Monday, September 24, 2018

GMSD Student Projection Analysis Fails to Consider Likelihood of New Multi-Family Projects

In this post I examine the GMSD analysis that administration allies are misleadingly touting to "prove" that new Smart Growth residential projects will not cause school overcrowding. I begin with an abstract because of the length of this post.   

GIGO-The quality of the output is dependent on the
quality of the input

GMSD has prepared an analysis and associated graphics that administration allies are touting to "prove" that future Smart Growth residential projects will not overcrowd our schools. In this post, I will drill down on the assumptions underlying the GMSD data. 

The following graphic, hereinafter referred to as "GMSD Chart 1", is typical of the misleading information currently being circulated by administration allies. It purports to show that, upon completion of Forest Hill Elementary, the City will not need another K-5 school, even after the full build-out of all vacant land in the City:

GMSD Chart 1 Click to enlarge, this chart is HIGHLY misleading

1.  GMSD Chart 1's most glaring flaw is its assumption that, with the exception of the four apartment projects currently exempt from the moratorium, no additional multi-family projects will be built. This graphic unrealistically assumes, in other words, that the apartment moratorium now scheduled to end in July 2019, will be extended permanently, and that the only projects built in the future will be either commercial projects or single-family homes. Superintendent Manuel, during a recent HMS PTO meeting, acknowledged that GMSD's analysis assumed that no new multi-family projects will be built in the Smart Growth areas. His explanation: "I can’t predict what is going in T3, T4, T5. That is for the City to take those things into account."

2.  GMSD Chart 1 further assumes, unrealistically, that any vacant land intended by its owner to remain undeveloped will forever retain that status throughout perpetuity.   
3. GMSD Chart 1 also unrealistically assumes that residential densities will never be increased, and that zoning classifications will not change. 

4.  GMSD Chart 1 incorporates a demographic study that assumes a student-to-residential-unit ratio that may be too low. More specifically, the study assumes that properties that change ownership will have the same ratio as the one that  GMSD uses when making projections for the entire pool of city-wide properties. Anecdotal evidence based on residents' conversations with their newest neighbors suggests that people typically move to Germantown for its schools, thus further suggesting that a higher ratio should perhaps be used for the subset of properties that recently has changed ownership. Additional study should be undertaken.

Below is a graphic that I prepared (Chart A). Unlike GMSD's Chart 1, my chart accurately reflects the data used by GMSD. Question marks denote the missing data from future Smart Growth multi-family projects-- data that, as acknowledged by Mr. Manuel, must, if and when new Smart Growth residential projects are planned, be supplied by the City so that the future student projections can be updated.

Chart A prepared by Shining a Light on Germantown


GMSD uses the following color-coded map in conjunction with GMSD Chart 1. I will begin my analysis with this GMSD Map because it will facilitate my discussion of the faulty assumptions underlying GMSD Chart 1.

GMSD Map Chart 2 Click to enlarge

Some, but not all, of the color-coded areas located on the map are also represented in GMSD Chart 1. Only those areas that GMSD assumes will supply future students are shown on the Chart 1. Note, in particular, the absence of any reference to the Smart Growth areas (colored blue, and labeled on the map  "Zoned T3, T4, or T5") on GMSD Chart 1.

Let's begin by looking at the areas that GMSD actually does include in GMSD Chart 1 in order to calculate its projection of a total of 2,881.2 K-5 students. As you can see, GMSD's projection starts with current K-5 enrollment (2,487), and then adds the following:

a. 96 K-5 students predicted from GMSD's "Demographics" study.  

b. 73.2 K-5 students from "Undeveloped/Vacant Lots".  This portion of the city is depicted on the map in the coral-colored areas.

c. 57 K-5 students from "Approved Single Family Residences" (yellow on the map).

d. 168 K-5 students from "Approved Multi Family Residences" (lavender on the map). This portion includes only the four projects currently exempt from the apartment moratorium-- Thornwood, Viridian, Watermark, and Center City.

In calculating the number of students for each of the above four categories, GMSD used a 0.31 student-per-residential-unit ratio. This is the ratio that GMSD has been using for the last year or so. The 0.31 ratio is spread out equally among each of the thirteen K-5 grades.

Deficiency Number 1:  GMSD Chart 1 Assumes There Will Be No New 
Multi-Family Residential Units Built In The Smart Growth Areas (blue areas on the map). 

GMSD Chart 1 omits in its entirety the blue areas shown on the map-- that is, the portion described in the Legend as "Zoned T3,T4, or T5". By this omission, GMSD Chart 1 unrealistically assumes that no currently undeveloped land in the blue areas will be used for multi-family residential projects. According to GMSD Chart 1, the only undeveloped land that will supply future students is located in the coral areas on the map. As I explain below, any residential units built on the undeveloped land in the coral areas will, according to GMSD's analysis, be limited to single-family homes.

In order to correct the misleading aspects of GMSD Chart 1, I 
made two changes that are shown above as line items in my Chart A. First, I make it clear to the reader that the coral areas on GMSD's map will supply only students from single family homes:

Graphic prepared by Shining a Light on Germantown
 Second, I add to the categories listed in GMSD Chart 1 a new category that tells the reader that the Smart Growth areas designated T3, T4, or T5 (blue on GMSD's map) possess the potential to supply K-5 students from multi-family residential units: 

Graphic prepared by Shining a Light on Germantown

I could not, of course, estimate the number of K-5 students who might come from undeveloped Smart Growth areas. As Mr. Manuel readily states, who knows what will happen after the apartment moratorium expires?

Coral Areas- In order to understand that GMSD Chart 1 assumes that the coral-colored areas on its map (GMSD Chart 2) will supply future K-5 students only from single-family homes, we must next examine another GMSD graphic (GMSD Chart 3):

GMSD Chart #3

As you can see, all of the listed properties, totaling slightly over 200 acres, are zoned residential with the exception of two small T4 Smart Growth areas (#28 and #30). Land within these two small T4 areas could potentially be developed as multi-family residential projects; however, GMSD has chosen to assume that the coral portions, in their entirety, will be developed solely as single-family homes. I say this because GMSD Chart 3 assumes a density of three units per acre for these two T4 areas. I could have parlayed GMSD's failure to note the potential for multi-family development in these T4 areas into another "deficiency"; however, because these areas are small, I let this slide. I thus do not discuss this omission in a separate section; however, I did note the omission by the use of double asterisks on my Chart A.

Note also that most of the Cordova Triangle is in the coral-colored portion of GMSD Chart 3. I take no issue with this because this area is currently zoned single-family. It is worth noting, however, that a number of the members of the Planning Commission have expressed a willingness to consider denser zoning for this area at a later time. See Planning Commission Votes to Return Cordova Triangle to Residential Zoning, at Least for Now.

Blue Areas- As I have previously explained, GMSD Chart 1 assumes that no new students will come from the undeveloped land located in the Smart Growth areas. GMSD bases this assumption upon the premise that all of the vacant lots in the Smart Growth areas will be office or commercial projects, or simply remain vacant. By law, however, multi-family residential projects, including apartments, are permissible in these areas. The blue areas, as you can see, dwarf the coral portions in size, and, given the higher residential population densities permitted in areas covered by a Smart Growth overlay, have the potential to provide substantially more students than do the coral areas.

GMSD's assumption that no new multi-family projects will be built in the blue areas flies in the face of Smart Growth's 
"live, work and play" central theme. The assumption thus makes no sense. Smart Growth is premised on the proposition that people bike to work, and walk from their residential units to the laundromat, shoe repair shop, coffee shop, etc. GMSD Chart 1's rosy projection that the City will need no new K-5 schools is, therefore, wholly incompatible with the City leadership's devotion to Smart Growth.

Consider, for example, the Forest Hill Heights T-5 area located south of Winchester in the southeastern part of the City. 
Although it contains a few commercial projects, this area is, for the most part, currently undeveloped. This T5 area contains over 200 undeveloped acres, and its T5 status permits the construction of multi-story apartment and mixed-use buildings.   

Does anyone seriously believe there will be no additional multi-family projects built in this area? To hold such a belief, one would have to completely discount the BMA's December 2017 decision to remove all residential density limits in this area (from 12 residential units per acre to no density limit). There would have been no need for removing density limits if the City did not anticipate the construction of more multi-family projects. I venture to say that the current administration, as soon as the apartment moratorium expires in July 2019, will approve mixed-use (commercial plus residential) developments for this area.    

In order to flesh this point out a little further, I remind you of a dialogue that took place at the July 23, 2018  BMA meeting, between Alderman Massey and Director of Economic Development Cameron Ross. Following the BMA's December 2017 decision to remove the residential density limits, there was confusion concerning the scope and purpose of the action taken by the BMA. Alderman Massey sought clarification about the purpose of that action at the July 23 meeting. In response, Mr. Ross, in full Smart Growth mode, explained that future residential density levels would be decided on a project-by-project basis, taking into account all the uses in the area. 
Here is the specific exchange on that one point at the July 23 meeting. Alderman Massey attempted to seek additional clarification, but Mayor Palazzolo did not allow Mr. Massey any followup questions.

Before leaving Forest Hill Heights, I must, for the sake of completeness, discuss the Watermark project and briefly recall its recent turbulent history. Watermark is located in the Forest Hill Heights T5 area, but, like the other three projects excluded from the current moratorium, it is placed in a lavendar-colored portion of GMSD's map (Chart 2). Subsequent to its exclusion from the moratorium, Watermark was voted down by the BMA because of concerns regarding certain actions taken by the developer. As GMSD's analysis itself recognizes (because it includes Watermark in the lavender portion of its map), the City's current leadership will almost certainly approve another multi-family project in Watermark's place after the apartment moratorium is over. When the BMA rejected Watermark this past July 23, two aldermen, Gibson and Owens, made it clear that their only concern was with the actions of the developer, and Alderman Janda actually voted to go forward with Watermark. Aldermen Massey and Barzizza were the only ones who noted their objections to the construction of an apartment complex in this area. 

I anticipate that some might argue that GMSD's recognition of the likelihood of a replacement for the now-unapproved Watermark signifies that GMSD Chart 1, contrary to what I have explained in this post, does not assume that the moratorium will be extended indefinitely. The argument, I suppose, would be that approval of a replacement could be accomplished only if the moratorium expires. My response is that the replacement would simply be a Watermark 2.0 that would enjoy the same exempt status accorded to its predecessor. We must not lose sight of the overriding fact that GMSD Chart 1 does not take into account the probability that multi-family projects, in addition to the four previously exempted from the moratorium, will be built in the Smart Growth areas.

Recent events concerning Carrefour, just like those surrounding the Forest Hill Heights T5 area, also illustrate the absurdity of GMSD Chart 1's projection that we will need no additional K-5 schools. Carrefour's owner has been openly pitching for an exemption from the apartment moratorium, as have the Chair of the Economic Development Commission, the Germantown Chamber of Commerce, and Alderman Janda. Located in the Western Gateway portion of the Smart Growth area, Carrefour lies within an area subject to T5 and T6 overlays that permit the construction of multiple-storied mixed-use projects. As you can see from the image below, the Germantown Small Area Plan for Poplar Avenue West (also called Western Gateway) envisions several stories of residential units over storefronts: 

The chart below lists the components of two possible density options. As you can see, one version calls for as many of 2,181 residential units.
From Small Area Plan
If the entire Western Gateway area (blue on the map, which includes Carrefour) were to be built with 2,181 residential units (likely apartments), it would supply an additional 676.11 K-12 students (using GMSD's 0.31 student-per-residential-unit ratio). The projected number for Riverdale Elementary K-5 would be 312 students, and that for Riverdale Middle would be 156 students. You can find my most recent post about the Carrefour plans here.   


At a recent September 14 HMS PTO meeting, Superintendent Manuel, in response to a question, commented on GMSD's decision not to include the large Smart Growth area in Forest Hill Heights as a potential source of future students. A parent posted the video of Mr. Manuel's presentation, including the subsequent Q & A, and it can be accessed in full here on YouTube. The audio is a bit challenging (hint-turn up the volume all the way). You may start at this point,  Here are some snippets from his comments:

"There is nothing being considered [there] now."

"At any time that the City goes in and changes the zoning, and if they change it to multi-family, it was commercial at the time I was looking at it."

"Know that at any time that the City goes in and changes zoning-- If they change it to multi-family and they approve a unit to go in there besides the Watermark, that changes..... that is why I am very specific about my calculations."

"I can’t predict what is going  in T3, T4, T5. That is for the City to take those things into account."

Mr. Manuel is overlooking recent Smart Growth history-- in particular, the ease with which developers may use Smart Growth to gain approval of multi-family projects. When seeking to develop property that is subject to a Smart Growth overlay, a developer has a choice. The developer may simply apply for a project that already fits the use permitted by the property's underlying zoning, or the developer may invoke the process created by Smart Growth and thereby avoid being confined to the use specified by the underlying zoning status. Precisely because the Smart Growth process does not confine developers to the underlying zoning, developers usually go that route. We know, from the multi-family projects approved just during the last two years, that Smart Growth is a convenient tool by which a developer can gain approval of a Watermark, a Viridian, or a similar project.

During the PTO meeting, Mr. Manuel, to his credit, acknowledged that he is "not a City planner, and not a demographer". It is up to the City, he said, to determine the future student projections necessitated by any residential growth that may take place in Smart Growth areas.  

I appreciate Mr. Manuel's candor, and, of course, I agree that it is impossible to predict the City's future actions. That said, we cannot fall into the trap of relying on a fancy graphic that misleadingly projects that there will be no new multi-family units in the Smart Growth areas. 

Bottom line prediction: If we continue unabated on the "Smart Growth" path, we will definitely need another K-5 school (unless, of course, we love portables and overcrowded classrooms).  Don't be fooled: The administration is using GMSD's Chart 1 to deceive us into believing that additional multi-family projects will not necessitate the construction of a new K-5 school. The fact is that the GMSD charts assume no additional multi-family projects. Touting the GMSD analysis to justify additional Smart Growth residential projects is nothing but a subterfuge.

Don't just take my word for the proposition that new multi-family projects would beget a new school. Mr. Manuel himself, this past January, said the exact same thing:

"If they do approve all these apartments in the city, something that would present a difficult challenge for the school district, then our request from the City would be to fund another elementary school, and more capacity at the middle school."  
See my 01-27-18 post

Deficiency Number 2--
 GMSD Chart 1 Assumes, Unrealistically, That Any Vacant Property Intended By Its Owner to Remain Undeveloped Will Forever Retain That Status Throughout Perpetuity. 

GMSD's Chart 1 assumes that no future K-5 students will come from property intended by its owner to remain undeveloped. These properties are contained within the gray areas on GMSD's map (Chart 2). Mr. Manuel has candidly acknowledged that this is problematic. Intentions change, after all, as land changes hands. Future generations often differ from their ancestors on how land should be treated. When their status changes and they become available for development, these properties will supply future students and will need to be included in the projection.

Deficiency Number 3: GMSD Chart 1 Unrealistically Assumes Zoning Classifications Stay The Same And Residential Densities Will Not Be Increased.

GMSD Chart 1 assumes that the residential densities will never be increased. Considering the number of times the Planning Commission and the BMA have increased the density of residential projects just over the past year, whether in Smart Growth or purely single-family areas, this is a ridiculous assumption. Just off the top of my head, I can think of three projects where residential densities were increased-- Viridian and Watermark (Smart Growth) and the Reaves development (single-family). Of course, as I have previously explained, I suppose one could say there will be no increases in residential density 
in the 278-acre Forest Hill Heights T-5 area, for the simple reason that, this past December, the BMA removed residential density caps in their entirety

Deficiency Number 4: The Demographic Study Commissioned by GMSD May Be Significantly Understating The Student-to-Residential-Unit Ratio In Recently Sold Homes And Condos.

I have heard from a number of citizens who question the demographic study's projection that the future student population will level off in the next few years, and eventually decline. GMSD, in its first few years, experienced a steep growth in the student population. Parents who have looked at the projections want to know why this steep growth would not continue. They advocate using a straight-line projection of the current trend.

Here are the demographer's K-5 student population  projections:

Total District Enrollment, Actual in Green, projected in blue, by Demographers
The total student population in the above chart includes both resident and non-resident students. This explains why the first three columns of figures above do not match the resident-only population shown below in a chart prepared by GMSD. (In the future, GMSD plans for no new non-resident students, other than the children of GMSD employees.)    

These figures are based on resident student enrollment, prepared by GMSD
Why, parents ask, would GMSD's demographer not use the same growth rate experienced by GMSD in its first four years, in projecting future growth? As you can see in the above GMSD chart, in the past four years (2015 through 2019), the resident K-5 enrollment has increased by 308 students. Yet, the demographer projects a gain of only 15 students (2,709-2,694) between 2019 and 2023. And by 2026-27 a decline in K-5 student population is projected.

Those who question the projections feel that the demographer did not fully take into account the number of GMSD children produced by families who move into homes sold by seniors who choose to downsize. 
If families are moving to the City specifically for the schools, it is likely that the student-to-residential-unit ratio is higher in homes that have recently changed ownership.  

Here is just one of the many anecdotal reports I have heard from residents:  

"There are 20 houses on my one street neighborhood. 3 empty nester houses sold in the summer adding 10 school age children. Our street had 9 kids before. More than doubled the number of kids in 3 months."

I realize this parent is referring to only three homes, but who knows the extent to which this same nester-to-young-family phenomenon has occurred through the entire city? It is hardly farfetched to think that the proper ratio for this subset of homes should be higher than 0.31. 

Parents also take issue with the demographer's assumption that the percentage of private school students will remain constant. They have observed an increase in the number of families who have moved their children from private schools to our fine public school system.  

At the September 14 HMS PTO meeting, alderman candidate Jeff Brown asked Mr. Manuel about the demographer's projections. You may listen to Mr. Manuel's answer on the YouTube I linked above. Mr. Manuel defended the demographer's projections, stating that there was, in GMSD's early years, a disproportionate shift of students from GES (Shelby County Schools) to GMSD that will not be repeated in the future. Mr. Manuel also pointed out that the demographer's projections for 2018-2019 were accurate. He further noted that the demographer would re-examine the figures
 after the 2020 census.

We do not have sufficient data at this time to determine the validity of the parents' belief that the demographer should have used, for the subset of properties that change ownership, a student-to-residential-unit ratio higher than 0.31. The requisite data could easily be obtained by sampling the GMSD enrollment percentage in recent home sales. As much as I like data, I have no background in either demographics or market research. For now I will accept the "96" demographics line item in the GMSD Chart 1 above, with the caveat that, given what I have heard from parents, there is a serious question about whether the demographer's projections are understated. And if they are, it goes without saying that the 2,881.2 K-5 students projected would need to be increased. Of course, as I have previously explained, the 2,881.2 projected total student figure is, in any event, grossly misleading for other reasons. 

Approved Housing (57, Yellow On Map) And Apartments (168, Lavender On Map) 

I accept GMSD Chart 1's projections for the Approved Housing (57 students) and Apartments (168) categories-- hence, there are no asterisks for these categories on my Chart A. 


I could have discussed middle and/or high school numbers; however, in order to avoid belaboring an already lengthy post, I chose to focus only on K-5 projections. Please understand, though, that the flaws I have illuminated in this post also plague the projections of middle and high school students. And, let's not forget we already have an overcrowding problem at the middle school level.  

Please also understand that I am not saying GMSD's analysis is a worthless undertaking. The analysis actually contains some useful information. What I am saying is that we cannot take at face value the ridiculous claim, now being asserted by administration allies, that we will need no new capital expenditures for schools other than those already under consideration. We must be not be swayed by the specious claim, advanced by administration allies, that Mr. Manuel says we need not worry about new residential Smart Growth projects crowding our schools. 

Let this be a lesson to all of us: Don't rely solely on conclusions presented in a fancy graphic. EXAMINE THE ASSUMPTIONS UNDERLYING THE CONCLUSIONS! Understanding the assumptions in this instance is critical to avoid being deceived by misleading, politically motivated pronouncements. Do not be fooled!

If an alderman or administation ally tells you that Jason Manuel says that. even with full build-out, we will never need a new K-5 school, answer thusly: "That is true only if you don't approve any new multi-family Smart Growth projects

The demographic study is found here on the GMSD website, and the GMSD analysis presented at the BOE Work Session can be accessed here


  1. Great, thorough analysis. Triangle is not R yet. It still has to get through the BMA. 2nd reading / hearing is tonight (9-24-18).

    1. Thanks, yes, I knew that. Since I knew it was a done deal that the overlay would be removed, and since it has an R underlying zoning, I decided not to go into any more detail. I had enough trouble trying to explain the on-off Watermark and how that fit in!!