Rebuttal to Campanelli’s Deceptive Development Proposal in North Ashford
By Charles Vidich
The comments below respond to a recent document found on the Campanelli website that attempts to discredit a flyer titled “Ten Things to Love about the Mega Warehouse in North Ashford.” The analysis below reaffirms all of the remarks made in the flyer titled “Ten Things to Love about the Mega Warehouse in North Ashford.” As you will see from the analysis below, Campanelli is attempting to confuse, distract and underplay the unprecedented level of environmental destruction that can be expected from a full build out based on the zone text changes requested from the Ashford Planning and Zoning Commission. To save you reading the detailed rebuttal of the Campanelli rebuttal, suffice it to say Campanelli is 100% wrong and has not divulged what the company really plans to do in the Interstate Interchange Development Zone (IID Zone). All we know is that they are not giving us the complete story nor any information concerning the ultimate use of the 113.77 acres within the IID zone.
Largest Building in Eastern Connecticut: Campanelli claims there are larger warehouses in Eastern Connecticut. What Campanelli fails to understand is that the size of the building that can be built in the IID zone is not determined by their slide show. It is determined by their request to allow a building with 30% building coverage on 113.77 acres. Simple math shows: 113.77 acres x 30% building cover = 34.13 acres x 43,560 square feet per acre =1,486,764 square feet. However, the regulations do not address the number of floors in the building nor does Campanelli. If the building has 2 floors the total would be 2,973,925 square feet. Since Campanelli does not appear to be a zoning expert, the company may not know that the proposed requested regulations do not place a limit on the square footage – only the building footprint!
Destruction of 70 Acres of Trees: Campanelli is once again making the mistake of confusing their slide show with the proposed text amendments. The regulations allow a 60% impervious cover. Simple math: 113.77 acres x 60% impervious cover = 68.3 acres. Moreover, Campanelli will inevitably destroy more than 70 acres of trees if the company intends to remove more than 3.5 million cubic yards of earth (see below). Campanelli’s slide show presented at the February 13, 2023 public hearing has no bearing on the requested change to the text of the zoning regulations.
Mega Warehouse Smack Dab on top of a Critical Public Water Supply Watershed: Campanelli apparently does not understand a public water supply watershed is not the same as an aquifer protection area. Lacking any understanding of the distinction the company has failed to understand that the entire proposed development site is within the public water supply of the Windham Water Works and the University of Connecticut. Combined. Both Windham Water Works and UCONN provide water for 55,000 people. Campanelli apparently, never reviewed the memo from the Windham Water Works opposing their change to the zoning. Perhaps, their consultant Loureiro, failed to notify Campanelli of this issue. Campanelli claims the development is not adjacent to any other public water supply wells. Obviously, there is a misunderstanding concerning the distinction between water supply wells and public water supply watersheds. The key point is that the proposed development site is NOT adjacent to a water supply watershed – it is smack dab on top of one of the most important public water supplies watersheds in eastern Connecticut.
65,000 gallons of Wastewater a Day into the Fenton: Campanelli conveniently fails to address the impact of drawing down 65,000 gallons of water per day on nearby wells or the impact that it will have on wetlands located on the development site. In fairness, these issues cannot be fully understood at this state of the development process but are clearly a major concern given the anticipated water needs of such a large facility. Campanelli simply relies on its slide show and not its zoning text amendments to deflect public concerns with the worst case development they are requesting. Campanelli claims only 14,000 gallons of wastewater will be generated and states the CTDEEP thinks that number is appropriate. Of course, Campanelli undoubtedly presented their slide show proposal and not the worst case proposal. This is a common marketing technique designed to confuse the public on the worst case development allowed under their zone text request. Since the requested zoning text change proposal allows for warehouses, distribution centers, research labs and industrial facilities, Campanelli presumably made a “softball pitch” to CTDEEP about a non-worst case development scheme INCONSISTENT with their requested the zoning changes. Since Campanelli has requested four types of projects, if the industrial facility concept should go forward, a 1.5 million square foot industrial building could generate as many 11,100 trips per day and as many as 5,550 employees and truck trips per day. Under this scenario, there would be a demand for as much as 412,500 gallons per day in water consumption – simply from employee or trucker use. Once again, Campanelli is confusing their marketing slide show with the proposed zone text amendments. Campanelli needs to decide what is being proposed and communicate it honestly to Ashford residents. Is it a warehouse, a research laboratory, an industrial facility or a distribution center? They all have different water consumption profiles. Campanelli also needs to decide what the company is really trying to sell to the town of Ashford. Of course, we are not buying it.
Tallest Building in Eastern Connecticut: Campanelli was unable to find a larger building in Eastern Connecticut than the one their company is proposing at 75 feet. Merely refuting the analysis in the flyer is nothing more than bluster. The reason Campanelli is unable to do so, is because the company is unfamiliar with the development regulations in Connecticut. An analysis of the zoning regulations of all municipalities in eastern Connecticut found not a single warehouse at or above a 75 foot height. We also retained an independent architect to evaluate Campanelli’s proposed building profile from a view along I-84. A 75 foot tall building, as Campanelli has requested would create an eye sore at the Gateway to Ashford. Campanelli is simply greenwashing the real visual impact. The company slide show was nothing more than that.
3.5 Million Cubic Yards of Mountain Removed: Amazingly Campanelli has admitted the company will take down the mountain. Campanelli thinks that simply by keeping the 3.5 million cubic yards on site that no harm comes to nearby Snow Hill, the Connecticut State Forest, Mount Laurel Sanctuary or the Fenton River. The Fenton River will be the receiving stream for all of the erosion and sedimentation created by this massive blasting and earth removal effort. Not even the most sophisticated erosion and sedimentation control plans could ever guarantee a foolproof protection of the Fenton River. More importantly this would be one of the worst environmental impacts to pristine land anywhere in the state of Connecticut. Building a mega warehouse on tobacco fields is fairly easy given the flat land. Destroying an entire mountain simply because you got a good price on the land is unconscionable when there are so many other more appropriate sites for a mega warehouse. The real environmental impact is far greater than 3.5 million cubic yards mentioned in the flyer. The analysis behind that flyer only looked at the impacts caused by the building footprint – not the parking and maneuvering areas, dock bays and other related development allowed within the 60% impervious cover standard. The amount of material to be removed will be far more than 3.5 million cubic yards under worst case conditions. If soil and bedrock is removed from the 68.2 acres that are allowed to become impervious (i.e., 60% of the 113.77 acre site) the environmental impacts are unimaginable. If this material had to be removed off site, it would take more than 100,000 truckloads at the rate of 15 cubic yards per truck. This is an outrageous proposal within a public water supply watershed.
Developer Doesn’t Care About Ashford: Campanelli was smart enough to concede that they will not build a Federal Bureau of Prisons. The real question is why won’t Campanelli indicate what the proposed use will be? Why request four different development options? Does the company want a research lab, a Mega Warehouse, a distribution center or an industrial facility? OR does Campanelli want all four in four separate buildings? How can Ashford residents trust Campanelli’s zone text amendments when it won’t declare its intentions concerning the purpose of the building? Campanelli apparently wants a blank check for development. How can Ashford residents have any level of confidence in their marketing strategy when it doesn’t align with the requested zoning text changes? Campanelli may have 16 business parks in Massachusetts but no one in Ashford considers that relevant based on the company’s performance so far.
Developer is Sucker Punching the Town: Campanelli claims taxes will go down because of the proposed development. Campanelli indicates in their rebuttal (i.e., see rebuttal of “Ten Things to Love about the Mega Warehouse”) that the Ashford town assessor agrees the average residential tax bill saving will be $852 annually. This of course is NOT how the town of Ashford determines the taxes for any given residence in town. The town determines the expenditures and revenues for each year based on a town-wide decision – not one made by the town’s tax assessor. A decrease in the mill rate in Uxbridge is NOT the same as a decrease in the taxes for residences in Uxbridge. Once again Campanelli is confusing any potential tax ratable that may come from a development in Ashford with the way a municipal budget is created and approved. Campanelli has failed to mention points that are not in the company’s interest such as the wide range of additional town services needed from any development in the IID zone of the mega- scale size the company seeks. Furthermore, what about all of the other expenses associated with servicing the largest mega-warehouse ever proposed in the history of Ashford? Whatever economic benefits Campanelli would like us to believe would come from a mega warehouse, mega distribution center, mega research lab, or mega industrial facility are simply part of a one- sided marketing campaign that ignores its less quantifiable but extremely expensive environmental, public health and social impacts. What will it cost the town and Ashford residents faced with increased traffic accidents, loss of life from truckers passing through school zones at excessive speeds, increased truck pollution and noise from diesel trucks, and the unimaginable impacts to water quality from development within the Fenton River watershed.
9. Expect Triple the Traffic, Noise and Accidents: Campanelli once again chooses to provide an unrealistic assessment of the worst case traffic. Campanelli claims their development would only generate 1,700 trips. To make that number look small the company claims a 5 building development would generate 6,000 daily trips. Of course, a 5 building development is not before the Ashford Planning and Zoning Commission. That is purely a hypothetical comparison that is meaningless. The more meaningful comparison is to evaluate the traffic impacts of the four possible developments being proposed. The Institute of Transportation Engineers (ITE) is the authoritative source for anticipated trip generation rates. According to the ITE a 1.5 million square foot industrial facility would generate 11,100 trips a day. Campanelli is requesting the Ashford Planning and Zoning Commission to allow industrial facilities as one of four possible uses. Why has the company conveniently failed to discuss these worst case traffic impacts? Does Campanelli really think that people in Ashford are naïve?
No Public Water and Sewer exist in North Ashford: Once again Campanelli is painting a rosy picture about a hypothetical development that would only generate 14,000 gallons per day inside a 1.5 million square foot facility. Campanelli clearly did NOT tell the CTDEEP that one of the options is to build a 1.5 million square foot industrial facility. Undoubtedly, based on a 14,000 GPD throughput, the building would have no more than 200 people (i.e., 75 gallons per day of water per employee times 186 employees = 14,000 gallons per day. However, if Campanelli’s trip generation rates found in the company’s rebuttal document (i.e., the one found on their website) are taken seriously, then there will be 1,710 trips per day. Assuming these are round trips by employees then the facility would generate 855 employees or possibly some combination of 855 employees and truck drivers. Of course, Campanelli’s trip generation numbers have NO bearing on the four development options requested. For example if Campanelli decides to pursue an industrial facility, then there could be as many as 5,550 employees and/or truck drivers travelling to the site on a daily basis. Campanelli needs to come clean with what they plan. Who does Campanelli represent? There is no room for giving Campanelli a blank check. Ashford needs honesty about the ultimate plan. The slide show doesn’t line up with the requested zoning amendments. Why ask for 1.5 million square feet and then present a slide show with only a million square feet? Why request a 75 foot tall building and then show a 62 foot building in the slide show? Why request four different land use options and then try to sell Ashford on only one?
Conclusion: Campanelli needs to withdraw its proposed zoning text change immediately if the Campanelli Company wants to maintain any sense of integrity with the citizens of Ashford.