Susan LaFond

From: Devin Clarke Sent: Wednesday, August 12, 2020 10:11 AM To: Susan LaFond Subject: RE: Zoning Amendment Proposed Change - Article III Sectoin 3.9; Article V Section 5.1; Article XI Section 11.2

Susan,

MetroCOG is in receipt of this referral. We will conduct a review and distribute our response.

Thank you, Devin

From: Susan LaFond Sent: Tuesday, August 11, 2020 3:47 PM To: [email protected]; Beverly Hayes ; Brett Broesder ([email protected]) ; [email protected]; Christine Angeli ; Christopher Saley ; David Sulkis ; [email protected]; Debra S. Kelly ; Deirdre Thomas ; Devin Clarke ; [email protected]; Gregory H. Pidluski ; Jim Quish ; [email protected]; Jonathan Berchem ; Joseph Griffith ; Julie Nash ; Justin Rosen ; Karen Fortunati ; Marcus Irrek ; MaryRose Palumbo ; Mayor-Ben Blake ; Meg E. Greene ; Patrick Carleton ; [email protected]; Raymond Swift ; [email protected]; Stephen H. Harris ; Steven Johnson ; Suzanne Horvath ; Taft Clark ; Toni Weeks Cc: John Knuff ; [email protected] Subject: Zoning Amendment Proposed Change - Article III Sectoin 3.9; Article V Section 5.1; Article XI Section 11.2

Good afternoon,

Please find attached a proposed text change to Milford Zoning Regulations.

If you have any questions concerning the attached memo, please respond to me via email.

Thank you.

Sue

Susan R. LaFond Administrative Assistant City of Milford Department of Permitting and Land Use 70 West River Street Milford, CT 06460

1 203-783-3374 [email protected]

2 Susan LaFond

From: Eugene Livshits Sent: Thursday, September 3, 2020 5:14 PM To: Susan LaFond Subject: RE: Zoning Amendment Proposed Change - Article III Sectoin 3.9; Article V Section 5.1; Article XI Section 11.2

Good afternoon Sue,

Thank you for submitting the proposed zoning regulation amendments pertaining to Article III Section 3.9; Article V Section 5.1; Article XI Section 11.2. The referral was reviewed by SCRCOG Staff and it was determined that the applicable Zoning District does not appear to be within 500 feet of another municipality in the South Central Region. A review by the RPC will not be required.

If you have any questions, please do not hesitate to contact me.

Best Regards,

Eugene Livshits Senior Regional Planner South Central Regional Council of Governments 127 Washington Avenue, 4th Floor West North Haven, CT 06473 (203) 466-8626

From: Susan LaFond [mailto:[email protected]] Sent: Tuesday, August 11, 2020 3:47 PM

Subject: Zoning Amendment Proposed Change - Article III Sectoin 3.9; Article V Section 5.1; Article XI Section 11.2

Good afternoon,

Please find attached a proposed text change to Milford Zoning Regulations.

If you have any questions concerning the attached memo, please respond to me via email.

Thank you.

Sue

Susan R. LaFond Administrative Assistant City of Milford Department of Permitting and Land Use 70 West River Street Milford, CT 06460

203-783-3374

1 [email protected]

2 Susan LaFond

From: Toni Weeks Sent: Wednesday, August 19, 2020 2:55 PM To: David Sulkis; Susan LaFond; Joseph Griffith Cc: Jonathan Berchem; Debra S. Kelly Subject: FW: Zoning Amendment Proposed Change - Article III Sectoin 3.9; Article V Section 5.1; Article XI Section 11.2 Attachments: #20-7 Article III V and XI Sections 3.9 5.1 and 11.2 081120 for distribution JDG.pdf

Good Afternoon:

The City Attorney’s Office has no legal concerns with regard to the above referenced amendments.

Please note new email address: [email protected]

Toni Weeks Paralegal/Acting Risk Manager City of Milford 110 River Street Milford, CT 06460 (203) 783-3250

This message contains information which is confidential or privileged. Unless you are the addressee or authorized to receive for the addressee, you may not use, copy, distribute or disclose to anyone this message or any of the information contained in this message. If you have received this message in error, please advise the sender by reply email and delete/destroy the message. This message is protected by applicable legal privileges and is confidential. Unauthorized interception is prohibited by Federal Law.

From: Susan LaFond Sent: Tuesday, August 11, 2020 3:47 PM To: [email protected]; Beverly Hayes ; Brett Broesder ([email protected]) ; [email protected]; Christine Angeli ; Christopher Saley ; David Sulkis ; [email protected]; Debra S. Kelly ; Deirdre Thomas ; Devin Clarke ([email protected]) ; [email protected]; Gregory H. Pidluski ; Jim Quish ; [email protected]; Jonathan Berchem ; Joseph Griffith ; Julie Nash ; Justin Rosen ; Karen Fortunati ; Marcus Irrek ; MaryRose Palumbo ; Mayor-Ben Blake ; Meg E. Greene ; [email protected]; [email protected]; Raymond Swift ; [email protected]; Stephen H. Harris ; Steven Johnson ; Suzanne Horvath ; Taft Clark ; Toni Weeks Cc: John Knuff ; [email protected] Subject: Zoning Amendment Proposed Change - Article III Sectoin 3.9; Article V Section 5.1; Article XI Section 11.2

Good afternoon,

Please find attached a proposed text change to Milford Zoning Regulations.

1 If you have any questions concerning the attached memo, please respond to me via email.

Thank you.

Sue

Susan R. LaFond Administrative Assistant City of Milford Department of Permitting and Land Use 70 West River Street Milford, CT 06460

203-783-3374 [email protected]

2 HURWITZ SAGA,RIN r" SLOSSBERG .KNUFF HS LLC SK

LAW OFFICES 147 North Broad Street Milford, CT 06460 Amy E. Souchuns, Esq. T: 203.877.8000 F: 203.878.9800 [email protected] hssklaw.com

September 3, 2020

Hand Delivered

Karen Fortunati, City Clerk CityofMilford 70 W. River St. Milford, CT 06460

Re: Petition for Change ofMilford Zoning Regulations Article III, V & XI, Sections 3.9, 5.1 & 11.2

Dear Ms. Fortunati:

On behalf of the petitioner, The Post Limited Partnership, enclosed is a copy of the proposed amendments to the Milford Zoning Regulations that the petitioner has submitted to the Milford Planning and Zoning Commission. In accordance with Conn. Gen. Stat. § 8-3, please place this proposal on file with your office.

Please feel free to contact me with any questions.

Very, truly yours, 1/Uc/^ Amy E. Souchuns

ec: David Sulkis ^^<^%^W, ^owtectwtt Department of Permitting and Land Use

Founded 1639 David B. Sulkis, 70 West River Street • Milford, Connecticut • 06460-3317 City Planner wwvi'.ci.milford.ct.us

TO: ^ South Central Regional Council of Governments M Greater Bridgeport Regional Planning Council IZ] City Attorney, City ofMilford State of CT DEEP City of West Haven, City Clerk IE) Town of Stratford, Town Clerk M Town of Orange, Town Clerk

FROM: David B. Sulkis, City Planner

DATE: August 10,2020

RE: Proposed Changes to the City of Milford Zoning Regulations Article III Section 3.9; Article V Section 5.1; Article XI Section 11^2

In accordance with Milford Zoning Regulations 10.3 and CT General Statutes 8-3b and 22a-104, the distribution of the following proposed regulation change is submitted for your agency's review and comment. Please provide this office with acknowledgement of your receipt of this memorandum and provide your comments or approval within 35 days of the above date.

EXISTING TEXT:

ARTICLE III DISTRICT USE REGULATIONS

SECTION 3.9 SHOPPING CENTER DESIGN DISTRICT^SCD

3.9.1 Permitted Uses: All uses permitted in Shopping Center Design Districts shall be deemed to be Special Uses.

3.9.2 Special Uses: Subject to all other applicable provisions and limitations of these Regulations, the Board may permit the following buildings or uses, subject to Special Permit and Site Plan Approval in accordance with ARTICLE VII, herein.

3.9.2.1 Mixed uses containing allowable businesses, offices, and multi-family

Milford Department ofPerniittiiig and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Plamiing and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 1 dwelling units; subject to the limitations of Section 3.3 medium density multi-family residential districts (RMF-16): subject to the limitations of Section 3.9.4.3 herein, and provided that the minimum lot area utilized for multi- family dwelling units shall not be less than 20 acres.

3.9.2.2 Multi-Family Dwelling Units as provided and regulated in Section 3.3 medium density multi-family residential districts, subject to the limitations of Section 3.9.4.3, herein, and provided that the minimum lot area shall not be less than 20 acres.

3523 Offices for business, financial, professional or personal services or other similar offices.

392A Hotels or motels as provided and regulated in the Design Office District, Section 3.6.2.3.

3525 A retail store containing at least 40,000 square feet of floor area.

3926 A shopping center containing at least 60,000 square feet of floor area and containing stores for sale of goods at retail or for performance of personal services clearly subordinate and customarily incidental to retail sales.

3527 Eating places subject to the provisions of Section 5.5 where applicable.

3528 Restaurants with an outdoor customer dining area as defined in Section 11-2.

3529 Sale of alcoholic liquor, subject to the applicable provisions of Section 5.5 herein.

35210 Stores for sale of goods at wholesale.

352.11 Indoor places of entertainment, amusement, recreation or assembly such as theaters, billiard rooms, bowling alleys or other similar indoor uses. A public hearing shall be required for all uses designated in this subsection.

35.1t2 Dry cleaning or dyeing establishments using non-inflammable solvents; provided that the floor area shall not exceed 3,000 square feet per establishment, and subject to approval of the cleaning solvents by the Fire Department and approval of the method of waste disposal by the Departments of Public Works and Public Health.

35213 Off-street parking garages or lots.

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Plamiing and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page|2 392.14 Accessory buildings or uses clearly subordinate and customarily incidental to and located on the same lot with any of the foregoing special uses shall be approved by the Board in the same manner as a Special Use. 352.15 A change in the use of interior space of an existing building in a Shopping Center Design District shall not require either an amendment to a Special Permit and/or Site Plan Approval, provided that such use is listed in Section 3.9.2 or Section 3.9.3, and further provided that no exterior structural changes to the existing building shall be made in connection with such changed use. 352.16 Extended stay hotels.

352.17 Health centers or clubs provided that the maximum gross building area devoted to such health center or club use shall not exceed 41,000 square feet.

352.18 Other related or equivalent principal buildings or uses, which are not specifically listed and are not prohibited may be permitted by the Board by Special Exception in accordance with Section 7.3.

Requests for change of use to be considered under the provisions of this Section shall be in accordance with Section 8.8.2 Change of Use.

3.9.3 Accessory Uses: The following accessory uses shall be allowed: 3.9 J.l Converting, altering, finishing, cleaning, assembly or other processing of products which is clearly subordinate and customarily incidental to a principal use and where goods so produced or processed are used or sold exclusively on the premises provided that the area used for such purposes shall be within a completely enclosed building.

3.932 Accessory vehicle repair and/or service garages, subject to the applicable provisions of Section 5.4 herein.

3.933 Accessory storage of equipment, merchandise, materials or supplies within completely enclosed buildings.

3.9J.4 Other accessory buildings or uses which are clearly subordinate and customarily incidental to and located on the same lot with the principal use, and that will not be hazardous to the public health, safety and welfare.

3.9 J5 Off-Street Parking and Loading: In accordance with Section 5.1,

Milford Departmeiit of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Planning and Zoning; 203-783-3245 Fax (Planning and Zoning/Wetlaiids): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 3 herein; except that off-street parking, loading and vehicular access areas shall be provided in the manner and to the extent determined by the Board to be adequate for any mixed use building, notwithstanding the applicable provisions of Section 5.1.4, herein. Landscaping in parking areas shall conform with Article V, Section 5.14.

3.93.6 Signs: In accordance with Section 5.3 herein.

3.9.4 Lot and Building Requirements: Subject to all other applicable provisions and limitations of these Regulations, buildings and uses shall comply with all lot and building requirements as set forth herein.

3.9.4.1 Minimum Lot Requirements:

(1) Lot Area: (a) with dwelling units 20 acres (b) without dwelling units 10 acres (2) Lot Width: 300 feet

(3) Lot Depth: 300 feet

3.9.42 Minimum Yard and Open Space Requirements:

(1) Principal Uses: Front, side and rear yards for all principal uses shall not be less than 50 feet.

(2) Accessory Uses: Front, side and rear yards for all accessory uses, exclusive of signs, shall not be less than 25 feet.

(3) Buffer Strip: At least 10 feet adjacent to any Residential District for the first 50 required off-street parking spaces or any portion thereof, plus an additional 10 feet of buffer strip adjacent to any Residential District for each additional 50 required off-street parking spaces, or major fraction thereof, up to a maximum of 100 feet of buffer strip The planting shall conform with Article V Section 5.14.

3.9.43 Building Requirements:

(1) Design: Buildings shall be designed in such a manner as to be compatible with the lot and in harmony with the general character and appearance of the surrounding neighborhood.

(2) Length: Buildings shall not be of such unreasonable length as to adversely affect the general character and appearance of the

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Planning and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 4 surrounding neighborhood.

(3) Height: No building or structure shall exceed 10 stories or 120 feet in height; except that multiple-family dwellings shall comply with the applicable height provisions for RMF-16 Residential Districts.

(4) Spacing: Group buildings on a single lot shall be so arranged that the minimum distance between principal and/or accessory buildings shall be equal to or greater than one-third the sum of the heights of the affected buildings; exclusive of parking structures which are designed to function in conjunction with a principal building.

(5) Building Area: A maximum of 50 percent or less as required by off-street parking and loading regulations.

(6) Floor Area Ratio: A maximum of 1.5 FAR, exclusive of accessory parking garages and structures.

(7) Dwelling Units/Business Floor Area: Where multi-family dwelling units are proposed, a maximum of 40 percent of the aggregate floor area, exclusive of accessory parking and loading garages and structures, shall be used for dwelling purposes and a minimum of 50% shall be used for business and/or office uses.

(8) Dwelling Units: Where dwelling units are proposed not to be part of a mixed use development, density shall be allowed within the following limitations: a medium density of 16 to 24 bedrooms per acre; multi- family residential shall be allowed within buildings or structures of 3 or less stories or a height of 35 feet. Increased densities are subject to Planning and Zoning Board review of building and site design to include roof style screening of mechanical equipment, facade treatments, minimum re-grading and/or changes to topography, sign designs and location, underground utilities, on site lighting and design and landscape and grading design of the site.

The provisions shall not be construed to allow a greater density than is otherwise allowable within the limitations of Section 3.9.2.2, herein.

3.9.5 Prohibited Uses: The following uses shall be expressly prohibited:

3.9.5.1 No display of goods outdoors, exclusive of nursery stock, shall be permitted except in courts or mails.

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Plamims and Zoning; 203-783-3245 Fax (Planning and Zoning/WetIands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 5 3.9.52 No retail sales outdoors, from open counters, or with curb service shall be permitted; except for seasonal sidewalk sales.

3.9.53 No drive-in establishment shall be permitted; except for drive-in banks.

3.9.5.4 No commercial garage, gasoline station, vehicle repair and/or service garage, vehicle dealership, vehicle washing establishment, or other similar use shall be permitted; except for one accessory gasoline station per lot, and for one accessory vehicle repair and/or service garage per lot.

3.9.5.5 No parking or loading area shall be used for the storage of new or used vehicles for sale or hire or for the storage of unregistered vehicles.

3.9.5.6 No warehouse or storage; junk yard; or outside storage yards shall be permitted.

3.9.5.7 No trucking terminal facilities for handling freight or material with or without maintenance facilities shall be permitted; except for clearly subordinate and customarily incidental delivery departments or off- street loading facilities operated by business concerns for their own use.

3.9.5.8 No principal manufacturing, fabricating, assembling or processing of goods or products shall be permitted.

3.9.5.9 Any building or use which will not comply with the Performance Standards of Section 5.11 shall be prohibited.

3.9.6 Modification of Requirements:

3.9.6.1 Reserved for future use.

3.9.6.2 A development site may be subdivided for separate sale of the components of a plan approved under this Section, provided the overall development complies with these Regulations. Any such subdivision shall be in accordance with the provisions of the Subdivision Regulations of the City ofMilford. That, in the event of the foregoing, any subdivision for separate sale of a development site shall be deemed to meet the requirements of these Regulations if the overall development complies with these Regulations.

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Planning and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 6 ARTICLE V SUPPLEMENTARY REGULATIONS

SECTION 5.1 PARKING AND LOADING REGULATIONS

5.1.4. Off-Street Parking Requirements:

Figure 4: Minimum Off-Street Parking Requirements

TypeofBuildineorUse Minimum Required Parking Spaces

(3) Multiple Family Dwellings (a) Efficiency bedroom units 2 space minimum per dwelling unit (1-1.5 in MCDD, CDD-1, CDD-2) (b) One bedroom unit 2 space minimum per dwelling unit (1.5-2 in MCDD, CDD-1, CDD-2) (c) Two bedroom units 3 space minimum per dwelling unit (2-2.5 in MCDD, CDD-1, CDD-2) (d) Three bedroom units 3 space minimum per dwelling unit 2-2.5 in MCDD & CDD-2)

Figure 4: IVIinimum Off-Street Parking Requirements

TypeofBuildinsorUse Minimum Required Parking Spaces (24) Regional Shopping Malls 1 space for each 250 sq. ft. of gross buildable area. Storage areas of more than 10,000 sq. ft. per store unit shall not be included in the parking calculations and shall be a deduction from gross buildable area. * An establishment may reduce its parking requirement down to a minimum of 1 space for each 400 sq. ft. of gross floor area, in exchange for an increase in buildable floor area equal to one-halfofthe difference between the reduced parking requirement and the general minimum of 1 space for each 250 sq. ft. of gross floor area. The remaining one-halfofthis difference must be maintained as additional landscaped open space on the site, in accordance with Article V, Section 5.14 of these Regulations. The Board, if it determines upon review of a Site Plan for such establishment that a reduction in the number of parking spaces is suitable and proper for the site, may grant this reduction by way of a Special Exception.

ARTICLE XI DEFINITIONS

SECTION 11.2 OTHER TERMS

(NEW)

THE CONNECTICUT POST LIMITED PARTNERSHIP

Proposed Text Changes July 2020

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Buiiding): 203-783-3690 Planning and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands); 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 7 Language to be deleted shown in strikethrough; language to be added shown bold underlined.

ARTICLE III DISTRICT USE REGULATIONS

SECTION 3.9 SHOPPmG CENTER DESIGN DISTRICT: SCD

3.9.1 Permitted Uses: All uses permitted in Shopping Center Design Districts shall be deemed to be Special Uses.

3.9.2 Special Uses: Subject to all other applicable provisions and limitations of these Regulations, the Board may permit the following buildings or uses, subject to Special Permit and Site Plan Approval in accordance with ARTICLE VII, herein.

3.9.2.1 Mixed uses containing allowable businesses, offices, and multi-family dwelling units subject to the limitations of Section 3.3 medium density multi family residential districts (RMF 16); subject to the limitations of Section 3.9.4.3 herein, and provided that the minimum lot area utilized for multi- family dwelling units shall not be less than 30 4 acres.

3.9.2.2 Multi-Family Dwelling Units as provided and regulated in Section 3.3. medium density multi family residential districts, subject to the limitations of Section 3.9.4.3, herein, and provided that the minimum lot area shall not be less than SO 4 acres.

3.9.2.3 Offices for business, financial, professional or personal services or other similar offices.

3.9.2.4 Hotels or motels as provided and regulated in the Design Office District, Section 3.6.2.3.

3.9.2.5 A retail store containing at least 40,000 square feet of floor area.

3.9.2.6 A shopping center containing at least 60,000 square feet of floor area and containing stores for sale of goods at retail or for performance of personal services clearly subordinate and customarily incidental to retail sales.

3.9.2.7 Eating places subject to the provisions of Section 5.5 where applicable.

3.9.2.8 Restaurants with an outdoor customer dining area as defined in Section 11-2.

3.9.2.9 Sale of alcoholic liquor, subject to the applicable provisions of Section 5.5 herein.

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Planning and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page|8 3.9.2.10 Stores for sale of goods at wholesale.

3.9.2.11 Indoor places of entertainment, amusement, recreation or assembly such as theaters, billiard rooms, bowling alleys or other similar indoor uses. A public hearing shall be required for all uses designated in this subsection.

3.9.2.12 Dry cleaning or dyeing establishments using non-inflammable solvents; provided that the floor area shall not exceed 3,000 square feet per establishment, and subject to approval of the cleaning solvents by the Fire Department and approval of the method of waste disposal by the Departments of Public Works and Public Health.

3.9.2.13 Off-street parking garages or lots.

3.9.2.14 Accessory buildings or uses clearly subordinate and customarily incidental to and located on the same lot with any of the foregoing special uses shall be approved by the Board in the same manner as a Special Use.

3.9.2.15 A change in the use of interior space of an existing building in a Shopping Center Design District shall not require either an amendment to a Special Permit and/or Site Plan Approval, provided that such use is listed in Section 3.9.2 or Section 3.9.3, and further provided that no exterior structural changes to the existing building shall be made in connection with such changed use.

3.9.2.16 Extended stay hotels.

3.9.2.17 Health centers or clubs provided that the maximum gross building area devoted to such health center or club use shall not exceed 41,000 square feet.

3.9.2.18 Other related or equivalent principal buildings or uses, which are not specifically listed and are not prohibited may be permitted by the Board by Special Exception in accordance with Section 7.3.

Requests for change of use to be considered under the provisions of this Section shall be in accordance with Section 8.8.2 Change of Use.

3.9.3 Accessory Uses: The following accessory uses shall be allowed:

3.9.3.1 Converting, altering, finishing, cleaning, assembly or other processing of products which is clearly subordinate and customarily incidental to a principal use and where goods so produced or processed are used or sold exclusively on the premises provided that the area used for such purposes shall be within a completely enclosed building.

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Plamiing and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 9 3.9.3.2 Accessory vehicle repair and/or service garages, subject to the applicable provisions of Section 5.4 herein.

3.9.3.3 Accessory storage of equipment, merchandise, materials or supplies within completely enclosed buildings.

3.9.3.4 Other accessory buildings or uses which are clearly subordinate and customarily incidental to and located on the same lot with the principal use, and that will not be hazardous to the public health, safety and welfare.

3.9.3.5 Off-Street Parking and Loading: In accordance with Section 5.1, herein; except that off-street parking, loading and vehicular access areas shall be provided in the manner and to the extent determined by the Board to be adequate for any mixed-use building, notwithstanding the applicable provisions of Section 5.1.4, herein. Landscaping in parking areas shall conform with Article V, Section 5.14.

3.9.3.6 Signs: In accordance with Section 5.3 herein.

3.9.3.7 Recreational buildings and uses accessory to Multi-Family Dwelling Units, including swimming pool, clubhouse and exercise facilities.

3.9.4 Lot and Building Requirements: Subject to all other applicable provisions and limitations of these Regulations, buildings and uses shall comply with all lot and building requirements as set forth herein.

3.9.4.1 Minimum Lot Requirements:

(1) Lot Area: (a) with dwelling units SO 4 acres (b) without dwelling units 10 acres

(2) Lot Width: 300 feet

(3) Lot Depth: 300 feet

3.9.4.2 Minimum Yard and Open Space Requirements:

(1) Principal Uses: Front, side and rear yards for all principal uses shall not be less than 50 feet.

(2) Accessory Uses: Front, side and rear yards for all accessory uses, exclusive of signs, shall not be less than 25 feet.

(3) Buffer Strip: At least 10 feet adjacent to any Residential District for the first 50 required off-street parking spaces or any portion thereof, plus an additional 10 feet of

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Planning and Zoning: 203-783-3245 Fax (Planning and Zomng/Wetlands): 203-783-3303 Wetlands; 203-783-3256 Director: 203-783-3374 Page | 10 buffer strip adjacent to any Residential District for each additional 50 required off-street parking spaces, or major fraction thereof, up to a maximum of 100 feet of buffer strip. The planting shall conform with Article V Section 5.14.

3.9.4.3 Building Requirements:

(1) Design: Buildings shall be designed in such a manner as to be compatible with the lot and in harmony with the general character and appearance of the surrounding neighborhood.

(2) Length: Buildings shall not be of such unreasonable length as to adversely affect the general character and appearance of the surrounding neighborhood.

(3) Height: No building or structure shall exceed 10 stories or 120 feet in height; except that multi-family dwellings units shall comply with the applicable height provisions for RMF 16 Residential Districts not exceed 5 stories or 85 feet in height.

(4) Spacing: Group buildings on a single lot shall be so arranged that the minimum distance between principal and/or accessory buildings shall be equal to or greater than one-third the sum of the heights of the affected taller buildings; exclusive of parking structures which are designed to function in conjunction with a principal building.

(5) Building Area: A maximum of 50 percent or less as required by off-street parking and loading regulations.

(6) Floor Area Ratio: A maximum of 1.5 FAR, exclusive of accessory parking garages and structures.

(7)—Dwelling Units/BusinosG Floor Area: Whore multi family dwelling units are proposed, a maximum of/10 percent of the aggregate floor area, exclusive of accessory parking and loading garages and Qtructuros, shall be used for dwelling purposes and a minimum of 50% shall be used for business and/or office uses.

(87) Dwelling Units: Where dwelling units are proposed not to be part of a mixed uoo development, density shall be allowed within the following limitations: a medium density of 16 to 21 bedrooms per acre; multi family residential shall bo allowed within buildings or structures of 3 or less stories or a height of 35 feet. Increased densities are subject to Planning and Zoning Board review of building and site design to include roof style screening of mechanical equipment, fa9ade treatments, minimum re grading and/or changes to topography, sign designs and location, underground utilities, on site lighting and design and landscape and grading design of site. The maximum number of units within the zone shall be 300.

The provisions shall not be constructed to allow a greater density than is otherwise allowable within the limitations of Section 3.9.2.2, herein.

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Plamiing and Zoning: 203-783-3245 Fax (Planning and Zoiiing/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 11 3.9.5 Prohibited Uses: The following uses shall be expressly prohibited:

3.9.5.1 No display of goods outdoors, exclusive of nursery stock, shall be permitted except in courts or malls.

3.9.5.2 No retail sales outdoors, from open counters, or with curb service shall be permitted; except for seasonal sidewalk sales.

3.9.5.3 No drive-in establishment shall be permitted; except for drive-in banks.

3.9.5.4 No commercial garage, gasoline station, vehicle repair and/or service garage, vehicle dealership, vehicle washing establishment, or other similar use shall be permitted; except for one accessory gasoline station per lot, and for one accessory vehicle repair and/or service garage per lot.

3.9.5.5 No parking or loading area shall be used for the storage of new or used vehicles for sale or hire or for the storage of unregistered vehicles.

3.9.5.6 No warehouse or storage; junk yard; or outside storage yards shall be permitted.

3.9.5.7 No trucking terminal facilities for handling freight or material with or without maintenance facilities shall be permitted; except for clearly subordinate and customarily incidental delivery departments or off-street loading facilities operated by business concerns for their own use.

3.9.5.8 No principal manufacturing, fabricating, assembling or processing of goods or products shall be permitted.

3.9.5.9 Any building or use which will not comply with the Performance Standards of Section 5.11 shall be prohibited.

3.9.6 Modification of Requirements:

3.9.6.1 Reserved for future use.

3.9.6.2 A development site may be subdivided for separate sale of the components of a plan approved under this Section, provided the overall development complies with these Regulations. Any such subdivision shall be in accordance with the provisions of the Subdivision Regulations of the City ofMilford. That, in the event of the foregoing, any subdivision for separate sale of a development site shall be deemed to meet the requirements of these Regulations if the overall development complies with these Regulations.

Milford Department of Permitting aiid Land Use Building; 203-783-3234 Fax (Building): 203-783-3690 Planning and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page [ 12 ARTICLE V SUPPLEMENTARY REGULATIONS

SECTION 5.1 PARKING AND LOADING REGULATIONS

Figure 4: Minimum Off-Street Parking Requirements

5.1.4 Off-Street Parking Requirements

Figure 4: Minimum Off-Street Parking Requirements

Type of Building or Use Minimum Required Parking Spaces

(3) Multiple Family Dwellings (a) Efficiency bedroom units 2 space minimum per dwelling unit (1-1.5 in MCDD, CDD-1 and CDD-2) (1.5 inSCDD) (b) One bedroom unit 2 space minimum per dwelling unit (1.5-2 in MCDD, CDD-1 and CDD-2) (1.5 inSCDD) (c) Two bedroom units 3 space minimum per dwelling unit (2-2.5 in MCDD, CDD-1 and CDD-2) (1.5 inSCDD) (d) Three bedroom units 3 space minimum per dwelling unit (2-2.5 in MCDD and CDD-2) (1.5 in SCDD)

Type of Building or Use Minimum Required Parking Spaces

(24) Regional Shopping Malls 1 space for each 250 sq. ft. of gross buildable 3 spaces for each 1,000 sq. ft. of gross leasable area. Storage areas of more than 10,000 sq. ft. per store unit shall not be included in the parking calculations and shall be a deduction from gross buildable leasable area.

ARTICLE XI DEFINITIONS

SECTION 11.2 OTHER TERMS

GROSS LEASABLE AREA - The total enclosed floor area designed for the exclusive use and occupancy by all tenants including basements, mezzanines, and upper floors as measured from the center line of joint partitions, from the lease line at common areas, and from outside wall faces.

Milford Department of Permitting and Land Use Building: 203-783-3234 Fax (Building): 203-783-3690 Planning and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 13 REASON FOR CHANGE:

To allow for redevelopment opportunities at the Connecticut Post IVIall.

A petition for substantially the same change in regulations has previously been filed: Yes _ No X if Yes, date of hearing:

This regulation change is proposed by: Petitioner X Planning and Zoning Board or Planning and Zoning Board Subcommittee

C: Chairman, P&Z Chairman, P&Z Regulation Sub-Committee Director, DPLU

Milford Department of Permitting and Land Use Building: 203-783-3234 FELK (Building): 203-783-3690 Planning and Zoning: 203-783-3245 Fax (Planning and Zoning/Wetlands): 203-783-3303 Wetlands: 203-783-3256 Director: 203-783-3374 Page | 14

Connecticut Post Mall Proposed 300-Unit Multi-Family Development

Municipal Fiscal Impact Analysis: for the Milford Planning and Zoning Board

June 26, 2020

Prepared by: Donald J. Poland, PhD, AICP Managing Director, Urban Planning & Strategy Goman + York Property Advisors, LLC 1137 Main Street East Hartford, CT 06108 Phone: 860-655-6897 E-mail: [email protected] www.gomanyork.com

DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

June 26, 2020 Jim Quish, Chair Town of Milford Planning & Zoning Board 70 West River Street Milford, CT 06460

RE: Connecticut Post Mall – Application to Amend the Milford Zoning Regulations (“Regulations”)

Dear Chairman Quish: I submit this report as expert testimony and supportive material for the Connecticut Post Mall application to amend the Shopping Center Design District (“SCDD”) regulations. The SCDD regulations currently permit a multi-family residential community, but only in a format that does not reflect the needs, desires, or expectations of the current multi-family rental market. As I am sure you are aware, the retail sector is being disrupted by advances in technology, the increasing popularity of ecommerce, and shifts and changes in consumer shopping and spending behaviors. While these changes are impacting most segments of the retail industry, the large, regional, enclosed malls have been harmed the most. In past decades, headlines touted the Malling of America. Today, headlines claim a Retail Apocalypse. A recent Business Insider1 article estimates that up to 25% of the remaining malls (hundreds have already closed) will shutter by 2022. The fact is few malls will survive as traditional enclosed malls. Malls that do survive will be those that innovate, adapt, and become hybrid spaces that combine retailing with entertainment, residential, offices, and other uses— become mixed use developments. This report will explore these changes and challenges to the retail sector and malls—the issue at the core of this application—and provide a municipal fiscal impact analysis of the proposed residential development on the Post Mall site. Most important and unlike other malls, the ownership of Connecticut Post Mall are committed to innovating and adapting the mall to ensure its continued existence and substantial contribution to the City of Milford. Thank you for your time and consideration of this application. I will be available at the public hearing to answer any questions and address any concerns you or other members of the Commission may have. Respectfully submitted,

Donald J. Poland, PhD, AICP

1 50 Haunting Photos of Abandoned Shopping Malls Across America, Business Insider, Nov. 8, 2019 by Mary Hanbury. See also, The demise of America’s malls can deal a blow to the towns that depend on them, CNBC, June 20, 2020 by Lauren Thomas.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Town of Milford – Planning & Zoning Board Summary of Findings: Municipal Fiscal Impacts March 26, 2020

Revenues: Real Property Taxes & User Fees Real Property Taxes (300 Multi-Family Residential Units) = $1,101,772 Personal Property Taxes (450 Motor Vehicles at $252/vehicle/year) = $113,472 Sewer User Fees ($328.80/unit/year) = $98,640 Estimated Projection – Total Taxes & Fees = $1,313,884

Expenditures: School Enrollment Projections & Cost2 Total Enrollments (0.24 multiplier per unit = 72 enrollments)3 = Enrollment Expenditures (36 NTD Enrollments @ $10,855/Enrollment/Year)4 = -$390,200

Expenditures: Municipal Government Total Expenditures – General Government (23.1% of revenue)5 = -$280,710 -$670,910 Fiscal Impact Summary Total Revenue (Property Taxes & Fees) = $1,313,884 Total Expenditures – (Education & General Government) = -$670,910 Estimated Positive Fiscal Impact/Year = $642,974

One-Time Development Fees Land Use Permitting Fees6 = $6,855 Building Permitting Fees7 = $11,670 Sewer Connection Fees ($25/unit)8 = $7,500 Estimated One-Time Development Fees = $26,025

2 Milford’s housing stock consists of 23,571 housing units, of which 21,634 units are occupied. Owner-occupied housing accounts for 76.4%, of which 74.3% are single-family, and 59.6% of the housing stock has 3+ bedrooms. With 5,566 student enrollments in the school district, Milford’s housing stock generates 0.24 enrollments per housing unit (and 0.26 per household or occupied housing unit). 3 Projected enrollments from the 300 proposed multi-family apartments units equal 72 or 0.24 enrollments per unit. 4 Per pupil enrollment costs are adjusted for non-property tax education revenue and allocated expenses to account for fixed cost in the Milford BOE budget that generally are not impacted by changes in enrollments (i.e. utilities, maintenance, administration, etc.). 5 General Government expenditures estimate the percent value of government services (23.1% total revenues) utilized by the proposed multi-family units. This 23.1% accounts for general government services less the commercial and industrial portions of the grand list and the BOE expenditures that are captured in Education Expenditures. 6 Land Use Fees include Zoning Permits ($95), Special Permit Application ($510), Public Hearing fee ($250), and Plan Review fee ($20/unit). 7 Building permit fees are calculated $20 per $1,000 of the first $1,000 in construction costs and $18 per $1,000 for additional construction costs. Fees also include Certificate of Occupancy ($20/unit). 8 The Sewer Connection Fee is $25 per unit.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

City of Milford – Planning & Zoning Board Connecticut Post Mall – Municipal Fiscal Impact Analysis

I. Introduction The proposal before the Planning and Zoning Board is for an amendment to the SCDD regulations in order to permit the construction of a 300-unit multi-family housing development on the site of the Connecticut Post Mall. The Mall site is located at the intersection of Route 1 (Boston Post Road) and Interstate I-95 (Exit 39) and consists of 74.86 acres with 8 buildings totaling 1,752,680 square feet of retail space. First developed in 1960 and enclosed in 1981, the Connecticut Post Mall has functioned as a regional mall, anchoring the area, and attracting substantial surrounding retail development. For more than a decade, the Post Mall has been Milford’s largest taxpayer. The aim of this report is to provide the Milford Planning and Zoning Board with an analysis of the municipal fiscal impacts associated with the proposed multi-family housing development. As shown on the Summary of Findings page above, the proposed 300-units of multi-family housing will result in a positive fiscal impact of up to $642,974 in net-positive tax revenue each year—ensuring that the Connecticut Post Mall remains Milford’s largest taxpayer and that the housing units do not create a fiscal burden on the City of Milford municipal services. While the positive fiscal impact is important, understanding the demographic, social, economic, and generational changes that are underlying the positive fiscal impact are even more important. To best understand these changes, we first need to understand that cities (towns, suburbs, and urban areas) are complex adaptive systems—socio-economic ecosystems—that are constantly shifting, changing, and reorganizing around new social, behavioral, economic, and technological forces. Therefore, this report begins with a discussion of these changes and how such forces impact land use planning. To accomplish this, the report explores the changing landscape of retail, demographics, housing, and how these changes are impacting Milford, especially Milford’s declining school district enrollments. This will help us understand the importance of adaptation and the need not to resist, but to embrace and manage change.9

9 For a detailed account of urban ecology, changes in suburban communities (including commercial centers and retail), and the need to embrace and manage change, see Poland, Donald; (2016) Urban Resilience - Evolution, Co-Creation, and the Remaking of Space. Doctoral Thesis, UCL (University College London).

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

II. The Changing Landscape of Retail The form and function of our settlement patterns are forever changing around technological and transportation innovations, economics, and our social-cultural ways of living in our environment. For example, our first industrial mills and factories were located alongside rivers (their source of power) and towns and cities were constructed around them. Riverside locations were later abandoned once electricity was invented and electric power sources provided. The arrival of rail resulted in the abandonment of many ports, as manufacturing relocated along the rail lines. Later, interstate highways further transformed and reorganized the location and site of industry at interchanges and access ramps (i.e. the industrial park) and large single-story buildings that consolidated production, assembly, and distribution on a single floor. The same is true of retailing. The location, building forms, and space of retail has also been continually shifting and changing around technological and transportation innovations, economics, and our social- cultural ways of living in our environment (including the ways in which we shop). In the early to mid- 1900s the primary location of retail was in city centers (i.e. downtown and main street) and multi-story department stores. Over time department stores (and other retailers) shifted outward to suburban centers and retail strips. Later, the enclosed American mall came into vogue, located miles outside the central city, downtowns, and suburban centers, at interstate highway interchanges and access ramps, and anchored by large single- and two-story department stores. Next, the big box discount department stores and specialty retailers (i.e. category-killers) emerged on the scene, often favoring locations proximate to malls and other retail clusters. Just as the mill towns and industrial cities struggled with the changing location of manufacturing, the downtowns, main streets, and suburban centers struggled with the changing location of retailing.10 Today, with the arrival of ecommerce, the retail sector continues to change. However, the arrival of ecommerce retailing is not simply a spatial shift in the physical location of retail, it is a shift to a virtual space that captures market share, while rendering physical locations and physical spaces of retailing functionally obsolete. For example, when retailing moved from main street to malls, new uses and certain forms of retailing, such as personal service and hospitality (i.e. restaurants) discovered new opportunities on main street, backfilling into abandoned spaces, and creating new vitality on many main streets and in town centers. With the shift to the virtual space of ecommerce, there is no longer enough demand for physical space (bricks and mortar retail) to backfill in downtowns, town centers, main streets, retail strips, and most notably, enclosed regional malls. Many of the past locations and spaces of retail are being rendered functionally obsolescent.

10 It is important to note that during this century-long change in the spatial location and organization of retailing, the retail sector itself was also transformed from the tailor-made, local, and individualized product to off-the-rack mass-produced products provided by global commodity chains.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

This shift from the spatial location and physical space of past retail to the virtual space of ecommerce and the industrial location and space of fulfilment and distribution centers is at the core of the new media accounts of the ‘retail apocalypse’ and ‘dead and dying malls.’ While such media accounts may over-dramatize the collapse of bricks-and-mortar retail (and retailers), there are many truths to the apocalypse and the struggles of the changing landscape of retailing. The fact, the landscape of retail has changed and will continuing to change. Retailing as we once knew it is being disrupted and transformed by technological and transportation innovations, economics, and the ever-changing behaviors of consumers. Simply put, consumers no longer shop and spend in the same ways as we did one or more decades ago. The retailers most harmed by these changes are the consumer electronics, apparel, books, and department stores (among others). Unfortunately for malls, retail apparel and department stores have been the lifeblood and anchors of malls. The Connecticut Post Mall is an illustrative example of the impact of these general trends in the retail industry and malls. For example, ecommerce, the aging of the Baby Boomers, the different priorities of the Millennials, and the over building of retail collectively have had a substantial impact on the enclosed mall retail distribution channel model. The impact is so dramatic, that various retail industry reports and experts estimate that between 25% and 50% of the existing enclosed malls will no longer be economically sustainable in the coming years. Bricks-and-mortar retail, including enclosed malls, will not cease to exist. Those that can and do innovate will find their place and persist. However, the future of retail remains uncertain, the struggle to innovate and persist are real, and the retail industry will remain subject to continued forces of disruption—technological advance in artificial intelligence and even autonomous auto-mobility will further challenge the retail industry. Many retail locations, sites, stores, and malls will collapse and be defined by vacancy, abandonment, and ultimately blight. Others will innovate, adapt, and shape-shift into new hybrid forms and functions that comingle similar, related, and compatible uses into new kinds of spaces and lifestyle experiences. Adaptation and hybrids are at the core our American entrepreneurial culture and by paying close attention to and giving “special sensitivity to marginal, neighboring, or occluded practices” we “generate the art, not science, of invention.”11 The owners of the Connecticut Post Mall are seeking to innovate—to adapt and find new hybrid forms to (re)position the Post Mall site to remain economically and socially viable and sustainable. In fact, the Post Mall ownership have done better than most in sustaining the malls occupancy as new tenants have been found to fill the spaces of past anchors and other tenant spaces. However, the universe of new retail tenants and opportunities to sustain occupancy is growing more challenging as store closing and bankruptcies continue to plague the retail industry. The writing is on the wall, given enough time, regardless of best efforts by the ownership, vacancies will increase, eroding the economic vitality and viability of the Post Mall—eroding Milford’s tax base. This threat is echoed in The demise of America’s

11 See Spinosa, Charles, Flores, Frenando, and Dryfus, Hubert, L., (1997): Disclosing New Worlds: Entrepreneurship, Democratic Action, and the Cultivation of Solidarity. The MIT Press. Cambridge, MA. (P. 30).

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com malls can deal a blow to the towns that depend on them. The article explains, “the coronavirus pandemic is speeding up the demise of America’s struggling shopping malls, which could deal a devasting blow to towns that depend on them.”12 During the collapse of the industrial economy and manufacturing sector, we did not have a crystal ball to see the future of industrial dereliction that would come. However, the collapse of our industrial economy and the abandonment and blight of industrial sites provides a window into the future of retail sites. Industrial decline helped us learn, taught us lessons, and provides us with the knowledge and understanding that complacency, resistance to change, and efforts to maintain and sustain the status quo do not work. The forces that drove industrial decline were more powerful than our ability to overcome the decline. The same is true of the forces that are driving the retail apocalypse. If we are complacent, resist change, or seek to maintain the status quo of retail, we will repeat our failures of the industrial past. From the perspective of community planning, the challenge is not to resist change, but to embrace and manage change.13 Adaptation is the foundation to resilience. Foresight and intentional action are the remedies to complacency and uncertainty. The abandoned sites of our industrial past were in less favorably locations and far less adaptable to new uses than our modern retail sites, structures, and locations.14 In fact, many retail sites, structures, and locations are adaptable and well-positioned to be transformed—this is especially true of the Post Mall site. However, to successfully adapt and reposition these sites requires intentional action. Those who act now—will stay ahead of the collapsing retail- wave that will erode malls into functional obsolescence—to find new hybrid forms and functions are the most likely to succeed. “New products and…services are generated…by knowledge, imagination, innovation, risk, trial and effort…”15 and who are first to “innovate and is lucky will take the market.”16 This application, to amend the SCDD regulations to facilitate a 300 unit multi-family community on the Connecticut Post Mall site is an intentional and proactive step by the Mall ownership to adapt the property to the ever-changing and challenging retail landscape, to create diversity in use and revenue aimed at creating resiliency. The Post Mall ownership is seeking to innovate, to create a hybrid site of retail and residences—compatible uses that are mutually beneficial. Entrepreneurial spirit and efforts are always constrained by governance structures. However, government can also be entrepreneurial, especially local land use planning, a practice and profession that is seeking to move a community

12 The demise of America’s malls can deal a blow to the towns that depend on them, CNBC, June 20, 2020 by Lauren Thomas. 13 Walker, Brian, and Salt, David, (2006): Resilience Thinking: Sustaining Ecosystems and People in a Changing World. Island Press. Washington, D.C. Walker, Brian, and Salt, David, (2012): Resilience Practice: Building Capacity to Absorb Disturbance and Maintain Function. Island Press. Washington, D.C. 14 Note, industrial sites are further burdened by the challenges of environmental contamination and cost of remediation. 15 Deming, W. Edwards, (1984): Out of the Crisis, The MIT Press. Cambridge, MA. (P. 182.) 16 Deming, W. Edwards, (1993): The New Economics: For Industry, Government, Education. Second Edition, The MIT Press. Cambridge, MA. (P. 10).

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com forward and into the future.17 The Milford Planning and Zoning Board can be entrepreneurial and innovative, embracing and managing change by working with the Post Mall ownership to adapt to change and (re)position the Post Mall site as a hybrid space that can and will compete for investment. In fact, there is a symbiotic relationship between retail and housing—retail needs households and households need retail. This is one of the reasons why mixed-use developments have become so common. Allowing residential housing and retail to share the same site provides mutual benefits to both uses.

III. Demographics, Housing, and School District Enrollments Connecticut has been a slow-to-no-growth state for three decades. Job growth has been stagnant and population growth has been anemic. This lack of statewide economic and demographic growth has resulted in changes to Connecticut’s demographics and demographic structure. Unfortunately, these changes are for the worse. It is often said that demographics are destiny. In the case of Connecticut and its communities (including, Milford), the primary outcome of our demographic destiny is that we are aging—growing older. Older populations require more government services, need to be supported by a contracting labor force, and result in fewer young families with children—further reducing the next generation of our labor force. One of the most notable community concerns related to any proposal for new residential housing development is the impact of housing on municipal budgets resulting from new public-school age children generated by new housing units and enrolled in the local school district. This fiscal concern results from the fact that the largest portion of any municipal budget is the Board of Education budget—typically between 55% and 65% of the total municipal budget. In Milford, the Board of Education budget represents 56.9% of the total municipal budget. However, and unfortunately, assumptions related to the number of public school-age children generated by new housing units are higher than the actual number of school district enrollments that result from new housing. For example, it is not uncommon for persons or commissions to assume that each new housing unit produces one, two, or even more school district enrollments. These assumptions result from past experiences, memories of prior generations, and failure to understand that the same social-cultural forces that are contributing to the disruption of retail are also disrupting our communities, government services, and school district enrollments.

17 Many Connecticut communities with malls are innovating and view residential development as a promising and viable use for struggling mall sites. For example, the Enfield Square Mall “plans to add housing to the site” and Town officials are working with the owners (see already facing a rough road in an online world, but the coronavirus pandemic made it even rockier, Hartford Courant, June 22, 2020 by Kenneth R. Gosselin). Another example, a Town official from the Town of Manchester contacted Mike Goman and Don Poland of Goman+York Property Advisors on June 3, 2020 to inform them he reached out to the mall’s ownership regarding the potential for multi-family development (already allowed in zoning) on the Buckland Hills Mall site and for Goman+York to spread the word of this opportunity to potential developers.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Changes in demographics and generational changes to lifestyle are resulting in fewer traditional households and fewer school age children (school district enrollments). For example, some simple calculations can dispel the myth of one or more school enrollment per housing unit. Statewide, Connecticut has 530,612 children enrolled in public schools18 and 1,354,713 households.19 Divide statewide enrollments (530,612) by households (1,354,713) and number of public-school district enrollments equals 0.39 enrollments per household (or occupied housing unit). The same calculation can be applied to Milford. Milford has 21,634 households (occupied housing units) and 5,56620 school enrollments (5,566 / 21,634) or 0.26 school district enrollments per household. Enrollments of 0.39 per household statewide and 0.26 per household in Milford are well below the one or more enrollments per new housing units that is commonly assumed. What is most interesting and more important to understand is that enrollments have been declining for over a decade. In 2008 statewide enrollments were 574,848 compared to 530,612 in 2019 (a loss of 44,236 school district enrollments). In 2008, Milford’s school district enrollments were 7,400 compared to 5,566 in 2020 (a loss of 1,834 school district enrollments or a 24.8% decline). The disconnect between perceived enrollments and actual enrollments, and the declining enrollments, should cause us to pause, think, and ask questions. For example, why are actual enrollments per household so low? Or, why are school enrollments declining? The answers to these questions are found in our demographics, specifically the changes in the demographic structure of our population.21

Demographics and Demographic Structure Before discussing the specifics of demographics, it needs to be stated that the total number of housing units in a community (and proposed new housing units) do play a role in public school enrollments. That is to say, the more housing units a community has, the more capacity a community will have for school-age children. However, the total number of housing units, existing or proposed, are not a primary driver of school district enrollments. School district enrollments are driven more by demographics and the demographic structure (i.e. age, persons per household, married couples/families, etc.) of the population. For example, what this means is that housing units (and the number of bedrooms within housing units) are simply vessels that can and may house school-age children—but there is no guarantee they will. More important, demographics and demographic structure as the driver, for example, means that as a population grows older, the number of births (the total fertility rate) and resultant number of children decrease. Decreasing number of children overall

18 Connecticut State Department of Education, www.http://edsight.ct.gov (2020). 19 United States Census, American Fact Finder, www. https://factfinder.census.gov (2017). 20 Milford Board of Education, Proposed Budget 2020 – 2021. 21 These changes in demographics and demographic structure are also contributing to the changes in retail and shopping behavior of consumers. For example, fewer family-households and fewer children per household, result in fewer apparel purchases for children—growing children who may need new cloths each year.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com typically results in declining school enrollments. Declining fertility rates are the primary driver of low and declining school district enrollments.22 The total fertility rate is the average number of children that would be born by a woman if all women lived to the end of their childbearing years. Since only women have children, and since all women do not live to the end of their childbearing years, the replacement level of the fertility rate is between 2.1 and 2.3 (births per women) to maintain a stable populations—higher rates result in population growth and lower rates result in population decline. Another way of understanding this is to understand how the fertility rate relates to the death rate. The equation for population growth (not including immigration and migration) is births plus deaths equals growth. If births are higher than deaths, the population grows. If births are lower than deaths, the population declines. Table 1. below shows how the fertility rate translates deaths to births. Note that the United States fertility rates is 1.73 and Connecticut’s fertility rate is 1.57. That means, in Connecticut, 27 fewer persons are born for every 100 persons who die. Excluding immigration and migration, given enough time at a 1.57 fertility rate, Connecticut’s population will decline to zero. Table 1. Median Age Fertility Rate Deaths Births Replacement Rate Above Replacement 2.4 100 120 +5 Births = Growth Replacement 2.3 100 115 Stable Replacement 2.2 100 110 Stable Replacement – USA 2.1 100 105 Stable Below Replacement 2.0 100 100 Decline United States 1.73 100 82 -18 Births = Decline Connecticut23 1.57 100 73 -27 Births = Decline Declining fertility rates, nationally and in Connecticut, are not simply the result of an aging population. Declining fertility rates are also tied to, and the result of, increased economic opportunity (wealth), greater education, and the associated changes social-cultural behaviors that come with wealth and education.24 Most important, these structural changes in our demographics can be traced across generations. For example, if you are of the Baby-Boom generation (born between 1946 and 1964),25 it likely that you have more siblings than you have children. It is also more likely, as a Baby Boomer, you moved out of your parent’s home, got married, and had your first child at a younger age than those in Generation X (born between 1965 and 1980) and the Millennial Generation (born between 1981 and 1996). These slow-moving changes in the way-we-live and behave are often hard to notice in real time. However, by studying demographics and social behaviors over time (generation by generation), the

22 PEW Research Center, 2018. The US Total Fertility Rate—lifetime births per women—has declined from 3.6 in 1960 to 1.73 in 2018. 23 www. https://en.wikipedia.org/wiki/List_of_U.S._states_and_territories_by_fertility_rate 24 For example, prioritizing career over childrearing. 25 PEW Research Center, 2018.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com changes become noticeable and their collective impacts can be profound. These changes (and other demographic and social changes) are why Milford’s school district enrollments are substantially declining. Milford is an aging community. In 2000, Milford’s median age was 39.4, increasing to 43.5 in 2010, and in 2017 the median age increased to 44.8—well above the national and state median age (Table2).26 In short, older populations have fewer children, resulting in fewer school enrollments. In addition, older households spend less on goods and services—spend less in retail establishments. Table 2. Median Age USA CT Milford 2017 37.8 40.8 44.8 2010 37.2 40.0 43.5 2000 35.3 37.4 39.4 Milford’s demographic structure over the past three decades has been transformed by the increasing age of the population. In addition, changes in demographic and socioeconomics have transformed household structure. For example, in 1960 only 13.0% of housing units in the United States were occupied by 1-person households. Today, 28% of our nation’s housing stock are occupied by 1-person households.27 The same is true in Milford. Today, 29.6% of Milford’s housing stock is occupied by 1- person households.28 Also notable, 43.7% of Milford’s renter-occupied housing units are 1-person households—that means that 43.7% of rental housing is not producing any school age children or school district enrollments. Another important change can be seen in married-couple households with children (under the age 18). In the United States, from 1970 to 2012, the percent of married-couple households with children declined from 40.3% to 19.6%. Milford is similar. The total family-households with children (under the age of 18) in Milford account for only 24.2% of households. These changes in household structure result from both an aging population and social-cultural trends. Today, compared to decades and generations before, we marry later, marry less, and have fewer children—the answers to Milford’s declining school district enrollments. What is most important and often missed in concerns over new housing the potential for more school age children and increased school district enrollments, is the benefits that young households and children provide to a community. In fact, no community should be pleased about declining school district enrolments or working to restrict young households—young families—from their community. What would a community be without children? How can we even have community without children?

26 All housing, demographic, and socio-economic data provided in this report are sourced from U.S. Census, American Fact Finder (2017) or the U.S. Census 2000 and 2010, unless otherwise noted. 27 United States Census, American Fact Finder, www. https://factfinder.census.gov (2017). 28 United States Census, American Fact Finder, www. https://factfinder.census.gov (2017).

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Children and young families are at the core of community. Little league sports, Girl and Boy Scouts, school talent programs, high school sports, and local parades and celebrations. While this may sound cliché, children are our future. As important, young families, especially renters, are the households that will be the purchasers of existing owner-occupied single-family housing. Without younger households, demand for housing (especially existing housing) will decline, as will property value. Milford, if it wants to remain socially and economically viable, must embrace younger households, families, young children, and school enrollments—the community’s future generations. Housing Characteristics The hard to notice slow-moving changes in demographics and demographic structure also impact housing and the housing market. Milford has 23,571 housing units, of which 21,634 (91.8%) housing units are occupied.29 Milford’s housing stock is 76.4% owner-occupied, 74.3% single-family (detached units equal 68.0% and attached units equal 6.3%), and 59.6% of the housing stock has 3- or more- bedrooms per units (Table 3).30 Owner-occupied housing is typically larger and has more bedrooms than renter-occupied housing. For example, in Connecticut only 5.9% and in Milford 5.4% of renter-occupied housing has four or more bedrooms.31 Most important to understand, it is the larger housing unit size and the housing units with the most bedrooms per unit are more appealing and desirable to families with children. This is the very reason why it should not be a surprise that owner-occupied households have more occupants per unit than renter occupied households. For example, Milford’s owner-occupied housing averages 2.59 persons per unit compared to 2.09 persons per renter-occupied housing unit.32 Simply put, with a 76.4% homeownership rate, 74.3% of the housing stock as single-family, and 59.3% of housing units having 3- or more-bedrooms, Milford’s housing stock has historically favored family-households with children. Today, traditional families and large families with many children are in decline. Table 3. Milford Housing by Bedrooms Bedrooms Units Percent No bedrooms 561 2.4% 1 bedroom 3,186 13.5% 2 bedrooms 5,770 24.5% 3 bedrooms 9,313 39.5% 4 bedrooms 3,946 16.7% 5 or more bedrooms 795 3.4% Source: U.S. Census, American Fact Finder 2017

29 United States Census, American Fact Finder, www. https://factfinder.census.gov (2017). 30 United States Census, American Fact Finder, www. https://factfinder.census.gov (2017). 31 United States Census, American Fact Finder, www. https://factfinder.census.gov (2017). 32 Statewide, Connecticut’s owner-occupied households average 2.67 persons and renter occupied households average 2.32 persons. United States Census, American Fact Finder, www. https://factfinder.census.gov (2017).

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

School District Enrollments The structural changes to Milford’s demographics—specifically median age and household size—are further evidenced when comparing Milford’s recent new housing development and its decade long decline in school district enrollments. For example, from 2008 to 2019 a total of 2,134 new housing units were constructed in Milford for a net gain of 1,926 housing units (after demolitions).33 During that same period, Milford’s school district enrollments declined from 7,400 to 5,566 enrollments (see Table 4.).34 That is a loss of 1,834 enrollments (a 24.8% decline). To put it another way, for every new housing unit added 2008 to 2018, Milford’s school district loss 0.95 enrollments per new housing unit. Table 4. Milford: New Housing Vs Enrollments New Total Total Net Unit School District Permits Units Demos Gain Enrollments 2021 n/a n/a n/a 5,502 2020 n/a n/a n/a 5,566 2019 140 n/a 140 5,635 2018 169 n/a 169 5,792 2017 194 24 170 5,926 2016 178 33 145 6,152 2015 358 0 358 6,278 2014 217 38 179 6,434 2013 189 0 189 6,670 2012 145 30 115 6,836 2011 96 43 53 6,988 2010 96 0 96 7,147 2009 86 20 66 7,326 2008 266 20 246 7,400 Total 2,134 208 1,926 -1,834 This simple comparison of new housing construction to school district enrollments (Table 4) highlights the power of demographic change—the force of demographic structure (i.e. an aging population) over housing production. It also demonstrates that new housing development and new housing units are not a primary driver of school district enrollments. It is also important to note and understand that school district enrollments are not a primary driver of local school board education costs. For example,

33 Connecticut State Department of Community and Economic Development: www.https://portal.ct.gov/DECD/Content/About_DECD/Research-and-Publications/01_Access-Research/Exports-and- Housing-and-Income-Data. It is important to note, especially if persons and commission members assume that multi-family housing drives school district enrollments. The fact is, only 16% of the new housing units constructed since 2008 were single-family detached. 84% of the new units were multi-family housing—and during that time enrollments declined. 34 Connecticut State Department of Education, EdSight (www.edsight.ct.gov), Milford School District, District Enrollments.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com in 2008 the Milford education budget was $103,170,41435 or $13,941 per pupil. In 2020, the Milford education budget was $123,406,98736 or $22,717 per pupil. Therefore, while Milford added 1,926 housing units and lost 1,834 school district enrollments, the education budget increased by $20,236,573 and per pupil spending increased $8,776.37 It is also important, now, to return to the earlier statement that the total number of housing units in a community (including the proposed new housing units as part of this application) do play a role in public school enrollments by adding capacity to the community to house school age children. It is reasonable, based on this statement, to assume persons or the Planning and Zoning Board will raise questions or be concerned that by adding more housing, Milford is increasing its capacity for school age children, and opening the door to future increase—possibly dramatic increases in school district enrollments. To put this concern and the data above in context, at Milford’s current rate of 0.24 enrollments per housing unit, Milford would need to add over 7,500 new housing units to regain the 1,834 enrollments lost since 2008 or the enrollment rate per housing unit would need to increase from 0.24 to 0.34 enrollments per housing unit to return to 7,400 enrollments—or a combination of increased housing units and enrollment rates. The fact is this is highly unlikely in the foreseeable future. The demographic trends are working against a return to past enrollment levels—fertility rates have been in decline for decades and household size will likely continue to decline. While it is likely school district enrollments declines will slow and possibly level out, there is no indication the declines will reverse and increase. For the near term, the next ten years, the demographic structure of the Millennial Generation is working against younger families producing large numbers of school age children (and enrollments), as once was expected. In fact, more than half the Millennials are already over the age 29, the peak age for births. In addition, Millennial births peaked at 11% of women at age 29 compared to Generation X with 12% of women at age of 29. Furthermore, and at same time, Millennial births at age 22 were 9.2% of women compared to 11.3% of Generation X women.38 This shows that Millennials are not, and more than likely will not, produce a large cohort of children that will substantially increase school enrollments. Add to this the fact that the youngest Baby-Boomers are now 56 years old, the population structure should continue aging for the next decade.

35 Connecticut State Department of Education, EdSight (www.edsight.ct.gov), Milford School District, Fiscal Resources. 36 City of Milford, Board of Aldermen Adopted Budget, 2019-2020. 37 Education expenditures, the cost of education, is tied more to inflation and the rising costs of salaries, benefits, and transportation, than it is to enrollments. In addition, declining enrollments increase per pupil expenditures as a result of fixed costs being spread over fewer enrollments. 38 Millennial and Generation X comparisons based on United States Census analysis by the PEW Research Center, 2018.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

IV. New Housing Enrollment Projections Understanding, at the macro-scale of Milford, how demographics and demographics structure are impacting school district enrollments (discussed above) allows us to shift to the micro-scale of the proposed 300-unit multi-family residential development. To accomplish this, we utilize a comprehensive study performed by Rutgers University, Center for Urban Policy Research to estimate the projected school district enrollments from the proposed 300 housing units based on the estimated mix of one, two, and three-bedroom units.

Residential Demographic Multipliers The Rutgers “Residential Demographic Multipliers - Connecticut”39 are utilized to project enrollments from the proposed new housing units. The Multipliers are derived from the 2000 U.S. Census and the demographic fields, differentiated by housing type, housing size, housing price, and housing tenure, have been found by Rutgers to be associated with statistically significant differences in Household Size, School-Age Children, and Public School-Age Children. The multipliers are calculated for new housing, defined as units enumerated in the 2000 Census and built from 1990-2000. It is important to note, while the “Residential Demographic Multipliers” are derived from the 2000 U.S. Census and based on new housing built from 1990-2000, the data is still relevant and meaningful today since our demographic trends related to age, fertility rates, and household structure of continued to slowly trend in the same direction they we in the 1990s. Therefore, if there is a time-related error in the Multipliers, they are over, not under, estimating enrollments. An analysis of the Residential Demographic Multipliers for Connecticut reveals that new housing units, regardless of type and tenure, generate fewer total persons, school-age children, and public school-age children (enrollments) per housing unit than is commonly assumed. This is consistent with the calculations and discussion above that showed statewide, Connecticut’s housing/households produce 0.39 enrollments per household (occupied housing unit) and Milford’s housing/households produce 0.26 enrollments household. The proposed housing development consists of 300 multi-family rental units. The mix of unit types by bedroom, as proposed, is anticipated to include 30 three-bedroom units (10%), 135 two-bedroom units (45%), and 135 one-bedroom units. Based on the mix of units by number of bedrooms and the Rutgers Multipliers for each type of unit, the 300-units are projected to generate 72 total enrollments into the

39 Rutgers University, Center for Urban Policy Research, Residential Demographic Multipliers—Connecticut — Estimates of the Occupants of New Housing: Residents, School-Age Children, Public School-Age Children by State, Housing Type, Housing Size, and Housing Price. 2006.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Milford School District. This equals 0.26 enrollments per unit, which is consistent with Milford’s occupied housing stock (household) enrollment rate 0.26 enrollments per unit.40 Table 5. 300 Housing Units – School Enrollment Projections Housing Units Units Multiplier (1) PSAC (2) N-T-D (3) NTD-E Enrollment (6) One-Bedroom (45%) 135 0.04 5.4 50% 2.70 3 Two-Bedroom (45%) 135 0.25 33.75 50% 16.87 17 Three-Bedroom (10%) 30 1.07 32.1 50% 16.05 16 Totals 300 [0.26] (5) 71.25 50% (4) 35.62 36 Notes: 1) Multipliers: Derived from the Rutgers University, Center for Urban Policy Research “Residential Demographic Multipliers – Connecticut.” 2) PSAC stands for Public School Age Children. It is another way of saying enrollments. 3) N-T-D stands for New-To-District: represents the percent of student enrollments who are projected to be new to the Milford School District—most enrollments from new residential development are associated with students already enrolled in the District. For example, recent studies by the South Windsor Board of Education have shown New-to-District enrollments for new developments equal 21% in 2018 and 30% in 2019. Such findings are consistent with our own research. However, to be conservative, we estimate enrollments at 50% new-to-district. Recognizing the New-To-District enrollments are important to understanding the actual fiscal impact of new residential development. 4) The 50% New-To-District estimate in conservatively high. 5) Milford has 21,634 occupied housing units and 5,566 students enrolled in the school district. That equals 0.257 or 0.26 pupils per household. 59.6% of Avon’s housing stock has 3 or more bedroom. The projected enrollments for the proposed multi-family housing units—with only 10% three-bedroom units—are projected to generate 0.26 enrollments per unit. The same enrollment rate as Milford’s existing occupied housing stock. 6) The total New-To-District enrollments projected from the development. The New-To-District enrollments are estimated at 50% of total enrollments or 36 new-to-district enrollments. The New-To-District enrollments are calculated and presented to highlight the point that every enrollment associated with new housing developments/units do not equal a new enrollment into the school district. Households with school-age children typically move less than those without children. In addition, parents often seek not to disrupt their child’s education by moving districts. Therefore, many enrollments from new housing units are existing enrollments that result from rental shifts within the community. The new-to-district calculation often raises concerns about the potential or likelihood of backfill enrollments in the existing units vacated by the occupants/enrollments associated with the new housing units. While there is the potential for and it is likely that some backfill enrollments will occur into the existing units, it is unlikely that such backfill would occur at the same or even similar rate as

40 The fact the proposed enrollment of 0.26 enrollments per unit is the same as the overall rate of 0.26 enrollments per unit for Milford’s existing housing stock is reasonable, considering only 10% of the proposed units are 3-bedroom, compared to Milford’s existing housing stock with 59.6% of units being 3- or more-bedrooms and aging population.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com the shift in enrollments into the new housing units. The most notable reason for this not occurring is, as discussed earlier, the change in demographic structure and decade-long decline in school district enrollments—especially the comparison of new housing development/units to enrollments in Table 4. In addition, assuming 50% new-to-district enrollments is intentionally high, projecting greater impact than anticipated. The households who occupy housings units are continually in flux with approximately 3% to 5% of households moving yearly. For example, in 2017 there were 546 home sales in Milford, 2.6% of the total housing stock or 3.3% of the owner-occupied housing stock.41 Backfill enrollments are more likely the result of home sales, than a shift in renters. At 0.26 enrollments per household, 546 home sales would have the potential to generate 141 enrollments, far more than the 72 total enrollments from the proposed 300 multi-family units.

V. Municipal Fiscal Impact Analysis Understanding that the proposed 300 multi-family housing units will generate 72 total school district enrollments, of which 36 or 50% will likely be new-to-the-district, provides the starting point for thinking through and calculating the municipal fiscal impacts that will result from the 300 housing units. To accomplish this, this section calculates (and presents) the municipal revenues and expenditures relevant to the Connecticut Post Mall site and the proposed 300 housing units. For revenues, the analysis will consider existing property taxes for the Connecticut Post Mall site, estimated projections for new real property taxes and new personal property taxes (motor vehicles), and sewer connection fees associated with the proposed 300 housing units. For expenditures, the analysis will consider the education costs associated with the 72 total enrollments from the 300 housing units and the cost of general government services associated with the 300 housing units.

Revenues The first step in assessing the municipal fiscal impact is to establish the baseline of current conditions— the existing taxes paid by the subject property. Table 6. below provides the existing conditions and tax revenues paid by the existing Connecticut Post Mall site. The data presented is sourced from the City of Milford assessment records. The Post Mall property consists of 74.86 acres, with 8 buildings, and a total of 1,752,680 square feet of gross building space. The appraised value (market value) is $199,529,450. The assessed value (70% of appraised value) is $139,670,615. Multiplied by the Mill Rate (27.71 or 0.02771), current year tax value (taxes paid) is $3,870,272.

41 CERC Town Profiles, Milford 2019.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Table 6. Existing Property – Tax Value Boston Post Building(s) Appraised Assessed Tax Taxes Taxes Road Acres Units Sq. Sf. Value Value Value /Acre /Unit 1201 74.86 8 1,752,680 $199,529,450 $139,670,615 $3,870,272 $51,700 n/a Notes: - Mill Rate = 27.71 (or 0.02771) - Appraised Value is market value and Assessed Value is 70% of appraised value per CT property tax law. - Tax Value is the assessed value multiplied by the mill rate. - The ‘Unit’ column represents building, not residential units. Malls are “an economic engine, hiring hundreds, if not thousands, of workers and providing a significant amount of dollars to the local tax base.”42 In fact, malls are often the top taxpayers in the communities where they reside,43 as is the case with the Connecticut Post Mall. Ranked as the number one taxpayer in 2019 (and in 2010), the City of Milford Comprehensive Annual Financial Report44 show that the taxable assessed value of the Post Mall property has declined from $176,390,000 in 2010 to $149,099,000 in 2019.45 The percentage of net taxable assessed value decreased from 3.28% in 2010 to 2.27% in 2019. This decline in assessed value and percent of the total grand list demonstrates the weakening position of the Post Mall as a result of the disruption and struggles in the retail sector (as discussed above). Considering recent trends and retail sector forecasts, it is highly probable that the Connecticut Post Mall property, if it remains in its present use and form, will continue to depreciate, as well as the taxes paid by the property. Therefore, the proposed 300-unit housing development is critical to diversifying the property, creating and maintaining value, and ensuring the property remains economically viable. To estimate the initial property value for the 300 multi-family housing units, we utilize the construction cost approach to value, adjusted down for soft costs.46 Our assumptions, calculations, and estimates for the appraised, assessed, and tax value of the 300 multi-family housing units are provided in Table 7. We estimate an appraised value $56,801,160, an assessed value of $39,760,812, and a tax value of $1,101,772 (the taxes to be paid per year).

42 The demise of America’s malls can deal a blow to the towns that depend on them, CNBC, June 20, 2020 by Lauren Thomas. 43 The demise of America’s malls can deal a blow to the towns that depend on them, CNBC, June 20, 2020 by Lauren Thomas. 44 City of Milford, Comprehensive Annual Financial Report: Fiscal Year Ending June 30, 2019, Prepared by, City of Milford Finance Department. 45 The depreciation amounts to a total of $27,291,000. However, adjusted for inflation, the 2010 value of $176,390,000 is equal to $206,806,225 in 2019 dollars. Therefore, adjusted for inflation, the Connecticut Post Mall property lost $57,707,225 in value. 46 In utilizing the construction cost approach to value, we recognize that once the property is developed, occupied, and stabilized, it is likely that the City of Milford’s Assessor will utilize the income approach to value. At this preliminary point in the approval process, we do not have detail of development costs needed to estimate the income approach.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Table 7. Proposed New Units – Tax Value Boston Post Building(s) Appraised Assessed Tax Taxes Taxes Road Acres Units Sq. Sf. Value Value Value /Acre /Unit 1201 74.86 300 315,562 56,801,160 $39,760,812 $1,101,772 $14,717 $3,672 Notes: - Building square feet assumes the 1-bedroom units are 750 Sq. Ft., 2-bedroom units are 1,075 Sq. Ft., and 3- bedroom units are 1,350 Sq. Ft. An additional 10% of building area is added to account for common areas. - Appraised Value (market value) utilizes the construction cost approach to value. Total construction is estimated at $225 per square foot and is then reduced to 80% of the total ($180/Sq. Ft.) to account for soft costs that do not contribute to real property value. - Mill Rate = 27.71 (or 0.02771). The new value added to the Connecticut Post Mall property from the new housing units is substantial and equal to the inflation adjusted property value depreciation since 2010. The estimated $1,101,772 in new taxes to be paid to the City of Milford is also substantial, equal to 28% of the $3,870,272 in taxes paid by the present property. This new property value and taxes paid will go a long way toward stabilizing the Connecticut Post Mall property and City of Milford Grand List in the near term. In addition to the real property taxes to be paid by the 300 multi-family housing units, the City of Milford will also receive personal property tax revenue from the motor vehicles owned by the occupants of the housing units. For taxable property purposes, we estimate a total 450 motor vehicles to be associated with the 300 residential units (or 1.5 vehicles per unit). Table 8 provides the assumptions, calculations, and estimates for the appraised, assessed, and tax value of the 450 motor vehicles. This result is a conservative estimate of $113,472 per year in personal property taxes to be paid to the City of Milford. Table 8. Proposed Development – Personal Property Tax (Motor Vehicles) Motor Total Housing Vehicles Motor Assessed Mill Total Taxes Units Per Unit Vehicles Value Rate Estimated Taxes Per Vehicle 300 1.5 450 $4,095,000 27.71 $113,472 $252 Notes: - The Milford Zoning Regulations (Sec. 5.1.4 Off-Street Parking Requirements) currently require 2 parking spaces per 1-bedroom unit and 3 parking spaces per 2- and 3-bedroom units. Based on the proposed unit mix of the 300 units, zoning will require 765 parking spaces. We believe the required parking is much higher than the actual vehicles to be associated with the 300-units. - To calculate the total number of motor vehicles (for tax purposes) associated with the 300 residential units, we utilize a ratio of 1.5 motor vehicles per unit (300 units x 1.5 = 450 motor vehicles). - Specific data related to the average appraised value of motor vehicles in Milford was not found in the City of Milford financial statements. Therefore, based on our experience, research, and similar assignments in dozens of CT communities, we estimate the appraised value of motor vehicles at $13,000 and the assessed value at $9,100 per motor vehicle.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

The proposed 300 multi-family housing units are projected to generate approximately $1,101,772 in new real property tax revenues. In addition, the 450 motor vehicles are projected to generate approximately $113,472 in new personal property tax revenue. Combined, the new real and personal property taxes will contribute an estimated $1,215,244 in revenues to the City of Milford. This will increase the tax revenue generated from the Connecticut Post Mall property from $3,870,272 to $5,085,516, a substantial and positive increase in revenue (see Table 9 below). Table 9. Existing and Proposed Properties – Tax Value Boston Post Building(s) Appraised Assessed Tax Taxes Taxes Road Acres Units Sq. Sf. Value Value Value /Acre /Unit 1201 74.86 8 1,752,680 $199,529,450 $139,670,615 $3,870,272 $51,700 n/a 1201 74.86 300 315,562 56,801,160 $39,760,812 $1,101,772 $14,717 $3,672 Total 74.86 300 2,068,242 $256,330,610 $179,431,427 $4,972,044 $66,417 n/a Personal Property 450 Motor Vehicles $5,850,000 $4,095,000 $113,472 n/a $252 Combined Total $5,085,516 Notes: - Mill Rate = 27.71 (or 0.02771). - The 300 multi-family units and 450 motor vehicles will add an estimated $1,215,244 in tax value to the Connecticut Post Mall property and payments to the City of Milford.

Expenditures - Education The Milford Board of Education Operating budget totaled $95,078,487 for the 2019 – 2020 budget year.47 In addition, the City of Milford contributes an additional $28,328,500 toward education expenditures for a total education budget expenditure of $123,406,987.48 To estimate the cost of enrollments resulting from the proposed 300 multi-family units, we make four calculations aimed at estimating the actual cost of new per-pupil enrollments, rather than the common and misleading calculation of total per-pupil spending.49 Table 10 provides a summary of these calculations and detailed notes to explain the specifics of the calculations.

47 Milford Board of Education Adopted Budget, 2019-2020. 48 City of Milford, Board of Aldermen Adopted Budget, 2019-2020. 49 The reason the total expenditures per-pupil spending is misleading, is that it assumes each new enrollment will include an increase in all cost. This is not the case, many educations costs are fixed and do not change based on enrollments.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Table 10. Projected Enrollments & Education Expenditures BOE Expenditures Per Pupil Total PSE Total Cost N-T-D N-T-D Cost Total Expenditures $22,717 72 $1,635,624 36 $817,812 Local-Share Expenditures $18,092 72 $1,302,624 36 $651,312 Allocated Expenditures $10,855 72 $781,560 36 $390,780 Calculation Notes: - Total Expenditures is the BOE budget dived by the total enrollment. BOE Operating budget 2019-20 = $95,078,487 plus the City of Milford share of $28,328,500 for a total of $123,406,987 / October 1, 2019 enrollment of 5,566 = $22,717 per pupil. - Local-Share Expenditure is the per pupil expenditures less non-local tax revenues (federal, state, and other revenue sources). Milford’s total 2019-20 budget is $216,550,313. However, local property tax account for only $176,798,053 of the total revenues or 81.6% of total revenues. Therefore, to calculate the fiscal cost of education related to property taxes, the Local-Share Expenditures for education cost per pupil are reduced to 81.6% of the Total Expenditures ($22,717) or $18,092 per pupil. - Allocated Expenditures is based on a general analysis of the BOE budget that isolated approximately 40% of the budget that is unlikely to be impacted by changes in enrollment (For example, district office expenditures, school administrative offices, utilities, building operations and maintenance, prorated staffing, etc.). Therefore, the Local-Share Expenditure is reduced by 40% to provide for the Allocated Expenditure. This approach is conservative compared to other approach that would allocate new resources and staffing per new pupil. - N-T-D (New-To-District) represents the portion or percent of student enrollments who are anticipated to be new to the Milford School District. Our research and other studies show that student enrollments generated by new housing development are not all new enrollments into the school district. In fact, most enrollments from new housing development are existing enrolled students who have relocated within the district. A recent study by the South Windsor (DRG-B District) Board of Education revealed that New-to-District enrollments for new multi-family residential developments ranged from 21% in 2018 to 30% in 2019. New-To-District enrollments are important to understand and need to be factored into any calculations of fiscal impacts. - To account for the New-To-District enrollments, we conservatively estimate that 50% or enrollments will be new-to-district.

Expenditures – General Government To estimate general government expenditures associated with the proposed 300 multi-family housing units, we isolate those portions of the budget that can be attributed to residential uses by a process of elimination. For example, we have already accounted for (isolated) education expenditures, or $123,406,987 of the $216,550,313 by allocating the education expenditures to fiscal impact of school district enrollments discussed above. That accounts for 56.9% of the total City of Milford budget.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

To further isolate portions of the budget, we note that in 2019 commercial and industrial properties accounted for approximately 20% of the total Grand List.50 It is commonly understood that commercial and industrial land uses are fiscal positives regarding municipal tax revenue and expenditures. For example, a 2012 study published by the American Farmland Trust and Connecticut Conference of Municipalities51 showed that commercial and industrial land uses require, on average, only $0.27 in community services for every $1.00 generated in tax revenue. Therefore, commercial and industrial properties pay-their-own-way. In addition, commercial and industrial properties further subsidize the residential tax burden. As a result of this, we can account for and deduct 20% of the Milford budget that is funded by commercial and industrial property tax revenues. Combined with education expenditures (56.9%), commercial and industrial properties (20%), a total of 76.9% of the municipal budget expenditures can be accounted for, leaving 23.1% of Milford’s budget to be allocated exclusively to the residential share of general government services/expenditures. Therefore, we allocate $280,710 of the $1,215,194 in real and personal property tax revenues generated by the proposed 300 multi-family housing units to the cost of general government services (expenditures).

Municipal Fiscal Impact The fiscal impact findings and conclusions, based on the analysis and assessment presented above, are straight forward. The existing Connecticut Post Mall property is a fiscal positive for the City of Milford. The Connecticut Post Mall is Milford’s largest taxpayer. In addition, Post Mall contributed approximately $3,870,272 in tax revenues to the City of Milford last year. Unfortunately, the Connecticut Post Mall’s property has been depreciating as a result of the contracting retail sector, which has negatively and disproportionately impacted large enclosed malls. The property owners are seeking to innovate, to transform, (re)position, and diversify the property and income producing asset classes on the property. The proposed 300 multi-family housing units are a substantial investment in this property that will add value to the existing property, while creating economic vitality and sustainability. The proposed housing units will generate an additional $1,215,244 in real and personal property tax revenue, bring the total tax revenue to $5,085,516. Below, Table 11 (Municipal Fiscal Impact – Revenues & Expenditures), provides the calculation for the fiscal impact of the proposed 300 multi-family housing units. The calculations for revenues include real property taxes ($1,101,772), personal property taxes ($113,472), and sewer connection fees ($98,640). The expenditures include both education and general government services. General government expenditures are estimated at 23.1% ($280,718) of real and personal property tax revenue. The

50 City of Milford, Comprehensive Annual Financial Report: Fiscal Year Ending June 30, 2019, Prepared by, City of Milford Finance Department. 51 American Farmland Trust and the Connecticut Conference of Municipalities, (2012): Planning for Agriculture: A Guide for Connecticut Municipalities. Connecticut.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com education expenditures are presented in the table as Allocated and New-To-District. The aim of this presentation of revenues and expenditures is to not use the misleading Total Expenditures (or Local Share) which falsely assume all costs to new enrollments. Therefore, the Allocated and New-To-District education expenditures are utilized to better represent the actual costs of new student enrollments created by new residential development. Based on this approach, we find and estimate a positive fiscal impact of $642,974 and no less than $251,614. Table 11. Municipal Fiscal Impact – Revenues & Expenditures Revenues & Expenditures Total Revenues Real Property Taxes (300 Units) $1,101,772 Personal Property Taxes (Motor Vehicles) $113,472 Sewer User Fee ($328.80/unit/year) $98,640 Total Revenue $1,313,884 $1,313,884

Expenditures Allocated N-T-D/Allocated Education Expenditures $781,560 $390,200 General Government (23.1% real property taxes) $280,710 $280,710 Total Expenditures $1,062,270 $670,910 Municipal Fiscal Impact $251,614 $642,974

V. Economic Impact Job Creation & Wages The aim of our economic impact assessment is to provide the Planning and Zoning Board with reasonable estimates for job creation and overall economic impact from the proposed 300 multi-family housing units. It has long been known, going back to ‘The New Deal Era,’ that housing is a key driver in our economy. Housing construction creates jobs and households generate consumer spending. Research has shown that new housing positively impacts the local economy. For example, a study by the National Association of Home Builders (2015) found that the construction of 100 multi-family units creates 165 jobs, $14.5 million in wages, and $2.4 million in taxes & fees in the first year. In the second year (and beyond), the study found on average each 100 housing units creates another 52 jobs. Using these findings as multipliers, we can estimate the economic impact of 300 multi-family units. It would be easy to simply triple the finding of the NAHB report and provide high or strong economic impacts. However, we believe that economic impacts typically overestimate and project higher than actual economic outcomes. In addition, based on our experience and understanding of Connecticut’s real estate market, development costs, and overall condition of the Connecticut economy, we adjust the NAHB numbers to better reflect Connecticut. Job growth (creation) has been sluggish in Connecticut for decades. Therefore, we are not comfortable with the NAHB 165 jobs created and will reduce to 124 jobs created (or 75% of NAHB) in our calculations. We do not calculate taxes and fees

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com since those were already addressed above in the municipal fiscal impact analysis. As for wages, even though Connecticut’s median household income is 15% higher than the national median household income, we reduce the wages by 20% to $11.6 million based on our understanding of construction and labor costs and recognition that the household income of renters is typically lower than that of owner- occupied households. Based on these adjustments, we estimate the construction of 300 multi-family units will create 372 jobs52 and $34.8 million in wages in the first year. In the second year (and beyond), we estimate the 300 housing units will create (or sustain) 117 jobs53.

Consumer Spending Consumer spending is another way to think about the economic impacts of new housing and households. To estimate the consumer spending impact of new housing, we use discretionary income. Based on figures from several sources,54 we estimate that between 25% and 35% of household income is available for discretionary spending. Based on the average rental value of the 300 housing units, we estimate the average household income to be approximately $55,000. Assuming 30% of household income is discretionary, we further estimate that approximately $16,500 per household income is available for discretionary spending. That totals $4,950,000 in discretionary spending for the 300 households. Last, we assume and estimate that only 25% of household discretionary spending will be spent in the local community (within Milford), recognizing that our lives stretch across metropolitan space. That 25% in local discretionary spending totals $1,237,500 in consumer spending at local businesses per year.

Economic Impact We find and estimate that the proposed 300 multi-family housing units will have a positive economic impact on the local (Milford) economy. This impact includes 372 jobs created (or sustained) in year one and an additional 117 jobs created (or sustained) in year two and following years. In addition, the

52 The calculations for job creation in the NAHB study utilizes an all-inclusive approach or what can be called a ‘commodity chain’ approach to economic impact and job creation. That means the calculations include the positive economic impacts and jobs created and sustained for suppliers of materials, transportation of materials to the site, on-site construction, and the ripple effects offsite during construction. This approach also includes the positive impact on jobs related to soft costs associated with the development. For example, architects, engineers, and other professionals involved in the design, entitlements, and general management of the development from inception to completion. 53 The calculation for the second-year job creation in the NAHB study is also all-inclusive. That means the calculations include the on-site job creation and the ripple effects offsite. For example, this includes jobs associated with property management, contracted property maintenance, and the jobs created and sustained in the community by consumer spending of the residents. 54 Sources include, The Site to Do Business, ESRI Tapestry, US Census data, government reports, and other studies.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com economic impact includes approximately $34.8 million in wages and an estimated $1,237,500 in local (within Milford) consumer spending. Appendix I. Methods and Sources

This report is intended to provide a municipal fiscal impact analysis for the proposed 300 multi-family housing units on the Connecticut Post Mall site. Specifically, the report is aimed at estimating and projecting potential municipal fiscal/tax impact (positive or negative) on the City of Milford and other economic impacts. To accomplish this, the following approach and method was utilized: Market Assessment: While not presented in this report, a general review of existing market conditions was conducted. This market assessment included a review of existing rental property listings/rates and municipal tax assessment data for other rental properties. In addition, the market assessment, we also reviewed demographic and socio-economic data. Sources included, US Census, American Fact Finder, CERC Town profiles, ESRI Tapestry, STDB (The Site to Do Business), and ULI real estate publications. The primary focus of this market assessment was to understand the general characteristics of the local and regional housing and retail market. Sources: AdvanceCT, Town Profile – Milford 2019, https://www.advancect.org/advancing- business/data-information/town-profiles/. U.S. Census (2018), https://factfinder.census.gov The Site to do Business for Commercial Real Estate Professionals, https://www.stdb.com/ Existing Site: The Connecticut Post Mall is located at the intersection of Route 1 (Boston Post Road) and Interstate I-95 (Exit 39). The site consists of 74.86 acres with 8 buildings totaling 1,752,680 square feet of retail space. The subject property was visited on February 16, 2020. This site visit included a general inspection of the site and surrounding area and proximity and access to the interstate highway. Google Earth Pro was further utilized to inspect and become familiar with the site, the general area, and other properties. The City of Milford online assessment database, Plan of Conservation and Development, and Zoning Regulations were also reviewed. Proposed Multi-Family Housing: This review included the conceptual site plan and unit/bedroom mix. In addition, we reviewed market data to estimate construction costs and anticipated market values. In addition, we relied on our professional experience, knowledge, and understanding of real estate market. Construction cost estimates, market value, and tax assessments are converted to per square foot and/or per unit values to allow us to equalized comparison. To test our assumptions and approach we compare our work with best practices

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com and ULI publications. In addition, we rely on the work and publications of Professor Robert Burchell, of Rutgers University, as background sources and methods for our fiscal impact analysis. Sources: Brett, Deborah L., and Schmitz, Adrienne, (2009): Real Estate Market Analysis: Methods and Case Studies. Second Edition. Urban Land Institute. Washington, D.C. Burchell and Listokin, The Fiscal Impact Handbook, New Brunswick, , Center For Urban Policy Research, 1978. Burchell, Listokin, and Dolphin, The New Practitioners Guide to Fiscal Impact Analysis, New Brunswick, New Jersey, Center For Urban Policy Research, 1985. Burchell, Listokin, and Dolphin, Development Impact Assessment Handbook, Washington, DC, Urban Land Institute, 1994. Miles, Mike E., Berens, Gayle L., Eppli, Mark J., and Weiss, Marc A., (2007): Real Estate Development: Principles and Process. Fourth Edition. Urban Land Institute. Washington, D.C. Fiscal Impact of Public-School Age Children (Enrollments): To conduct the analysis of fiscal impacts related to public school age children, the Rutgers University, Center for Urban Policy Research “Residential Demographic Multipliers for Connecticut” are utilized. These multipliers are a trusted source of data/multipliers for public school age children generated by new housing development. To ensure the generalized multipliers work for the local municipality, a few calculations are made to cross-check the data. For example, dividing the actual school district enrollment by the number of housing units to establish a baseline for enrollments per unit. In addition, we make further calculations using U.S. Census data on housing occupancy, single-person households, family-households, family-households with children, and age cohort data to calculate the approximate number of enrollments per unit for both owner- and renter- occupied housing. In addition, we continually our calculations to previous studies we have conducted to ensure there is no excessive variation. We also conduct post-development reviews on out calculations—once a project is occupied and stabilized, we test our projected enrollments with the actual enrollments. Other sources used in this process include the State Department of Education District Profiles, the EdSite data sets, local enrollment studies, BOE, and municipal budgets. Sources: Connecticut, State of, Department of Education, EdSight, http://edsight.ct.gov, Milford 2008-2019. Connecticut, State of, Department of Economic and Community Development, Annual Construction Report (Housing Permit Data) 1997-2019, www.ct.gov/ecd/cwp/view.asp?a=1106&q=250640. Milford, Board of Education, Adopted Budget 2019-2020.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Milford, City of, Assessment Records, 2020. Milford, City of, Board of Alderman Adopted Budget 2019-2020. Rutgers University, Center for Urban Policy Research, Residential Demographic Multipliers for Connecticut, 2006. Job Creation: For calculating job creation and consumer spending, we utilize multipliers, based on a well-recognized study by the National Association of Home Builders. The study found that the construction of 100 multi-family units create 165 jobs, $14.5 million in wages, and $2.4 million in taxes & fees in the first year. In the second year (and beyond), the study found on average each 100 housing units create another 52 jobs. Source: National Association of Home Builders, (2015): The Economic Impact of Home Building in a Typical Local Area: Income, Jobs, and Taxes Generated. This approach and method recognize fiscal impacts, especially municipal fiscal impacts, as more of an art than a science. Many factors and variable influence development, demographics, socioeconomics, public policy, and local fiscal impacts of new development. Therefore, this approach is intended to provide reasonable estimates of the fiscal impacts resulting from the specific development. To say it another way, these are reasonable projections and estimates, not forecasts or predictions of actual numbers or dollars.

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DONALD J. POLAND, PHD, AICP SENIOR VP AND MANAGING DIRECTOR, URBAN PLANNING PHONE: 860.655.6897 – E-MAIL: [email protected] – www.gomanyork.com

Statement of Qualifications – Expert Witness My name is Donald J. Poland, PhD and I am an urban geographer and professional planner with twenty-five years’ experience in land use planning, community and economic development, and market and development feasibility. I have worked in public, private, non-profit, and academic sectors as a municipal planning director, zoning enforcement official, planning consultant, executive director/CEO, and as a university lecturer and professor in human geography, urban planning, and tourism. I earned my PhD in the Department of Geography, Cities and Urbanization program at UCL, London, England. My doctoral dissertation explored the remaking of urban space through the utilization of urban-ecological theory and metaphors to better understand how places change. I also earned a Master of Science in Geography, concentrating in planning, from Central Connecticut State University (CCSU) and a Bachelor of Arts degree, majoring in both Psychology and Geography, from CCSU. As a planning professional, I’m a member of the American Institute of Certified Planners (AICP) and a Certified Zoning Enforcement Official (CZEO). I have been accepted as an expert witness in the areas of land use planning, neighborhood redevelopment, and community development in the United States District Court, Eastern District of Louisiana. I have also been accepted as an expert witness in the Circuit Court of St. Louis County, State of Missouri. Over the course of my career, I have held the positions of Zoning Enforcement Official for the Town of East Hartford (1996-1998), Director of Planning and Development for the Town of East Windsor (2000-2004), and Executive Director/CEO for the Neighborhoods of Hartford, Inc. Since 2008, I operate a boutique planning consulting practice and have worked on assignments in 15 states and over 100 local jurisdictions. This work includes post-Katrina planning, zoning, and redevelopment strategies in St. Bernard Parish, Louisiana; an HUD NSP-2 application and reinvestment strategy for Venango County, ; zoning regulation modernization and updates as part of the 2016 Comprehensive Plan for Canton, Ohio, Canton, Ohio; a downtown economic investment strategy for Oswego, , and countless municipal planning and zoning assignments in Connecticut. In addition, I have also represented dozens of real estate developers before public agencies for commercial, residential, industrial, and mixed-use development projects— including market research, financial feasibility, project viability, and municipal fiscal impact analysis. I’m a Past-President of the Connecticut Chapter of the American Planning Association (CCAPA) and Past Chairman of the CCAPA Government Relations Committee. I have also served on APA’s Chapter Presidents Council, the Executive Committee for the CT Association of Zoning Enforcement Officials, the Board of Trustees for the CT Trust for Historic Preservation, the Board of Trustees for the Bushnell Park Foundation, and was a public member of the State Board of Examiners for Professional Engineers and Land Surveyors. In addition, I have assisted the CT General Assembly’s Planning and Development Committee with bill screening and drafting legislation. I also participated in the creation of the American Planning Association’s development of a smart growth policy guide and was a member of the National Delegates Assembly (for the Smart Growth Policy Guide). As an academic, I have taught over a dozen courses in human geography, urban planning, and tourism at Saint Joseph University, Manchester Community College, Central Connecticut State University, the University of Connecticut, and Trinity College. I held the position of Visiting Lecturer in Public Policy, Graduate Studies Program at Trinity College, Hartford, CT and Associate Professor, Tourism and Hospitality, at CCSU. I was awarded the CT Homebuilders 2003 Outstanding Land Use Official Award and am a 2004 alumnus of the Hartford Business Journal’s Forty Under Forty leaders.

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