Letters

An Open Letter to the New Castle Town Board Concerning the Form Based Code

We are part of The Trust Project

Dear New Castle Town Board,         

We are Asian immigrant families and their friends in New Castle and/or the Chappaqua School District. This letter is nonpartisan. We are a community with some shared core concerns, and respectfully demand that these concerns be heard, which means they are carefully reviewed, and responded to in good faith. 

The Open Letter to the Town Board of Oct. 18 presented our concerns: a) material information in the Draft Generic Environmental Impact Statement (DGEIS) is not credible based on our evidence, and b) public hearings should not continue when the public is misinformed of the material information. 

We include the evidence at the end of this letter.  We plead to the Town Board to respond to us publicly. 

This letter takes no position on the Form Based Code. We are only asking for reliable data for an honest discussion. We believe anyone who takes a few minutes to read our evidence will conclude the student enrollment numbers in the DGEIS are not credible. Different policy preferences will not scar the New Castle community permanently. However, the perception of a dishonest process will.     

The evidence was related to the enrollment projection. The DGEIS disclaims “[i]t is important to note that this source is over 10 years old, not specific to New Castle or Westchester County, and provides very conservative estimates” before presenting the estimated additional school enrollment of 96 students for the estimated additional housing units of 988. DGEIS 3-146; see Id. at 3-143. 

The 10-year-old source is the residential demographic multipliers produced by the Center for Urban Policy Research at Rutgers University. Id. at 3-146. The DGEIS did not follow the quick guide provided by the same center on correctly using their multipliers. (Listokin, David, et al. A Quick Guide to New Jersey Residential Demographic Multipliers.” (2006).)  

The guide explains the residential demographic multipliers should not be simplistically relied upon for areas known for the “quality of the local school district.” Id. at viii. New Castle is better-known than most places regarded as known for the “quality of the local school district.”

“The residential demographic multipliers contained in this document provide important statewide average benchmark data that can only go so far in accurately predicting the actual demographic impact of housing development in a specific community. For instance, a given community may attract ‘more’ … public school children per housing unit because of such differences as … the ‘quality of the local school district’ (e.g., households with more children may disproportionately self-select to live in communities with high-quality school systems).’ Id. at viii. “For best results, the state-level data presented here should be supplemented by local analysis, such as conducting case studies of the actual population, and especially public school children generation, of occupied housing developments comparable in character (i.e., type, size, price and tenure) and location to the subject development(s) being considered by the analyst.

For example, in quantifying the likely public school children generation from three-bedroom townhouses priced at $300,000 per unit proposed for Princeton Township, an analyst should first consider the “Quick Guide” statewide data for the average number of public school children (0.24) in housing of this type (single-family attached), size (three bedrooms) and price level (above median value).

The analyst should then identify comparable townhouses (e.g., three-bedroom units priced $250,000 to $350,000) that are occupied in Princeton and nearby communities and should then ascertain these developments’ actual public school children generation from public school data (e.g., busing and other information).

The combination of this document’s multipliers and local analysis provides a comprehensive framework for answering who lives in New Jersey housing. Id.

This letter was submitted by Zhengxi Liu of Chappaqua

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