The members of the Wall Street Neighborhood Association (“WSNA”) have read and are in unanimous agreement that the foundation of the Wall Street – West Avenue Redevelopment Plan (“the Plan”) is flawed and grossly inaccurate. As such we strongly recommend the Norwalk Redevelopment Agency (“NRA”) Commissioners reject the Plan outright for reasons noted below.
The foundation of the Plan relies upon Connecticut General Statute Chapter 130, Section 8-125(7). This Statute requires a determination of blight for at least 20 percent of the buildings in a potential Plan area. If that threshold of blight is met, or exceeded, then the NRA has the authority to request control over this area with the express intent of mitigating the blighted condition within the Plan area.
Link to Statute: https://www.cga.ct.gov/2015/pub/chap_130.htm
The NRA hired RPA (Regional Planning Authority) to make blight threshold determinations within the Plan area. RPA found that 53 percent, or 205 properties within the Plan area to be blighted. A link to this report is below.
WSNA rejects these finding based on, but not limited to, the following grounds:
- Scope of Work – No actual inspection of properties was undertaken as many of the properties noted in the RPA report have been significantly renovated or demolished and redeveloped. Examples include Head of the Harbor South, Waypointe, 38 Orchard St., Quincy Lofts and the Wall Street Theater.
- Actual Blight – The Norwalk Building Department, by city ordinance is the only certified Blight enforcement officer and therefore the only City authority to determine Blight. The Blight Ordinance has been very effective. Once the Building Department issues a genuine Blight warning or violation then the issues are resolved quickly in most cases. Neither the RDA or RPA consulted the Building Department to prepare the Plan. The Building Department currently classifies three (3) properties in the proposed RDA Plan Area as blighted. RPA claims that 205 properties are blighted in the Plan Area.
- Owner Notification – None of the property owners that RPA identified as blighted in their plan have been notified. They have not been given the opportunity to dispute or rectify the Blight finding. Notification is a clear requirement in the blight statute.
- Flawed Analysis – The Blight Statute lists 13 criteria that can be used to determine blight. RPA only used 3 criteria (bold type below). Their methods are highly suspect based on the following:
- Brownfields – RPA sites 29 properties as brownfields. This is based on the prior or current uses. However, in most cases no actual analysis has been done. It should be noted that any gas station or auto repair facility is considered a Brownfield by certain state/federal laws. They do not automatically constitute blight in their current form.
- Suspected Lead Paint – RPA cites any building built prior to 1978 and not having undergone a substantial renovation as automatically blighted! In this case the Plan area has 147 buildings duly cited. Consider that the bulk of the housing in the Northeastern section of the United States was built prior to 1978. Does that mean the residential neighborhoods of Greenwich, Dairen, Westport, or all of Norwalk’s residential areas are blighted? RPA did no actual inspections or testing to determine if lead paint was present or in a deteriorated condition. Presence of lead paint does not by itself automatically make a building blighted. Commercial and Industrial properties have very different standards than residential.
- Potential Flood Blight – While the other reasons for blight noted above are questionable, this one really stands out. RPA contends that there is the potential for 44 total properties located along the Norwalk River to become blighted by contamination during times of flooding. Not that they are currently blighted since no analysis has been done, but that they could potentially be blighted.
- Common Sense – one need only walk or drive around the Plan area to see that many of the buildings have been upgraded and improved over the past decade by the private sector. In fact NRA notes that in the Plan. Every owner of every blighted property in the RPA plan should be notified and allowed to contest this designation for moral and economic reasons.
Based upon our finding we believe it is incumbent that the Commissions of the Redevelopment Agency reassess NRA staff’s reasoning for requesting such extraordinary regulatory control, particularly when no such control is needed.
Wall Street Neighborhood Association board
Nancy McGuire – Austin McGuire Company
Marc Allen – Factory Underground
Sherri Gallina – Yoga 203
Dana DiElsi – The Silk Touch
Frank Farriker– The Wall Street Theater
Michael McGuire – Austin McGuire Company
Jason Milligan – Milligan Realty
The Common Council Planning Committee is scheduled to consider the Wall Street-West Avenue Redevelopment Plan at its Thursday meeting in City Hall, expected to begin at 6:30 p.m. in Room 330. A revised version of the plan was scheduled to be posted Tuesday on the City’s and the Norwalk Tomorrow website, but has not yet appeared.