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CostOfWasteBurialVSOffsiteDisposal_Nov_9_2022 Richard Hudson and Joyce Vann 393 Riverside Drive Florence, MA 01062 November 9, 2022 Sarah LaValley Northampton Conservation Commission 210 Main Street, Room 11 Northampton, MA 01060 Subject: Response to Notice of Intent for Cutlery Building Project at 320 - 360 Riverside Drive Northampton concerning economic impact of on site waste burial. Dear Sarah LaValley, The Cutlery NOI financial issues should include not only how much the project will cost but who will pay the costs. It takes as fact that hazardous and contaminated soils buried nearby will have an adverse effect on property values. This study tries to get at the costs to nearby properties of the on-site burial alternative vs. the off-site disposal alternative. The methodology used is simple, determine the value of nearby properties, approximate the percent loss in property value resulting from burying waste nearby and then determine the aggregate decrease in property value. This decrease in value is the cost to property owners of the on-site burial alternative. Simply put if on-site burial is the preferred alternative over off-site disposal nearby property owners will pay a high cost in the form of lower property values. The executive summary is that the value of property within 500 feet of the site is appraised by the City of Northampton at approximately $20 million dollars. If one believes that having buried waste on your block has 0% effect on property values then of course cost to the neighbors would be $0 dollars. A 10% reduction of property value would be $2 million dollars, 20% $4 million dollars, and so forth. The challenge to each conservation commission members is to estimate what percent their own home would be devalued if hazardous waste was buried within 500 feet. Multiply $20 million dollars by that percent to get the cost of choosing on-site burial over off-site disposal. More importantly nearby property owners will pay that cost in order to save the applicant money. I would humbly argue that no financial burden should be placed on the neighborhood and the applicant should bear the full cost of removal of the waste, cleanup, and rehabilitation of the site. The appendix at the end of this document explains the motivation, methodology, the data source, and sufficient information to reproduce the study. This study does not address whether the choice between on-site burial and off-site disposal should be based on financial or on environmental considerations. In the unlikely case that the commission is swayed by the applicants financial arguments the study presents additional data showing that the abutters will likely bear over $2 million dollars of financial burden for any on-site burial alternative and that those costs should be also considered along with the applicants financial costs. Sincerely, Richard Hudson and Joyce Vann 393 Riverside Drive Florence MA. 01062 CC: Wayne Feiden, FAICP Director Planning & Sustainability Alex Jarrett, Ward 5 City Councilor Alan Verson, Cutlery Building Associates Joshua Surette, Senior Scientist Epsilon Associates Gary Hartwell, Abutter Gaby Immerman, Mill River Greenway Initiative John Sinton, Mill River Greenway Initiative Appendix Methodology, data source, and analysis. (The machine readable raw data is available by contacting the author.) The study defines “nearby” as being within 500 feet of site. 500 feet is less than the length of the fence along the property. 500 feet is a city block, it is shorter than 2 football fields, 500 feet is the distance from City Hall to the Academy of Music, a simple two minute walk. It is a defensible number. Using the City of Northampton's Interactive Geographic Information System[1] all 75 parcels within 500 feet were located along with their parcel numbers. The appraised value for each of the 75 parcels was retrieved by selecting the parcel and clicking on parcel details to get the property record card holding the appraised tax value. This was all collected into a spread sheet which was edited to correct a few data formatting errors.Two recently developed properties were not found on the GIS data so values from real estate listings were used. A machine readable file containing the data is available by contacting the author. One alternative would have been to use appraisals from a web based valuation engine such as Zillow. The Zillow numbers are also also available and were close to $30 million and undoubtedly reflect recent increases in property values. The tax appraisals were ultimately used because they placed a lower bound on the property values, making them easily defensible and avoided rat holes trying to defend the Zillow numbers. The one exception was that two recently developed properties were not found on the GIS so prices from real estate listings were the only appraisals available. This data is also available by contacting the author. The appraisal values and the distance are correct, defensible, and reproducible. The third value, how much value is lost due to the hazardous waste being buried instead of being removed is harder to get at but is not zero. To get at the number an economist would ask various questions including the challenge made to the conservation commission above. Other question might include such as “how far would buried hazardous waste have to be before your property value would not be impacted?” “ How close would a hazardous waste site have to be for your property to lose 10% of its value? 20%? 40%?” A full study with professionally worded question or appraisals from real estate experts is beyond the scope of this study. Instead we rely on the common sense and intuitions of the commissioners. Finally, this is an economic study focused on real estate property values. It in no way addresses the the value lost by the environmental disturbance, the loss of habitat, loss of 96 trees. The study was done to address the main argument that the application makes, which is that the applicants cost is high and that the minimizing the applicants cost should be considered. This study discusses the cost that are not born by the applicant but by owners of property withing 500 feet of the site. [1] https://hosting.tighebond.com/northamptonma_public/