CAC Minutes.03-07-07NORTHAMPTON STATE HOSPITAL
CITIZENS ADVISORY COMMITTEE
c/o Mayor’s Office
210 Main Street Room 12
Northampton, MA 01060-3199
(413) 587-1249 Fax: (413) 587-1275
mayor@northamptonma.gov
State Senator Stan Rosenberg
Ex-Officio
State Representative Peter Kocot
Ex-Officio
___________________________
Mary Clare Higgins, Mayor
City of Northampton
David Narkewicz
City Council
David Modzelewski
Department of Mental Health
Reverend R. Leroy Moser
National Alliance for the Mentally Ill
of Western Mass., Inc.
Rutherford H. Platt
National Alliance for the Mentally Ill
of Western Mass., Inc.
Edward Skroski
Northampton Development Corporation
Charles DeRose
Northampton Development Corporation
Daniel Yacuzzo
Northampton Chamber of Commerce
Bruce Fogel, Esq.
Northampton Chamber of Commerce
Robert Starr
Northampton Labor Council
John W. Hornor
Northampton Housing Partnership
Francis A. Johnson
Northampton Planning Board
Christopher Kennedy
Historical Preservation
Joseph Blumenthal
Route 66 Neighborhood Representative
Harriet Diamond
Grove Street Neighborhood Representative
Jami Albro-Fisher
Route 10 Neighborhood Representative
MEETING MINUTES
Citizens Advisory Committee
for the Northampton State Hospital
Wednesday, March 7, 2007
5:00 pm
City Council Chambers
Present:
Members of the CAC
Absences:
Jami Albro-Fisher, Charles DeRose, Edward Skroski,
Robert Starr, Daniel Yacuzzo
Teri Anderson, City’s Economic Development Coordinator
Wayne Feiden, City’s Planning Director
Peg Keller, Housing and Community Development Planner
Barbara Blumenthal, Northampton Historical Commission
Beth Murphy, Vice Pres., Real Estate Development, MassDevelopment
Thomas Kegelman, The Community Builders
1. Call to order
Because Mayor Higgins would arrive late, Chair David Narkewicz called the meeting to order at 5:09 p.m.
Approval of Minutes
Approval of the minutes of the December 6, 2006 meeting was moved, seconded and voted for approval, with two abstentions, Bruce Fogel, Esq. and Frandy Johnson (they had not received
the emailed minutes).
Briefing on draft 40R Plan and Upcoming Subdivision Plan
City Planning Director Wayne Feiden distributed two documents, a summary of M.G.L. Chapter 40R/Smart Growth Zoning Districts (see Attachment 1) and a grid of Housing Incentive Payments
(see Attachment 2). Under the provisions of 40R the State offers financial incentives to produce more housing on a pedestrian scale. We currently plan for 8 dwelling units per acre;
approximately 140 units remain vacant in accordance to the Master Plan total. If these units are not spread out and are made more compact, the City benefits:
By furthering the Sustainable Northampton process
Requiring less infrastructure per unit, which is more efficient
By abiding by what our research has found: most trips are less than ½ mile by foot
By a financial payment from the State.
Wayne pointed out two cautions:
Chapter 40R is funded by a budgetary surplus fund, with all the uncertainties that are associated with the State budget process. 40R was funded last year but future funding is not guaranteed.
Chapter 40S monetary incentive has yet to be paid out. Future funding is very unclear and speculative. Chapter 40S pays a municipality for the net increase for children and schools,
etc. resulting from adherence to Chapter 40R. Northampton is a declining school enrollment community, plus our cost to educate a student is less than that in other communities.
Time line for approval:
March 20, 2007 Mayor holds public hearing.
April 26, 2007 Planning Board, or perhaps joint Planning Board/Ordinance Committee,
public hearing; the two boards make a recommendation to City Council.
City Council votes.
Assuming approval, City submits application to State.
40R does not cover the two historical buildings on campus or the male attendants building.
Tom Kegelman, The Community Builders: Repeated the current residence formula:
8/acre single-family units
12/acre townhouse, as defined by State
20/acre multi-family (2 or 3 townhouses in a row, as defined by State)
Tom displayed a map of the proposed 40R zone showing exclusions, such as a 2-acre zone that allows 16 units, but The Community Builders plans 15 (see Attachment 3). In total, the two
sub-zones allow 156 units, but Tom reasonably can fit only 139 units (see same attachment).
Tom emphasized a very important caveat: This plan is all conceptual. It will be several years before the site is all built out.
Jack Hornor, CAC: How much money does the City expect to receive from 40R incentives and where does it go?
Wayne Feiden, Planning Director: The money goes into the City’s capital improvements fund. The following is the payment incentive formula from M.G.L. Chapter 40R:
$10,000 for up to 20 units
$75,000 21-100 units
$200,000 101-200 units
$350,000 201-500 units
$600,000 501 or more units of housing
With the proposed 148 additional units, the City expects to receive $200,000. Additionally, a one-time density bonus of $3,000 for each unit of new construction is awarded upon issuance
of a building permit.
Jack Hornor: I understand the positives; what are the negatives?
Wayne Feiden: A minor criticism is that 40R, in his opinion, is a poorly written law. And there is a legitimate concern of what happens to the rest of the Hospital Hill property, does
it get developed?
Teri Anderson, Economic Development Coordinator: Requested that Wayne address the commercial/residential ratios.
Wayne Feiden: Currently, for every foot of commercial there is .85 foot of residential. MassDevelopment has secured funding to build the south campus road, with infrastructure and
utilities.
5:34 p.m. Mayor Higgins arrived.
Rutherford Platt, CAC: Will a condominium association exist to maintain the open spaces between townhouses?
Tom Kegelman, The Community Builders: Yes.
Wayne Feiden, Planning Director: There is one project landowner association for storm drains and exterior common facilities.
Rutherford Platt: Will there be access to the bikepath and bus stops for access to downtown?
Tom Kegelman: Yes.
Teri Anderson, Economic Development Coordinator: There will be some connections to the Manhan Rail Trail.
Bruce Fogel, Esq., CAC: I seek clarification about the ratio. The language in the zoning does not get transferred word for word into the 40R zoning, but the Master Plan’s ratio will
be valid?
Councilor David Narkewicz, CAC chair: 40R trumps zoning.
Wayne Feiden: Yes.
Bruce Fogel, Esq.: In short, the trump card gets played only after the balance as in the Master Plan has been achieved.
Wayne Feiden: No commercial footage will be lost.
Bruce Fogel, Esq.: I would like assurance that 40R will not subvert the goal of ongoing commercial development being done in lock step with the residential. I hear those assurances
tonight.
Wayne Feiden: Yes.
Bruce Fogel, Esq.: Is this “intensity of the density” (copyright of phrase by Attorney Fogel in process of being secured?), the squeezing in, being done to gain more money?
Tom Kegelman, The Community Builders: We designed this new urbanist version even before 40R was on the horizon. Most adjustment was toward livability and aesthetics. He fought to have
the language read, “You may build up to xxx units” rather than “You must build xxx units.”
Bruce Fogel, Esq.: Does it make sense to spread out the allowed extra units, to have residential and pedestrian components to add to the commercial space’s viability?
Beth Murphy, MassDevelopment: I repeat, this is a conceptual plan. The Community Builders still must develop marketing plans. They will not build something until they are sure it will
sell.
Frandy Johnson, CAC: This constitutes less than a 10% change. It has been strongly recommended by the City’s Planning Board.
Christopher Kennedy, CAC: If it were passed by the City Council, does the City receive its payment from the State up front?
Wayne Feiden: Yes.
Harriet Diamond, CAC: What percentage of the north campus that is developable is residential, is it approximately 50%? Whenever such a change is made, there must be some idea of future
actions. Does The Community Builders envision eventually a 40R request for the top portion? Will the CAC be asked to add the same amount of density on the land not shown on the map?
Tom Kegelman, The Community Builders: A lot of ground work has to happen in the City first regarding development in outlying areas vs. more in downtown; many similar conversations
have to take place. We are happy to devote the next few years concentrating on what we show here today.
Harriet Diamond: I see no organized play spaces for children. Won’t it follow that the 2nd half will be developed as the 1st half was?
Tom Kegelman: It makes more sense to have the density near the commercial area.
Joseph Blumenthal, CAC: The Master Plan and Chapter 40R are two separate issues.
MOTION:
The CAC recommends approval of Chapter 40R zoning, with the proviso that said approval does not authorize any change to the Master Plan.
Moved by Joseph Blumenthal
Seconded by Jack Hornor
Discussion followed.
Rutherford Platt, CAC: What is the number of parking spaces per unit? On the map it appears very crowded with parking.
Tom Kegelman: Off-site parking is relatively scanty. 50-something spaces for 33 units. The aim: 1¼-1½ spaces per unit of off-site parking.
Rutherford Platt: How can we prevent parking space from eating up all green space?
Harriet Diamond, CAC: What are the setbacks along the street where the ochre colored houses and townhouses are shown?
Tom Kegelman: The plan: parking—tree belt—sidewalk—room for a little planting out front.
Christopher Kennedy, CAC: Is on-street parking assumed? How wide are the streets?
Tom Kegelman: 11 foot travel lanes with parking on both sides.
Harriet Diamond: Are we able to have 40R and increase the green space?
Teri Anderson, Economic Development Coordinator: It is important to look at the 40R piece in the context of the entire project. You would see clearly a dense urban core surrounded
by acres of green space.
Councilor Narkewicz, CAC chair: A reminder that this is a conceptual plan, not a site plan.
Rev. Tex Moser, CAC: I am interested in the size of the townhouse rooms, and the single-family unit rooms. Does increased density mean fewer children are expected to be residents?
Tom Kegelman, The Community Builders: Yes. Our market study shows the market will be for very small households, people leaving their parents and setting up their first household and
people whose children have left the home and seek a place with less space.
Harriet Diamond, CAC: My question is directed at Wayne. This proposed density resembles which existing area in Northampton?
Wayne Feiden, Planning Director: The single family area of South Street, the multi-family area of Union and Cherry Streets/Graves Avenue, but not like the brick pre-war buildings,
which are denser.
Mayor Higgins: It has a Market Street feeling.
Harriet Diamond: To comply with 40R, must it necessarily be this dense?
Tom Kegelman, The Community Builders: 40R is a cap. The City wants it in place to allow builders more density. With a 20 units/acre cap, I don’t see where I can squeeze them all in.
Bruce Fogel, Esq., CAC: Is 40R an asset or a problem for Tom?
Teri Anderson, Economic Development Coordinator: The City of Northampton requested it.
Tom Kegelman: The Community Builders are here to help. All of us here are part of a team. 49R is not changing my plan, I want to be very clear about that.
Bruce Fogel, Esq.: I understand that you are proposing a change that is less than 10% overall, but a change concentrated in a very small section of the project can create real changes
to life in the surrounding neighborhoods.
David Modzelewski, CAC: There is no question that more affordable housing is necessary. This change will help.
David Modzelewski called the question on Joseph Blumenthal’s Motion:
MOTION:
The CAC recommends approval of Chapter 40R zoning, with the proviso that said approval does not authorize any change to the Master Plan.
Moved by Joseph Blumenthal
Seconded by Jack Hornor
The motion passed unanimously.
New Business
The Sustainable Northampton public input meeting has been scheduled:
Monday, March 26 at 7:00 p.m. in City Council Chambers.
Next C.A.C. Meeting
Wednesday, June 6, 2007
5:00 p.m.
City Council Chambers
Adjournment
Motion to adjourn was moved, seconded, and voted unanimously in the affirmative.
The meeting adjourned at 6:30 p.m.
Respectfully submitted,
Corinne Philippides
Mayoral Aide
March 21, 2007
ATTACHMENT 1
SUMMARY OF M.G.L. CHAPTER 40R
SMART GROWTH ZONING DISTRICTS
PASSED INTO LAW AS PART OF THE FY 2005 BUDGET
(includes a summary of related sections passed as part of the same budget)
Prepared by the Metropolitan Area Planning Council (MAPC)
60 Temple Place, Boston, MA 02111
July 22, 2004
Housing production within the Commonwealth has not kept pace with the growing
number of households looking for an affordable place to live. To help meet this demand,
the Commonwealth adopted Chapter 40R within the General Laws allowing
municipalities to encourage housing production that is aligned with the principles of
“smart growth.” Communities doing so may obtain funds through housing incentive
payments.
This document summarizes the new law and related sections passed as part of the FY
2005 budget. We hope you find it useful. Please remember that reading a summary of
legislation is not a substitute for reading the legislation itself. The legislation is more
detailed and may answer questions the summary cannot.
M.G.L. Chapter 40R Smart Growth Zoning Districts
Section 1. Purpose
It is the purpose of this chapter to encourage smart growth and increased housing
production in Massachusetts. Smart growth is a principle of land development that
emphasizes mixing land uses, increases the availability of affordable housing by creating
a range of housing opportunities in neighborhoods, takes advantage of compact design,
fosters distinctive and attractive communities, preserves open space, farmland, natural
beauty and critical environmental areas, strengthens existing communities, provides a
variety of transportation choices, makes development decisions predictable, fair and cost
effective and encourages community and stakeholder collaboration in development
decisions.
Section 2. Definitions
This section defines terms used in the new law. A summary of critical definitions
includes:
ATTACHMENT 1
Summary of Chapter 40R
Page 2 of 7
“Affordable housing,” housing affordable to those earning less than 80% of the median income, and subject to an affordability restriction lasting for at least 30 years;
“Approving Authority,” a unit of town or city government designated by the municipality to review and approve projects.
“Comprehensive housing plan,” plan prepared by a municipality assessing housing needs within the municipality and strategies to address those needs;
“Department,” the department of housing and community development;
“Developable land area,” that part of the smart growth zoning district that can be feasibly developed as residential or mixed-use development, excluding land already substantially developed,
parks, open space, and wetlands, and including land with underutilized residential, commercial, industrial, or institutional buildings that could be recycled or converted into residential
or mixed use.
“Eligible locations,” (1) areas near transit stations, including rapid transit, commuter rail, and bus and ferry terminals, (2) areas of concentrated development, including town and
city centers, other existing commercial districts in cities and towns, and existing rural village districts, or (3) areas that by virtue of their infrastructure, transportation access,
existing underutilized facilities, and/or location make highly suitable locations for residential or mixed use smart growth zoning districts;
“Multi-family housing,” apartment or condominium units in buildings with more than three units;
“New construction,” construction of new housing, substantial rehabilitation of existing buildings, or conversion to residential use;
“Smart growth zoning district,” a zoning district adopted by a municipality under this statute that is superimposed over one or more zoning districts in an eligible location, within
which a developer may elect to either develop a project in accordance with requirements of the smart growth zoning district ordinance or develop a project in accordance with requirements
of the underlying zoning district.
Section 3. Authority
A municipality may adopt a “smart growth zoning district,” in accordance with the
provisions of Section 5, chapter 40A, in any eligible location allowing for primary
residential use as-of-right and also permitting businesses, commercial and other uses
consistent with primary residential use. Smart growth zoning districts may include areas
eligible for Tax Increment Financing (“TIF”) and District Improvement Financing (“DIF”).
Section 4. Determination of Eligibility
Before adopting a smart growth zoning district, a municipality will apply to the
department, which has 60 days to make a preliminary determination of whether the
ATTACHMENT 1
Summary of Chapter 40R
Page 3 of 7
applicant would be eligible for the financial and other incentives in this chapter. The
department will communicate this determination via a letter of eligibility. The
department may also advise the applicant of deficiencies in the application. If the
municipality adopts the district, along with any changes recommended by the department,
the department has 30 days to issue a final approval.
Section 5. Application Requirements
To be eligible for a smart growth zoning district, the municipality must submit to the
department an application that:
identifies the boundaries of the proposed district;
describes the developable land area within the proposed district;
identifies other residential development opportunities for infill housing and the residential reuse of existing buildings and under-utilized buildings within already developed areas;
includes a comprehensive housing plan (see Section 8);
includes a copy of the proposed smart growth district ordinance or by-law; and
establishes that the proposed district satisfies the minimum requirements of a smart growth zoning district (see Section 6).
Section 6. Minimum Requirements of Zoning District
(a) The minimum requirements of a smart growth zoning district include the following:
The proposed district must be determined an “eligible location” (see definition in Section 2).
The zoning ordinance must provide for residential use to permit a mix of housing such as for families, individuals, persons with special needs, or the elderly.
Housing density allowed in the developable land area of a proposed district must be at least:
20 units per acre for multi-family housing,
8 units per acre for single-family homes, and
12 units per acre for 2 and 3 family buildings.
The zoning ordinance for each proposed district will:
provide that not less than 20% of the residential units constructed in projects of more than 12 units will be affordable, and
contain mechanisms to ensure that not less than 20% of the total residential units constructed in each district will be affordable.
The zoning ordinance must permit infill housing on existing vacant lots and additional housing units in existing buildings, consistent with neighborhood building and use patterns, and
consistent with building, fire, and safety codes.
ATTACHMENT 1
Summary of Chapter 40R
Page 4 of 7
Development in the district will not be subject to any limitation on the issuance of building permits for residential uses or any local moratorium on the issuance of such permits.
No restrictions on age or any other occupancy restrictions in the district as a whole. This provision does not preclude the development of specific projects that may be exclusively for
the elderly, the disabled, or for assisted living, provided that not less than 25% of the housing units in such a project will be affordable housing.
Full compliance with federal, state and local fair housing laws.
The proposed district may not exceed 15% of the total land area in the municipality, except that the department may approve a larger land area if such an approval serves the goals and
objectives of the chapter.
The total land area of all approved smart growth zoning districts in the municipality may not exceed 25% of the total land area in the municipality. (Note: unlike #9, above, this provision
may not be waived.)
Proposed housing density will not overburden infrastructure as it exists or may be practicably upgraded.
The proposed zoning ordinance must define the manner of review for individual projects by the approving authority in accordance with Section 11 (see below) and specify the procedure
for such review, in accordance with the regulations of the department.
(b-e) Within the zoning ordinance the municipality may:
modify or eliminate dimensional standards;
designate a limited percentage of the developable land area as dedicated perpetual open space through the use of a conservation restriction or other means; said open space will not be
considered part of the developable land area for density calculation purposes.
provide for mixed use development;
the district may encompass an existing historic district or establish an historic district within an approved district; and
require more affordability than required by this chapter provided that affordability thresholds do not unduly restrict opportunities for development.
(f) Municipalities with fewer than 10,000 persons, for hardship shown, may gain
approval from the department for a smart growth zoning district with lower densities than
provided in this chapter.
(g) Any amendment or repeal of the zoning for an approved district will not be effective
without the written approval by the department.
ATTACHMENT 1
Summary of Chapter 40R
Page 5 of 7
(h) Nothing in this chapter will affect a municipality’s authority to amend its zoning
ordinances under chapter 40A, so long as the changes do not affect the smart growth
zoning district.
Section 7. Certificate of Compliance
Each year the department will send a certificate of compliance to all municipalities with
approved districts where it has been verified by the city or town that the zoning district
has been adopted, that no previous certificate has been revoked, that the district is being
reasonably developed consistent with the density and affordability requirements of this
chapter, and that projects have not been unreasonably denied by the approving authority
within the municipality.
Section 8. Comprehensive Housing Plan
When applying for a determination of eligibility, the municipality will submit a
comprehensive housing plan that estimates the projected number of housing units of new
construction (see definition in Section 2) that could be built within the proposed district.
Existing comprehensive housing plans may be submitted with additions relating to the
newly proposed district.
Section 9. Housing Incentive Payments
Upon approval of the district, municipalities are entitled to zoning incentive payments for
housing creation. Based on number of units of new construction (see definition in
Section 2) projected in the smart growth zoning district, payments will range from:
$10,000 for up to 20 units;
$75,000 for 21-100 units;
$200,000 for 101-200 units;
$350,000 for 201-500 units; to
$600,000 for 501 or more units of housing.
Additionally, a one-time density bonus of $3,000 for each unit of new construction will be awarded upon issuance of a building permit. When awarding discretionary funds, the department
and the executive offices of environmental affairs, transportation, and administration and finance will use a methodology that favors municipalities with approved smart growth zoning
district, or other zoning policies that encourage affordable housing production.
(See Section 14 regarding repayment if no construction occurs.)
ATTACHMENT 1
Summary of Chapter 40R
Page 6 of 7
Section 10. Design Standards
Design standards may be adopted to ensure that the physical character of development
within the smart growth zoning district will complement the adjacent buildings and
structures, and not conflict with the comprehensive housing plan or any master plan for
the community. The design standards may not add unreasonable costs to residential or
mixed-use development, or unreasonably impair economic feasibility of proposed projects.
Section 11. Municipal Project Review
The municipality may prescribe the contents of an application for project approval. It may require payment of reasonable consulting fees for peer review. It may refer applications for
review by municipal entities in addition to the approving authority and such entities will have 60 days to comment.
Zoning in effect at the time an application is submitted will govern the review of that application while it is being processed, during any appeal, and for three years after approval.
If an application is denied, zoning will remain in effect with respect to any further application for two years after denial unless the applicant chooses otherwise.
The approving authority will hold a public hearing consistent with the provision of Section 11 of Chapter 40A. The approving authority will make a decision within 120 days of filing
or it is deemed approved.
Project approval is subject only to those conditions that are necessary to ensure compliance with the smart growth zoning district ordinance and to mitigate only those impacts that are
extraordinarily adverse to nearby properties.
A court may overrule approval of a project only if it finds that that the approving authority abused its discretion in approving the project. A plaintiff seeking to reverse a project
approval must post a bond.
In any court appeal of a project denial by an approving authority, the approving authority will have the burden of justifying its decision by substantial evidence in the record.
Section 12. Administration of Smart Growth Zoning Program
The department of housing and community development will serve as the administrator
of the smart growth zoning district program. It will also be responsible for an annual
review and report of data no later than November 15 of each year regarding the status of
proposed smart growth zoning districts, the number of approved districts, development
having taken place in districts to date, and monies paid to municipalities.
Section 13. Existing Zoning Districts
An existing zoning district may gain approval as a smart growth zoning district and
receive incentive payments if it meets the requirements of this chapter. The application
ATTACHMENT 1
Summary of Chapter 40R
Page 7 of 7
process will be consistent with that of a new smart growth zoning district. If such
districts are approved, the community will not be eligible for the zoning incentive
payment, but will be eligible, after the date of approval, for the one-time density bonus
payment, and will be eligible for favorable review in the awarding of certain state funds.
(See Section 9 for further information on these incentives.)
Section 14. Repayment
If no construction in the smart growth zoning district has taken place within three years
of the date of the zoning incentive payment (see Section 9), the municipality must repay
all monies paid to it under this chapter.
RELATED SECTIONS
M.G.L. Chapter 10, Section 35AA Smart Growth Housing Trust Fund
This section creates a Smart Growth Housing Trust Fund, funded by monies from the sale
of surplus land, appropriations, or sanctions on communities. Without requiring further
appropriation, available funds are to be disbursed by the department in accordance with
the provisions of M.G.L. Chapter 40R.
M.G.L. Chapter 26, Section 548 Funding of Smart Growth Housing Trust Fund
The first $25,000,000 of any proceeds realized from the sale of surplus state properties
will be deposited into the General Fund. The second $25,000,000 of any such proceeds
will be deposited into the Smart Growth Housing Trust Fund. Any additional proceeds
will be deposited into the Commonwealth Stabilization Fund. (Note: As a result of this
section, funds from the sale of surplus state properties will enter the Smart Growth
Housing Trust Fund only if annual sale proceeds exceed $25 million, and the amount
entering the Trust Fund cannot exceed $25 million per year.)
Outside Section 367 Impact Study
The department, in consultation with the departments of education and revenue, will
study the impact of the adoption of smart growth zoning districts on the educational
systems of participating municipalities. The department will report to the Legislature on
this study no later than July 1, 2006. The report will recommend a formula for
ascertaining any actual additional net public school costs to which municipalities may
become subject as a result of the adoption of smart growth zoning districts.
ATTACHMENT 2
MGL 40R Housing Incentive Payments Up Front Incent Per Bldg Per Total Incentive (range) Up to 20 units $10,000 $3,000 $13,000 to $260,000 21-100 units $75,000 $3,000 $1,578,000 to $7,800,000 101-200
units $200,000 $3,000 $20,203,000 to $40,600,000 201-500 units $350,000 $3,000 $70,353,000 to $176,500,000 501+ units $600,000 $3,000 $300,603,000 to no cap e.g. 140 units
$200,000 $420,000 $620,000
Notes:
40R was funded last year but current funding is committed.
Future funding not guaranteed.
MGL 40S Smart Growth Reimbursement Formula 1. # pupils in smart growth districts*per public net school spending Formula 2. Local 40R revenue (property tax, excise, Chapter 70 aid)*state
average of municipal spending on schools) (Formula 1)-(Formula 2)=Amount of 40S aid (if funded) Notes:
40S has not yet been funded.
Future funding is very unclear and speculative.
Formula provided above is simplified version.
Prepared by Office of Planning and Development 3/5/07 preliminary analysis
ATTACHMENT 3
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