Summary of Reasons in Support of the Proposed Zoning Text Amendment

The proposed text amendment will not change the regulations relating to any other zone
districts in Guilford.

This application is narrowly tailored to apply to the SCW zone district and would not
affect any other zone district in Guilford. Moreover, the SCW zone district is limited to
the area west of the I-95 Exit 57 interchange and north of U.S. Route 1. To the extent
that any other property owner in Guilford might consider proposing a discount club, such
a proposal would require Commission approval, after a public hearing, of either a
property rezoning or a zoning text amendment

The SCW zone district already allows multi-tenant retail buildings up to 150,000 square
feet in size, and up to 200,000 square feet in size with special permit approval.

As a general matter, overall building size is not an issue in this proposed text amendment.
Costco and DDR propose to amend the regulations to provide that a discount club would
be allowed in the SCW zone district and that a single discount club could be up to
150,000 square feet in size. Thus, under this proposal, the maximum size of a discount
club would be no larger than the maximum size of a multi-tenant retail building already
allowed by the regulations.

The proposed text amendment is consistent with the Guilford Plan of Conservation and
Development (POCD).

The proposed text amendment is consistent with the intent of the SCW zone district and
the important POCD policy to encourage economic development on appropriate sites in
Guilford. In particular, the Rockpile property was assigned the SCW zone designation
rather than a mixed use zone, indicating its appropriateness for larger scale retail
development.

A discount club is a form of retail use that is appropriate for the SCW zone district.

A discount club generally includes a limited number of items for sale, called “SKUs”
(stock keeping units), compared to general retailers. For example, a typical Wal-Mart
offers over 100,000 different SKUs in a single store, while a typical Costco offers
between 4,000 and 5,000 SKUs in a single warehouse of similar size. Because patrons of
a discount club generally shop less frequently, The Institute of Transportation Engineers
recognizes that the peak hour traffic generated by a discount club is somewhat less than
general retail on a per square foot basis.
The proposed zoning text amendment will enhance the opportunities for tax positive
development to occur in the SCW zone district.

The SCW zone district has already been designated as a location that is appropriate for
commercial development. Moreover, the Property is the only remaining significant area
of undeveloped land within the SCW district.

The proposed zoning text amendment includes a set of signage regulations for a discount
club.

This text amendment proposes the addition of sign requirements that would be
appropriate for a discount club. Many of the general sign provisions (such as prohibited
signs) are substantially identical to the current regulations. These sign requirements
would not apply to any other uses or zone districts in Guilford.

All of the other bulk and dimensional requirements contained in the SCW district would
continue to apply to a discount club.

In addition to maximum building size, the existing SCW regulations include other bulk
and dimensional requirements that shape the character of development in this zone
district. None of these standards would be changed by the proposed zoning text
amendment.

The proposed text amendment includes strict standards for the sale of gasoline.

The proposed text amendment would allow motor vehicle fuel sales as an accessory use
to a discount club, subject to six criteria that must be satisfied. From an environmental
standpoint, these criteria are consistent with recognized best practices across the country.

From a traffic standpoint, the feasibility of the SCW zone district to safely accommodate
150,000 square feet of retail space has already been demonstrated.

State law requires major traffic generators to apply for and receive approval of a
certificate of operation from the State Traffic Commission (STC). Guilford Commons
was reviewed by the STC and approved, and a certificate of operation was issued for the
project (see Tab 9). Any proposal for a discount club at the Property will also require
review and approval by the STC before a building permit can be issued. But, based upon
accepted methodologies of studying traffic impacts, a 150,000 square foot discount club
should generate less peak hour traffic than the same amount of general retail and
restaurant space.

From a wastewater discharge perspective, the feasibility of the SCW zone district to
accommodate 150,000 square feet of retail space has already been demonstrated.

The specific details of any an application by Costco must be reviewed and approved by
the CT DEP – but the general feasibility of the SCW zone district to accommodate
150,000 square feet of retail space has already been demonstrated (see Tab 10), and the
text amendment itself does not propose anything to change this.