substantially developed. He states that growth should extend gradually, so that the municipality can provide services. That makes eminent sense, rendering pell mell annexation unwise. History Forecasts Future In 2011 Brownsburg annexed ~ 2,143 acres, the it “East Annexation”, claiming was and can be for the Ronald Regan Parkway. Yet as identified by John Ayers, “needed used” this construction would have continued regardless. Testimony provided by Sabrina Graham & Kurt Disser specifies that even today, over five years later, almost all of this area remains undeveloped. Adding two plus two, if Town does not develop around a four lane parkway in five years, why do we believe it will develop cornfields within the next three governor elections? The proposed North Annexation Territory is not It is simply “needed.” “wanted” for tax revenue. That is the inescapable deduction, the only conclusion The Court sees. Evidence presented indicates that even if the Court were to believe some of the area was and can be these areas account for only a tiny percent of the annexation “needed used”, territory and does not support the annexation of territory that will increase the size of the Town by 50%. The evidence of the in Exhibit 61 is plain. Areas truly “razor bladed holes” contiguous to the municipality boundaries have been segregated & excluded from the annexation territory. Evidence demonstrates that these segregated & excluded areas do not have town sewer & water services, areas apparently not needed. Yet Town claims to the large need Highland Springs/Highland Green subdivisions directly north of the segregated, excluded areas, the Highlands already connected to town water & sewer services.
substantially developed. He states that growth should extend gradually, so that the municipality can provide services. That makes eminent sense, rendering pell mell annexation unwise. History Forecasts Future In 2011 Brownsburg annexed ~ 2,143 acres, the “East Annexation”, claiming it was “needed and can be used” for the Ronald Regan Parkway. Yet as identified by John Ayers, this construction would have continued regardless. Testimony provided by Sabrina Graham & Kurt Disser specifies that even today, over five years later, almost all of this area remains undeveloped. Adding two plus two, if Town does not develop around a four lane parkway in five years, why do we believe it will develop cornfields within the next three governor elections? The proposed North Annexation Territory is not “needed.” It is simply “wanted” for tax revenue. That is the inescapable deduction, the only conclusion The Court sees. Evidence presented indicates that even if the Court were to believe some of the area was “needed and can be used”, these areas account for only a tiny percent of the annexation territory and does not support the annexation of territory that will increase the size of the Town by 50%. The evidence of the “razor bladed holes” in Exhibit 61 is plain. Areas truly contiguous to the municipality boundaries have been segregated & excluded from the annexation territory. Evidence demonstrates that these segregated & excluded areas do not have town sewer & water services, areas apparently not needed. Yet Town claims to need the large Highland Springs/Highland Green subdivisions directly north of the segregated, excluded areas, the Highlands already connected to town water & sewer services.
filed_Fight_FFCL_13Sept16.docx