

You may not misrepresent the origins of this program; modified versions of the program must be marked as such and not identified as the original program.

This disclaimer supplements the one included in the General Public License. TO THE FULLEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW, THIS PROGRAM IS PROVIDED TO YOU "AS IS," WITH ALL FAULTS, WITHOUT WARRANTY OF ANY KIND, AND YOUR USE IS AT YOUR SOLE RISK. THE ENTIRE RISK OF SATISFACTORY QUALITY AND PERFORMANCE RESIDES WITH YOU. ELECTRONIC ARTS DISCLAIMS ANY AND ALL EXPRESS, IMPLIED OR STATUTORY WARRANTIES, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, SATISFACTORY QUALITY, FITNESS FOR A PARTICULAR PURPOSE, NONINFRINGEMENT OF THIRD PARTY RIGHTS, AND WARRANTIES (IF ANY) ARISING FROM A COURSE OF DEALING, USAGE, OR TRADE PRACTICE. ELECTRONIC ARTS DOES NOT WARRANT AGAINST INTERFERENCE WITH YOUR ENJOYMENT OF THE PROGRAM; THAT THE PROGRAM WILL MEET YOUR REQUIREMENTS; THAT OPERATION OF THE PROGRAM WILL BE UNINTERRUPTED OR ERROR-FREE, OR THAT THE PROGRAM WILL BE COMPATIBLE WITH THIRD PARTY SOFTWARE OR THAT ANY ERRORS IN THE PROGRAM WILL BE CORRECTED. NO ORAL OR WRITTEN ADVICE PROVIDED BY ELECTRONIC ARTS OR ANY AUTHORIZED REPRESENTATIVE SHALL CREATE A WARRANTY. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF OR LIMITATIONS ON IMPLIED WARRANTIES OR THE LIMITATIONS ON THE APPLICABLE STATUTORY RIGHTS OF A CONSUMER, SO SOME OR ALL OF THE ABOVE EXCLUSIONS AND LIMITATIONS MAY NOT APPLY TO YOU.