Opinion: Wall Street–West Avenue Redevelopment Plan should be rejected

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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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. 


Milly February 6, 2019 at 6:38 am

Yesterday once again at the ibntersection of East Wall St and Wall St the city trucks and jacobs sewage were down the sewers- this is because of those new apartments that were built. Numerous times these trucks have been there. It is obvious the waste system cannot handle all the waste water that huge apartment complex is generating. On West Ave where those huge apartment complexes were built on both sides of the road they are once again digging the street up! The system cannot handle all this waste. And the city wants to allow a huge one at the East Norwalk train station – this is all going to end in a disaster. Plus where is all this water going to come from?

Jason Milligan February 6, 2019 at 9:03 am

Please explain why the Redevelopment Agency is creating a new plan now? They are supposed to redo every 10 years. They have 5 years before another plan is due…

It is the POCD that is due for its 10 year update!

The RDA has confused and tainted the POCD process. RDA is supposed to comply with and support the POCD. That is impossible when the RDA has inserted themselves so deep in the POCD process and they have simultaneously promoted 2 competing plans. The Wall/West Plan and the Innovation District, which they are trying to rebrand under some other name.

The absolute right thing to do is to let the POCD process play out without RDA interference and confusion. Once the POCD is done then the RDA could read it, absorb it and then work on an early update to their plan area that is 100% aligned with it.

RDA please put the POCD horse back in front of the RDA cart.

Jason Milligan February 6, 2019 at 9:53 am

Without measured provable “Blight” there CANNOT be a Redevelopment Plan area anywhere in CT.

So far the only measured proven “Blight” in the Wall/West area are the 3 properties cited by the Norwalk Blight Enforcement Officer, The Building Department.

Ironically 2 of the 3 legitimate instances of “Blight” in the area are related to POKO which the RDA has controlled since 2004.

The only other instance of blight is a rotting and dangerous front porch that the owner has already created a plan and budget to fix.

Blight is not a meaningless adjective. “Blight” is clearly defined by Connecticut Statute. The City and RDA would be well advised to brush up on the statute, and the definition. “Blight” is what gives The Redevelopment Agency its existence.

Ironically as “Blight” is eliminated, so is the need and authority of the RDA. That may be why the RDA has hired a consultant to fabricate outrageous amounts of “Blight” in the proposed Wall/West plan area.

At what point is it fraudulent to fabricate “Blight”?

At what point is the RDA, City Council etc. culpable in the charade to keep the Redevelopment Agency in existence?

There are 205 properties currently labeled by the consultant as “Blight”. I wonder if any one of the 205 property owners will bring an injunction lawsuit against the council if they try to approve a plan with questionable (fraudulent?) “Blight” determinations?

I know that I would not like any of my properties labeled as Blighted. In fact, shortly before I acquired several of the POKO properties there were “Blight” warnings issued. Within days of my ownership the “Blight” was resolved.

The Blight ordinance is working. Hopefully the fines will motivate Citibank to cleanup their eyesore soon.

Piberman February 6, 2019 at 10:53 am

Does anyone at City Hall or beyond ever read the extensive economic literature on how successful City wide redevelopments have been achieved by the tens of thousands all over our nation ?

Hint. It’s not done “block by block” in the Norwalk style.

Does anyone in City Hall ever visit Stamford and ask how they redeveloped into CT’s only real City ?

Hint: It wasn’t done “block by block”.

Reminds one of the old adage: “There are none so blind who cannot see”.

So much energies spent locally on redeveloping our taudry and shabby Downtown. With so little to show for our efforts. Reading the literature on redevelopment is a good first step. Followed by electing officials who have read the literature !

Adam Blank February 6, 2019 at 11:02 am

I do not know the nuances on funding but it has been my understanding that a finding of blight is necessary for plan approval and plan approval is necessary to open up State and Federal funding for development of this area. Can someone put some context on the money that would be made available to this area if the plan is approved v. if the plan is not approved? If we are talking about significant money I’ll take that and let you call anything you want blight.

Jason Milligan February 6, 2019 at 11:16 am


You are an attorney and former chairman of zoning. Have you read the statute? Are you suggesting that knowingly lying or misleading the State of CT is acceptable?

I am shocked at your rationale. You don’t care what the RDA or City has to do to get the money, just get the money?

If you lie on a personal loan application you can obtain substantially more money from a bank. Just tell them that you make triple the amount of money that you actually do.

Similarly a fraudulent appraisal that overstates the value of your house could get you a much bigger mortgage.

Obviously both of these practices are illegal.

Those practices are in the same category as fabricating blight to rip of the State of CT taxpayers.

Please read the statute and consider amending your commentary?

Debora Goldstein February 6, 2019 at 11:26 am

Adam, here are the HUD grant figures: https://www.hudexchange.info/grantees/norwalk-ct/

But I find your premise insulting. Residents and Business-owners have a right to be protected from unreasonable seizure of their assets. Even if the assets are poorly maintained. And communities that actually NEED these HUD funds to mitigate real “slums” and “blight” will suffer if we take funds we don’t really need.

Unfortunately, everyone is confusing Federal Authority with local authority. The local blight ordinance enforcement has nothing to do with the qualification of properties as “slums” or “blighted” for the purposes of qualifying for HUD funds.

Here in Norwalk, becoming part of the RDA area is a little like Hotel California. You get in, but you never get out. Before expanding it any further, the City should do a full analysis of the performance of the RDA in the areas it already operates to see how many tracts can come out because they’ve been fully transitioned away from “slums” or “blight”.

It should seriously reconsider putting an area under RDA that is demonstrably on the upswing. And it should not undertake this at all, until it has resolved its own contributory element – the POKO project.

Adolph Neaderland February 6, 2019 at 11:58 am

Jason Milligan is right on – POCD and our Redevelopment Agency are on an unfortunate and unwarranted crash course, apparently aided and supported by our city governance.

Setting aside the issue of whether Redevelopment has done their homework, (the West Ave Association makes the case that they have not), does it really make any sense (other than to provide Redevelopment a reason to exist), to have an entire city engage in a mandated opportunity to decide it’s future, to be second guessed by a semi autonomous agency.?

A week or so ago, the plan proposed by Redevelopment was roundly opposed by participating stakeholders for a litany of reasons, conflict with POCD and the definition of blight topping the list.

Was the city listening?

Secondly, if a new or revised “Plan” is being proposed, that Plan should be made available with adequate time for review and comment prior to submittal.

Michael McGuire February 6, 2019 at 12:32 pm


Interesting point. Jason’s comments aside, my first questions would be – what is the money for? and who controls it?

The “what is the money for” question begs another question. Do developers really need tax payer subsidies for development in this area? Based on the level of investment by the private sector in the Wall-West-Main area over the past 14 years I would say….No.

Regarding “who controls it (the money and the regulations)” leads to more questions. Do we want un-elected, un-accountable, opaque, quasi-governmental agency deciding who can do what in the Plan area?

If the answer is Yes than this allows a very few people to dictate who wins and who looses over this rather large Central Business District. The NRA Plan essentially gives the money and regulator control to the NRA. That format gave us POKO.

Which begs more questions regarding NRA’s historical performance. Are they the best ones to oversee this? Do they have the requisite skill sets? Are they needed? Wouldn’t the private sector be a better arbiter of uses in this area – that seems to work in un-blighted areas everywhere else?

These points, and many others, should be asked and answered prior to ever allowing this to go forward. That is why we are asking the NRA Commissioners and the CC take a really hard look at what is happening on their watch.

Paul Lanning February 6, 2019 at 12:50 pm

Norwalk taxpayers get nothing for subsidizing apartment construction. Council members who support these subsidies should be voted out of office.

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