Talbot Preservation Alliance

210 Marlboro Avenue, Suite 31-208

Easton, MD 21601

(410) 763-8013 Fax (410) 763-9611

Position Paper

                                                Responses to Kehoe Memorandum of October 5,1999

November 1, 1999

1.0 COMPREHENSIVE PLANS SHALL PROVIDE FOR "THE COORDINATED, ADJUSTED, AND HARMONIOUS DEVELOPMENT OF THE JURISDICTION, AND ITS ENVIRONS WHICH WILL, IN ACCORDANCE WITH PRESENT AND FUTURE NEEDS, BEST PROMOTE HEALTH CONVENIENCE, PROSPERITY, AND GENERAL WELFARE."

1.1    Q.        Is additional big box retailing necessary for the town's present and future needs?

                    TPA Response:

· NoExhibits A, B, & C show that Easton is more than adequately served in virtually     all major big box categories.

· Easton's retail space in shopping centers only, per capita, is presently more     than 3 times the industry average of 20 square fee/capita! See Exhibit L

· The 700,000 square feet of new proposed shopping center space in Easton - the       additional space now being considered - would add over 20 square feet of retail space for every person in the county!

1.2    Q.    How should the Commission and Council make the determination of what our                      citizens need in this regard? Who defines our "needs?" Residents? How should                      their views be determined?

TPA Response:

· Based on Exhibits A, B, & C, it is clear that our needs are more than adequately served at present.

· The Mayor and Town Council should make this decision based on the "Visioning Process", the Comprehensive Plan, and input from town and county residents.

· The existing retail base in Easton can not survive solely on the town populace as there is insufficient population density. The county as a whole is inevitably involved.

The existing operating retailers in Easton should be consulted in this process.

· "There is enough commercial development in Easton at the present time. Future commercial development should be encouraged to locate in the Town Center or in the vacancies within one of the several existing shopping centers. People did not want any more shopping centers, but felt there is room in Easton for additional commercial uses of many types from 'big box' to 'Mom & Pop' type retail" (page 22 Easton Comprehensive Plan).

· "The Planning and Zoning Commission should evaluate all development regulations and encourage the stabilization of and strengthening of Easton's Town Center as a retail shopping area..." (page 98 Easton Comprehensive Plan).

· The views of residents can be obtained through public hearings.

1.3      Q. When members of the public express concern over additional big box retailing are those concerns primarily directed to the existence of additional big box retailing?

TPA Response

· Yes, public input is directed at the impact that additional big box retailing will have on the local economy, traffic, public safety, the environment and the overall "quality of life".

1.4   Q.   Can design and landscaping standards answer some of the concerns of the public?

TPA Response:

  • Yes, some of the concerns, but the major issues are how much additional big box retailing can this market sustain and what would be its impact on our community.

1.5    Q. We have been told that Easton is a regional marketing center for the Mid-Shore. Is this a trend which we wish to encourage? Discourage?

TPA Response:

While our role as a commercial center is important, our function as a gateway to other parts of the county cannot be overstated. People must go through Easton to get to these other areas. In addition, the land is surrounded by rivers on many sides and we must not ignore the limitations that these natural barriers place on Easton. Intense retail development in this geographical setting will turn the gateway into a "choke point" because the proximity to water limits our ability to reroute roadways around congestion. Our commercial and retail role must be weighed against our function as a gateway to other areas.

· The development of Easton as a regional marketing center for the Mid-Shore should not be encouraged. Such development would inevitably threaten its geographically imposed function as a gateway. The multiple projects proposed for Easton are not driven by the needs of the local community but rather by the need of the developer to develop.

· As the noted planner Andres Duany has pointed out, "each developer who wants to build one housing subdivision, one office park or one shopping center at a time can prove there is a market for it. Allowing growth in this fashion is not planning, it is a sequence of permits that issued one at a time, allows the landscape to be consumed, resulting in Anywhere, USA".

· See Exhibit B & C which depict the extent of big box retailing on the Mid Shore

1.6 Q. If the Town changes its infrastructure (i.e. roads) to accommodate current                   additional big box retailing proposals, will those changes, in turn, generate                   additional development pressures?

TPA Response

Yes. Bigger roads will inevitably bring more development and more traffic. A case in point is 1-270 in Rockville where development has outstripped even a 12 lane highway.

1.7   Q.   What are current big box retailers in Town?

TPA Response:

          Please refer to Exhibit B.

1.8    Q. What has been our current experience with big box retailing?

TPA Response:

Current big box retailers adequately serve the resident population. There has been a measurable increase of traffic off Rt. 50 to access the Giant and Wal-Mart on Elliot Road at both Matthewstown Rd. and Dover Rd.

1.9   Q.     How can we improve and learn from our experience?

TPA Response:

· Preserve and improve that which exists. Resist the idea that "bigger is better". Serve our present population as a first priority.

· Rely on the Comprehensive Plan regarding the locations of possible future big box retailers. The effect of any big box proposals on existing retailers must be carefully weighed.

· Other municipalities are leading the way in enforcing their Comprehensive Plan to shape their own destiny even when the individual land owners' economic interests are affected. See Exhibit D, "Zoning Bans Against Sprawl Locations".

1.1O   Q.   At what point does the presence of big box retailing detract from Easton˝ quality                    of life?

TPA Response:

We are already there!

· Any additional big box retailing will detract from Easton's quality of life by increasing traffic, increasing demands on public services and potentially damaging the environment.

· The scale of commercial development in Easton is already affecting the character of the Town.

1.11   Q.    What mechanisms can the Town use to give clarity to developers regarding the big box requirements?

TPA Response:

A number of planning tools exist to help communities protect against overdevelopment and ensure that a big box store respects the landscape. These include:

· Zoning bans against 'sprawl' locations (Exhibit D)

· Retail square footage or size caps (Exhibit E)

· Moratoria on development

· Design standards such as those recently adopted in Easton (Exhibit F)

· Retention zones to encourage downtown retailing (Exhibit C)

· Impact fees to require new development to carry its own weight

· Creation of development of regional impact review boards (Exhibit H)

· Strict Definition /criteria for big box store development ( Exhibit I)

1.12   Q.   If the Town decides we want big box retailing what limitations do we want to impose upon developers as far as location, and other physical characteristics of the big box?

TPA Response:

· Require that such developments take place within existing retail facilities and/or areas.

2.0 COMPREHENSIVE PLANS SHALL PROVIDE FOR "THE WISE AND EFFICIENT EXPENDITURE OF PUBLIC FUNDŁ

2.1 Q. What are the fiscal benefits and detriments to the town which will be associated with

              additional big box retailing?

TPA Response:

· Absent knowledge of the big box occupant fiscal impact is difficult to quantify. However, there is insufficient consumer demand/expenditure potential to support new big boxes and the existing retail stores. See Exhibit J regarding expenditure potential.

· Should Home Depot and a correspondingly enlarged Lowe's deploy in Easton, clearly they will negatively impact Moores, Warrens, Shortall Building Supply, Talbot Building Supply, Charter Distributors, The Lumberyard and Easton Hardware.

· For the past 15 years, the NATIONAL MAIN STREET CENTER has worked with 1,100 towns, cities and urban neighborhoods in 40 states. The Main Street Center has concluded that: "without question the single greatest cause of the economic decline of traditional commercial districts is commercial 'glut' (i.e. an excess of commercial space over commercial demand)." (Exhibit K)

· According to the NATIONAL MAIN STREET CENTER this problem is directly attributable to the following:

· An excess supply of commercial space in the community.

· The inability of available retail dollars to support enough square footage of retail businesses to occupy a significant share of the available retail space.

· The hidden costs of attracting customers from outside the community's primary trade area to augment sales in the superstore and to replace sales in the traditional commercial district which have been displaced by the superstore.

· "Impacts of Development on DuPage County (Illinois) Property Taxes" January 1992. An exhaustive study conducted in 1991 by the DuPage County planning department that demonstrated"... there is a significant statistical relationship between new development (both residential and nonresidential) and increases in personal property taxes."

· The same study concluded that by attracting regional shoppers (who come from outside the community & therefore do not pay local property taxes), the superstore shopping center places higher demands on municipal services. The study concluded, specifically:

· New development that attracts regional shoppers actually COSTS the local government MORE money than it generates through the new development

· To pay for increased demand for services such as police protection, water and sewer, roads and infrastructure, local government must raise property taxes. Such increases disproportionately harm lower income households.

· A study by the Real Estate Services Group, of Washington, D.C. demonstrated that a typical downtown commercial building that has been vacated costs the community the following amounts each year:

· $125,000 in direct retail sales

· $70,125 in secondary re?ail sales

· $15,000 in salaries

· $6,000 in rents

· $625 in property taxes

· $5,600 in business profits

· $4,750 in bank deposits

· $3,400 in utility collections

· $13,414 in loan demand

· $2,000 in lost advertising revenues

2.2   Q.   What are the tax benefits of additional big box retailing versus its costs both hidden and obvious?

TPA Response:

Absent knowledge of the big box occupant net impact can only be estimated, but the impressive oversupply of retail space in our area strongly suggests that the net effect will be negative. One of the Chamber of Commerce panelists recently stated in Easton that for every $1 in revenue collected the associated direct cost to the taxpayer is $1.12.

Expenditure potential and retail services presently offered must be seriously considered. See Exhibits A & I.

2.3 Q. Can the Town quantify the demand that additional big box retailing will place on public safety services?

TPA Response:

No. Absent knowledge of the big box occupant it is impossible to quantify the amount of public safety services costs. This is one of the reasons the Town should insist on having prospective occupants that testify before town authorities.

2.4   Q. Are the fiscal benefits and detriments associated with additional big box retailing different  from other types of development, i.e. residential, industrial?

TPA Response:

· Yes.

2.5 Q.    Are they greater or less?

TPA Response:

· Greater, because failed big box stores create empty hulks that are not easily used for other purposes.

Associated adjacent businesses will suffer from such vacancies.

2.6   Q. Are there studies done by other jurisdictions which can assist the Town in answering these questions?

TPA Response:

· Yes, the National Main Street Center has worked with over 1,100 municipalities in 40 states. See Exhibit K.

LDR, the company that completed the Revitalization Study in Easton, is an excellent source for this type of information.

2.7   Q. What fiscal impacts will additional big box retailing have on Talbot County?

TPA Response:

· Significant and negative impact. The existing retail space per capita (Easton only) is more than triple industry averages. See Exhibit L.

2.8   Q. What, if any costs related to infrastructure improvements should the Town require developers to pay?

TPA Response:

· ALL

3.0 COMPREHENSIVE PLANS SHALL ENCOURAGE ECONOMIC GROWTH

3.1  Q. What economic impacts will additional big box retailing have upon the private sector economy in Easton? Direct property value impacts on adjoining or nearby property?

TPA Response:

Studies of more than 30 Iowa communities conducted by the Main Street Center showed that commercial valuation in traditional commercial districts where a big box store has had a presence for at least seven years almost always declines in value. See Exhibit K.

3.2 Q. Effects on other retailing both in Downtown Easton and elsewhere? Existing shopping centers?

TPA Response:

Studies of 15 Illinois communities by the Illinois Institute for the Rural Affairs at Western Illinois University concluded that, when a large discount store opens, although some businesses gain customers (gas stations and restaurants) and other businesses lose customers (furniture, groceries, hardware, some apparel), the net effect on existing businesses is likely to be negative. See Exhibit K.

3.3   Q. Effect on unemployment?

TPA Response:

It can hardly reduce unemployment, which is now 1.6% in Talbot County, the lowest rate in Maryland. See Exhibit M.

3.4    Q.   Are retailing jobs the kinds of jobs Easton wants to encourage at this point?

TPA Response:

No. When queried, an official at the Talbot County Social Services office said that in our area, technology-related businesses are the ones that are needed because they pay well and provide needed benefits, whereas most of the manufacturing and retail jobs now available pay only $6 to $8 per hour which makes multiple jobs a necessity for even a minimum standard of living.

3.5   Q.   Are there sufficient persons in the labor pool to provide employees?

TPA Response:

No. Talbot County Social Services official said that Talbot County suffers from a

chronic shortage of workers, and new big box retailers would have to import a

work force or siphon off workers from existing businesses.

3.6 Q.   What supporting development, for example restaurants, will big box encourage and does the Town want these supporting developments?

TPA Response:

Studies have shown that large discount stores increase business for restaurants and gas stations. Easton seems adequately supplied with these businesses at present. See Exhibit K.

4.0 COMPREHENSIVE PLANS SHALL PROVIDE FOR "THE PREVENTION OF ENVIRONMENTAL POLLUTION" AND THE "STEWARDSHIP OF THE CHESAPEAKE BAY AND THE LAND IS A UNIVERSAL ETHIC."

4.1   Q. What environmental effects will additional big box retailing have upon the environment in and surrounding Easton? Is additional big box retailing in Easton consistent with stewardship of the Chesapeake Bay and the land?

TPA Response:

Additional big box retailing is not consistent with the stewardship of the Chesapeake Bay and the land. In its "Choptank River Basin Environmental Assessment of Stream Conditions" (Dail, et al, 1998). The Maryland Department of Natural Resources notes that further urbanization of the Choptank River watershed (which includes the Tred Avon River) will have a negative impact on its aquatic resources such as crabs, fish and waterfowl that rely on this important habitat. See Exhibit U. This negative impact will counter local and regional efforts to clean up the Bay and its tributaries. Under present stormwater and wastewater standards, additional big box retailing will negatively impact rivers around Easton, which are already listed as impaired by the Maryland Department of Environment.

4.2   Q. There are expressed concerns over the ability of the Easton wastewater treatment system to treat discharge adequately for the Choptank River How well does the Town fulfill its obligations currently?

TPA Response:

· Undetermined at this point. Easton's wastewater treatment plant's permit is presently up for renewal. New requirements can be expected.

· The Trappe wastewater plant has had to reduce the amount of pollutants it puts into a tributary of the Choptank River by 50% at a cost of $8M. Water and sewer rates will quintuple.

4.3  Q. Can the Town fulfill its obligations in this regard in the future?

TPA Response:

· Unknown, until the dimensions of its problem are defined by the new regulations Easton handles 10 times the Trappe total for wastewater. Additional big box retail development should be postponed until the details of the new permit are known.

4.4   Q. What is the effect of surface water run-off on the Tred Avon River?

TPA Response:

· Significant and deleterious. A recent professional study has revealed the presence of hazardous substances (as defined by EPA) in the Upper Tred Avon River at Easton Point. These substances, not found in nature, are the result of urban run-off. A second sample further down the river was practically devoid of these substances.

· The Upper Tred Avon has lost almost all its bay grasses in the last 30 years, and is already listed as impaired by the MDE. Additionally, some of the properties being considered for "big box development" drain into King's Creek. The mouth of

4.0 COMPREHENSIVE PLANS SHALL PROVIDE FOR "THE PREVENTION OF

ENVIRONMENTAL POLLUTION" AND THE "STEWARDSHIP OF THE CHESAPEAKE BAY AND

THE LAND IS A UNIVERSAL ETHIC"

4.1 Q. what environmental effects will additional big box retailing have upon the environment in and surrounding Easton? Is additional big box retailing in Easton consistent with stewardship of the Chesapeake Bay and the land?

TPA Response:

Additional big box retailing is not consistent with the stewardship of the Chesapeake Bay and the land. In its "Choptank River Basin Environmental Assessment of Stream Conditions" (Dail, et al, 1998). The Maryland Department of Natural Resources notes that further urbanization of the Choptank River watershed (which includes the Tred Avon River) will have a negative impact on its aquatic resources such as crabs, fish and waterfowl that rely on this important habitat. See Exhibit U. This negative impact will counter local and regional efforts to clean up the Bay and its tributaries. Under present stormwater and wastewater standards, additional big box retailing will negatively impact rivers around Easton, which are already listed as impaired by the Maryland Department of Environment.

4.2   Q. There are expressed concerns over the ability of the Easton wastewater treatment system to treat discharge adequately for the Choptank River How well does the Town fulfill its obligations currently?

TPA Response:

· Undetermined at this point. Easton's wastewater treatment plant's permit is presently up for renewal. New requirements can be expected.

· The Trappe wastewater plant has had to reduce the amount of pollutants it puts into a tributary of the Choptank River by 50% at a cost of $8M. Water and sewer rates will quintuple.

4.3   Q. Can the Town fulfill its obligations in this regard in the future?

TPA Response:

Unknown, until the dimensions of its problem are defined by the new regulations Easton handles 10 times the Trappe total for wastewater. Additional big box retail development should be postponed until the details of the new permit are known.

4.4    Q. What is the effect of surface water run-off on the Tred Avon River?

TPA Response:

· Significant and deleterious. A recent professional study has revealed the presence of hazardous substances (as defined by EPA) in the Upper Tred Avon River at Easton Point. These substances, not found in nature, are the result of urban run-off. A second sample further down the river was practically devoid of these substances.

· The Upper Tred Avon has lost almost all its bay grasses in the last 30 years, and is already listed as impaired by the MDE. Additionally, some of the properties being considered for "big box development" drain into King's Creek. The mouth of

King's Creek contains one of the most important wetland habitats in the State of Maryland, the Nature Conservancy's "King's Creek Preserve". The impact of pollution such as heavy metals generated from potential big box developments should be considered by the Town of Easton.

4.5    Q. Is it different for additional big box retailing than for other types of development? More harmful? Less harmful?

TPA Response:

More harmful since impervious surfaces (i.e. buildings and parking lots) will add more pollutants to an already threatened ecosystem.

4.6  Q. The Maryland Department of the Environment is planning to issue new surface water treatment standards. Will adherence to these standards improve the quality of run-off? When will these standards be effective?

TPA Response:

Definitive answers must await the issuance of the standards, but we can expect increased stringency. The Easton Zoning Ordinance requires that site plans improve water quality (Sec. 8 p.14).

4.7  Q. What effect will big box retailing have on noise, illumination, air quality, and visual characteristics of the Town?

TPA Response:

· Additional big box retailing will generate more noise, illumination and air pollution. Anything that damages the vitality of the town center will be detrimental to its visual characteristics. Also, the visual characteristics of big boxes will be very prominent at the gateways to Easton, and will not be consistent with Easton's image as the "Colonial Capital of the Eastern Shore".

   5.0 COMPREHENSIVE PLANS SHALL CONTAIN "ADEQUATE PROVISIONS FOR TRAFFIC

      ALL OR ALMOST ALL OF THE LAND UPON WHICH ADDITIONAL BIG BOX RETAILING CAN

           CURRENTLY BE LOCATED IN EASTON IS ON OR CLOSELY ADJACENT TO ROUTE 50, ROUTE

322 OR BOTH.

5.1 Q.   Can Route 50, Route 322 and the secondary road system adequately handle traffic generated by additional big box retailing?

TPA Response:

· We doubt it seriously. Traffic is already a problem in Easton. Route 50 is loaded particularly with through beach-bound traffic and is a significant impediment to cross-town traffic. More retail traffic, particularly out-of-town customers, would further exacerbate the situation.

· "The responsibility of the Town is to provide high-quality community services and facilities to guarantee public health, safety and welfare, and to enhance the quality of life of those who visit live, or work in Easton" (Comprehensive Plan, pg. 77).

· According to the Traffic Group Study of 7/31/98 the current SHA Level of Service

rating for the intersection of Rte. 50 and MD Rte. 322 in the evening peak hour on

Friday is "E" with "F" meaning failure. See Exhibit T for daily loads.

· Easton's location makes the town a gateway for everyone travelling to and from Saint Michaels, Oxford, Trappe or beyond

· The proposed big box shopping centers will ove4oad the road network and create barriers. See Exhibit N.

· Free flow of traffic through and around Easton to other areas of the county is vital in order to promote tourism. Such traffic will inevitably be restricted by the growth associated with new big boxes.

5.2 Q.  What are the current capacities and anticipated traffic volumes of Route 322, Route 50 and Route 33 over the next five years? Does the SHA have any plans to improve conditions on those roads? How much traffic will additional big box retailing generate?

TPA Response:

· Exhibit T shows the current traffic volume. Pending further information from the SHA, a 10% annual increase based on population seems reasonable.

· Mr. Parker Williams, State Highway Administrator said he predicted that traffic on Rte. 33 to Saint Michaels will increase 30% next year.

· Easton has experienced a disproportionately rapid increase in retail development over the last 10 years when compared to our population growth. Thus, the traffic volume has also disproportionately increased and has begun to clog our arteries.

· The MD SHA stated in 1998 that there were no plans for road improvements, other than resurfacing/ maintenance, on these roads for the next 20 years. (The Saint Michaels Rte. 33 Bypass and the Dover Rte. 331 Bridge replacement were two projects under consideration during that time). See Exhibit 0.

· Again, absent knowledge of the occupants of proposed big boxes, it is difficult to quantify traffic impact. This is a task for an independent professional analyst. On average, we are told that a big box home center generates 25,000 customers per week, supermarkets 10,000 customers per week (industry average) and consumer

electronic big box stores 15,000-18,000 customers per week. None of these figures factor in store deliveries from outside suppliers.

Clearly, any savings to the consumer as a result of big box discount retailing will be bought with higher taxes for city and county residents. Such savings will also be costly in terms of a deterioration of our downtown district.

5.3  Q.   Can the Town and the public obtain more accurate information regarding volumes of

traffic?

TPA Response:

Yes. Additional information can be obtained from the retailer occupant and comparable store data coupled with testimony from an independent traffic consultant.

5.4   Q. Most or all of the potential additional big box retailing sites are also served by the secondary road system of Talbot County: Black Dog Alley Chapel Road, Glebe Road, Goldsborough Neck Road Are these roads capable of handling larger volumes of traffic which will be generated by additional big box retailing?

TPA Response:

No. These narrow secondary roads could easily be saturated with additional traffic from big boxes. Not only would movement be slow on such roads, but life for those citizens who live on or close to them would be unpleasantly impacted. These roads were not designed nor constructed to handle such traffic. Upgrading and maintaining them will cost the taxpayer dearly.

5.5 Q.  In the 1980's and early 1990's, the Town approved Carleton Business Park which now features Wal-Mart and Giant. ft was anticipated at the time that the arrangement of Elliot Road, Route 328 and Route 331 would be adequate for that development what can the Town learn from that experience?

TPA Response:

We have traffic congestion problems at both ends of Elliot Road and a proposed Staples will only exacerbate the problem.

What we learned from this experience is that this area was not designed to handle the increase in customer and truck traffic that we now experience. Further, a complete build-out of available space will aggravate this situation.

5.6   Q.   What degree of cooperation and coordination can the Town realistically anticipate with the County and SHA as demands on road systems increase as a result of additional big box retailing?

TPA Response:

· Only the town authorities can make such an appraisal.

· A Capital Improvement Plan should be developed. (Comprehensive Plan, pg. 26).

· Such a plan provides for the orderly addition of improvements at a rate needed to accommodate anticipated growth. It provides the vehicle for elected officials to set priorities and to make the most efficient use of available funds. There is a danger in letting capital improvements follow rather than lead the development process. The recent joint town-county exploratory meeting was encouraging, but more is required with town-county growth factored into planning. The big box Moratorium and study is a first step, although a county-wide study involving

Easton, Oxford, St. Michaels, and County authorities is recommended. Further, the subject is important enough and complex enough to justify the expense of participation by a professional planning firm.

5.7   Q. If additional big box retailing will require significant changes to our street system, are the residents of Easton willing to tolerate the changes to traffic patterns and streets and highways to accommodate additional big box retailing?

TPA Response:

No. As residents have repeatedly testify in public hearings and elsewhere, they are deeply concerned about growing congestion.

5.8 Q.   Should the Town adopt minimum standards of service for affected road systems for future development proposals in the Town?

TPA Response:

Yes. The Comprehensive Plan states the following:

· The Town is required to develop an infrastructure master plan, which should include a working transportation master plan. Included in this master planning process are Small-Area Plans. Two areas recommended were the Route 50 Corridor and the Easton Parkway Corridor.

· The critical concerns for these two corridors are detailed in Comprehensive Plan, pg. 40, lines 22 through 24, and pg. 41, lines 1 through 7.

6.0    COMPREHENSIVE PLANS SHALL PROVIDE FOR 'THE PROMO HON OF GOOD CIVIC DESIGN AND ARRANGEMENT "PROFESSOR DIRIKER STATED AT THE GROWTH SYMPOSIUM THAT DOWNTOWNS FUNCTIONS AS PLACES TO CONNECT PEOPLES WITH GOODS AND SERVICES THEY NEED OR WANT AS TIMES HAVE CHANGED. THE PEOPLE, THE GOODS AND THE SERVICES HAVE CHANGED AND WILL CONTINUE TO CHANGE IN THE FUTURE.

6.1 Q. Will the buildings in which big box retailing is located prove to be flexible in meeting

changing needs and demands?

TPA Response:

· No, all big box retail stores are nearly identical, predominantly single use facilities.

· Empty big box buildings are not at all conducive to renovations for smaller occupants. These buildings are constructed to specifications that are very particular to occupant needs, and are essentially single-purpose buildings.

· Renovations for accommodating smaller retailers are extremely costly. For example, setting up separate utilities for each store is very expensive.

· The cost of partitioning a megastore is very high, perhaps approaching original construction costs. These stores are often 200 feet deep with tall ceilings. Since small retailers are more interested in wider storefronts, this makes the space undesirable for their use

· Refer to Exhibit P for information on typical store prototype sizes.

6.2 Q. Does the town want to encourage/permit/prohibit this particular means to connect

people with goods and services?

TPA Response:

Discourage - particularly in view of Easton's present overstored condition. Big boxes are a satisfactory way of connecting people with goods and services, but that is not the problem; rather, it is the direct and indirect cost associated with additional big box retailing especially as it relates to our downtown district.

6.3  Q. What is the cu~rent life span for big box retailing, particularly in light of the emerging alternate technologies for commerce?

TPA Response:

· Since big box retailing is a relatively new phenomenon, the question may be unanswerable at this point. E-commerce is rapidly changing the retailing landscape. See Exhibit Q for press coverage of this issue.

· Exhibit R depicts the cycle(s) of big box retailing.

· The retail industry is consolidating at unprecedented levels creating great uncertainty for the small chains and "mom & pop" retailers.

6.4   Q. what mechanisms should be imposed in the event that a big box becomes vacant? Guarantees? Bonds? How have other communities converted vacant big boxes to other uses?

TPA Response:

· Little can be done. Future use of the property cannot be legislated by the town or county. Developers may lease the vacant building to anyone they choose, which can include any of a number of non-retail businesses with no need for attractive appearances, e.g. warehouses, freight companies, etc., leading to the risk of creating unsightly areas of commercial development.

· Big boxes will close stores to build larger facilities elsewhere to preserve market share. In some cases, it makes economic sense to keep the store vacant or out of competitive hands.

· Vacant big boxes will be converted for any purpose permitted by zoning ordinance including flea markets, training schools, civic organizations, amusement malls, storage facilities, etc.

· Vacant periods can be long. In Portland, ME an 85,000 square foot HQ box is still mostly vacant after 5 years of active attempts to lease or sell. See Exhibit S.

6.5 Q. What is the current ratio of commercially zoned, residentially zoned, industrially zoned and institutionally zoned property in Easton? what is the ratio of developed to undeveloped property in Easton? How do these ratios compare to similar communities in this region?

TPA Response:

· The ratios mentioned above are highly changeable, as developers will often seek rezoning and annexation to suit their purposes.

7.0   AS SUGGESTED BY MARGARET PICKALL, CHAIRMAN OF THE PLANNING COMMISSION, WE HAVE ADDED SPECIFIC QUESTIONS TO BE ADDRESSED BY BIG BOX RETAILERS:

7.1 Q. What is appealing to retailers about Easton?

TPA Response:

· Lack of competition from national/regional chains.

· On a comparative basis, lower real estate costs.

7.2   Q.   What are the closest locations of stores of equal size to those proposed for Easton? what are the big box retailer  volume expectations in terms of numbers of customers? 

TPA Response:

Please refer to map at Exhibit C.

7.3 Q.   What are the closest locations of stores of equal size to those proposed for Easton? what are the big box retailer   volume expectations in terms of numbers of customers?

TPA Response:

· Please refer to the big box overview at Exhibit P.

· Perspective big box retailers should be obligated to testify before the Easton Town authorities on this subject.

7.4  Q.  Now?

TPA Response:

Retailers should testify on this subject

7.5 Q.   In 5, 10, 20 years?

TPA Response:

Unknown.

7.6 Q.   When would expansion be required?

TPA Response:

They will expand.

7.7 Q. How would it be accomplished?

TPA Response:

The quickest, easiest most inexpensive way possible.

7.8   Q. Is it possible for the retail shopping opportunities that are offered by big box stores to be made available in Easton through other mechanisms, for example "Home Depot Village Concept" or be retrofitted into existing shopping centers?

TPA Response:

· Typically, big box stores rarely deviate from their standard store deployment program.