DETERMINATION OF THE INCORPORATION REVIEW BOARD

October 28, 2020

In Re:

THE INCORPORATION OF A PORTION OF THE TOWN OF WRIGHTSTOWN,

BROWN COUNTY, WISCONSIN AS A VILLAGE

Case No. 2019-CV-896

John Brittnacher, Representative of the Petitioners

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TONY EVERS

GOVERNOR

JOEL BRENNAN

SECRETARY

Municipal Boundary Review PO Box 1645, Madison WI 53701

Voice (608) 264-6102 Fax (608) 264-6104 Email: wimunicipalboundaryreview@wi.gov Web: http://doa.wi.gov/municipalboundaryreview/

It is the function of the Incorporation Review Board to prepare findings and to make a

determination as to whether the territory petitioned for incorporation meets the applicable

standards prescribed in Section 66.0207, Wis. Stats. The Incorporation Review Board

("Board") was created by 2003 Wisconsin Act 171. Board members are appointed by

Wisconsin's municipal associations. Membership of the Board is provided at Appendix

A.

In summary, it is the DETERMINATION OF THE INCORPORATION REVIEW

BOARD that when considering the re-submitted petition under Section 66.0207, Wis.

Stats.:

STANDARD 1 (a), Characteristics of the Territory –Not Met

STANDARD 1 (b), Territory Beyond the Core –Met

STANDARD 2 (a), Tax Revenue – Met

STANDARD 2 (b), Level of Services – Not applicable

STANDARD 2 (c), Impact on the Remainder of the Town –Met

STANDARD 2 (d), Impact on the Metropolitan Community – Not applicable

The facts and analysis supporting these findings are discussed in the body of this

determination. The Determination of the Incorporation Review Board to the Circuit

Court, as prescribed by s. 66.0203 (9) (e) 3, Wis. Stats., is as follows:

The Petition as submitted is dismissed with a recommendation that a new petition

be submitted to include less territory as specified in the Board’s findings and

determination.

Dated this 28th day of October 2020,

Dawn Vick

Chair of the Incorporation Review Board

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NOTICE OF RIGHT TO APPEAL

This Notice sets forth the requirements and procedures for obtaining review for those

persons who wish to obtain review of the attached decision of the Board. Per

s. 66.0209 (2), Wis. Stats., decisions of the Board are subject to judicial review under

s. 227.52. Per s. 227.53 any person aggrieved by a decision of the Board is entitled to

review. Per s. 227.53 (1) (a) 1., proceedings for review are instituted by serving a petition

therefor upon the agency, either personally or by certified mail, and by filing the petition

in the office of the clerk of the circuit court for the county where the judicial review

proceedings are to be held. Per s. 227.53 (1) (a) 2m., an appeal must be filed within 30

days after mailing of the decision by the agency. Per s. 227.53 (1) (b), the petition shall

state the nature of the petitioner's interest, the facts showing that petitioner is a person

aggrieved by the decision, and the grounds specified in s. 227.57 upon which petitioner

contends that the decision should be reversed or modified. Any petition for judicial

review shall name the Incorporation Review Board as the Respondent. Petitions for

review should be served on the Chairperson of the Board. The address for service is:

c/o Municipal Boundary Review

101 East Wilson Street, 9th Floor

PO Box 1645

Madison, WI 53701

Persons desiring to file for judicial review are advised to closely examine all provisions

of Wis. Stat. sec. s 227.52, 227.53 and 227.57 to ensure strict compliance with all

requirements. The summary of appeal rights in this notice shall not be relied upon as a

substitute for the careful review of all applicable statutes, nor shall it be relied upon as a

substitute for obtaining the assistance of legal counsel.

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Table of Contents

EXECUTIVE SUMMARY .................................................................................................. 1

FACTUAL BACKGROUND ............................................................................................... 4

Physical boundaries ................................................................................................................. 4

SOCIAL AND ECONOMIC ACTIVITY ............................................................................................ 4

Topography .............................................................................................................................. 6

Drainage Basins ....................................................................................................................... 6

TRANSPORTATION ACCESS ........................................................................................................ 6

Schools ..................................................................................................................................... 6

Utility Districts ......................................................................................................................... 6

POPULATION DISTRIBUTION ..................................................................................................... 7

LAND USES ............................................................................................................................... 7

CHARACTERISTICS OF THE TERRITORY - DETERMINATION ................................. 13

TERRITORY BEYOND THE CORE - DETERMINATION ............................................... 15

FINANCIAL CAPACITY - DETERMINATION ................................................................. 17

SECTION 2(B) LEVEL OF SERVICES .............................................................................. 20

SECTION 2(C) IMPACT ON THE REMAINDER OF THE TOWN .................................. 21

SECTION 2(D), IMPACT UPON THE METROPOLITAN COMMUNITY ........................... 23

APPENDIX A: INCORPORATION REVIEW BOARD ..................................................................... I

APPENDIX B: PROPOSED VILLAGE BUDGET .............................................................. II

APPENDIX C: MAPS ........................................................................................................... III

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EXECUTIVE SUMMARY

This document constitutes the Findings and Determination of the Incorporation Review

Board on the petition that was filed by residents of the Town of Wrightstown in Brown

County to incorporate an area of the Town, shown by MAP 1 in Appendix C, as the

Village of Greenleaf. The area measures roughly 1-square mile in size and includes 814

residents. It includes a hamlet area which has historically been recognized as the

community of Greenleaf for over 100 years (the Historic Greenleaf Core Area), as well as

an area to the east located immediately below and above the Niagara Escarpment which

is an elevated ridge of limestone which extends through the Town (Ledge Area). MAP 1

also shows the Town of Wrightstown territory proposed to remain after incorporation

(Town Remnant), roughly 32-square miles in size. Petitioners desire incorporation to

legally recognize the long-established Greenleaf community and to more effectively

guide land use decisions and manage growth.

Greenleaf’s incorporation process began with a newspaper notice on February 21, 2019

indicating Petitioners’ intent to circulate an incorporation petition. After circulating the

petition and gathering sufficient signatures, a Court hearing was held in Brown County

Circuit Court on December 2, 2019 where Judge John Jakowski found the petition meets

the minimum area and population standards required by s. 66.0205, Wis. Stats., The

Judge also recognized the neighboring Village of Wrightstown as a Party of Interest

opposed to the proposed incorporation and ordered the petition be forwarded to the

Incorporation Review Board for review of the statutory standards in s. 66.0207, Wis.

Stats. On May 1, 2020, Petitioners submitted their materials and review fee which

commenced the Board’s 180-day review period. As part of its review, the Board held a

public hearing on July 14, 2020 to hear from Petitioners, the Village of Wrightstown, and

residents. The Board also held meetings on September 22, 2020 and

October 21, 2020 to discuss and analyze how the petition relates to the statutory

standards.

The neighboring Village of Wrightstown is opposed to the incorporation because it fears

the new Village of Greenleaf will annex or attach via boundary agreement all remaining

Town of Wrightstown territory. What activities and actions newly incorporated

communities may undertake following their incorporation is beyond the scope of the

Incorporation Review Board or its statutory authority for reviewing the standards in

s. 66.0207, Wis. Stats.

In reviewing and acting upon this incorporation petition, the Board has three statutory

options for action. According to s. 66.0203(9)(e) Wis. Stats., the Board may determine:

1) The petition as submitted is dismissed;

2) The petition as submitted is granted, or

3) The petition as submitted is dismissed with a recommendation that a new

petition be submitted to include more or less territory as specified in the Board’s

findings and determination.

The Incorporation Review Board finds that the petition as submitted meets some of the

requirements of s. 66.0207 Wis. Stats. but not all of them.

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1). Characteristics of the Territory – Not Met.

This standard requires the petitioned territory to be sufficiently compact and

homogenous to function as a city or village. Factors include natural boundaries,

the transportation network, employment, business, social and recreational

opportunities, population distribution, and land use patterns.

Greenleaf’s historic core area has a long history of being recognized as a

community, and these same long-standing social and economic patterns continue

today, including a Post Office, bank, convenience and hardware store, farm

supply store, three restaurants, a bowling alley, a fire station that includes a large

community meeting space, the Wrightstown Town Hall, Brown County’s public

works facilities, a church, and a community park. Additionally, the

neighborhoods surrounding the community center contain the most densely

residential development pattern, with small lots and a grid-style street network.

Additionally, twenty-four (24) businesses or organizational entities operate in

Greenleaf, employing 209 people. Greenleaf’s historic core area shows good

compactness and homogeneity and compares favorably to the standard.

However, as MAPS 1 and 2 show, the petition also includes an area to the east

which tends to be physically isolated from the rest of the proposed village by the

100-foot Niagara Escarpment as well as by vacant lands and an active quarry. As

a result, the Board cannot find this standard met, particularly as it relates to

compactness. However, the Board does believe that this standard could

potentially be met if the petition were revised and resubmitted to include

primarily Greenleaf’s historic core area.

2). Territory Beyond the Core – Met.

This standard requires that territory beyond the most densely populated one-half

square mile has an average of more than 30 housing units per quarter section. In

this case, Greenleaf’s historic core area is its most densely populated one-half

square mile, and the territory beyond it has an average of 33.34 housing units per

quarter section, which meets this standard.

3). Financial Capacity – Met.

This standard ensures that the proposed village has the capacity to raise sufficient

tax revenue to function as a village without unduly burdening residents.

The proposed village has a high equalized value compared with similar-size

villages, and a low debt level and tax rate. As a result, the Board finds the

proposed village has sufficient financial capacity to operate as a village.

However, the Board does caution that Petitioners’ proposed budget for the new

village may be insufficient for many budget categories which may give residents a

false sense for the true costs of operating as a village.

4). Level of Services – Not applicable, because no neighboring municipality has

intervened against the petition and filed a willingness to annex and serve the

petitioned territory.

5). Impact on the Remainder of the Town – Met.

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This standard requires the Board to consider the impact on the town remaining

after incorporation to ensure its viability. The proposed Town of Wrightstown

remnant still contains a substantial population and value. The remnant’s shape is

compact and homogenous with no newly created islands or other isolated areas

which would be difficult to serve. Additionally, Petitioners’ budget allocates all

current Town debt to the new village, which will be a benefit to Town remnant

residents. Because of all these factors, the Board finds this standard met.

6). Impact on the Metropolitan Community – Not Applicable.

This standard requires the Board to examine how incorporation would impact the

larger metropolitan area and region. The court has determined, and the Board

agrees that Greenleaf would be an “isolated municipality” as defined in s.

66.0201(bm), Wis. Stats. Therefore, this standard does not apply to the petition.

Specifically, because the proposed Village of Greenleaf is “entirely outside any

metropolitan community,” s. 66.0201(2)(bm), there is no there is no “metropolitan

community” for the standard to apply to, within the technical statutory meaning of

“metropolitan community.”

Having found that the petition fails to meet one of the Incorporation Review Board’s

statutory standards in s. 66.0207 Wis. Stats., the Board finds that the petition must be

dismissed. However, because Greenleaf’s historic core area could potentially comply

with the unmet standard, the Board recommends that the petition be re-submitted with

altered boundaries to primarily include only this area.

The Board thanks Petitioners, Town of Greenleaf staff and elected officials, and the

Village of Wrightstown for all their materials, presentations, testimony, and requested

information, which greatly facilitated the Board’s review.

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FACTUAL BACKGROUND

Physical boundaries The proposed village boundaries include the Historic Greenleaf Core Area at the

crossroads of State highway (STH) 32/57 and STH 96, and MAP 2 shows that additional

territory west of STH 32/57 was included along with Ledge territory below and on top of

the Niagara Escarpment. The historic core area tends to be compact and regular in shape,

while the additional included territory to the west, and the Ledge Area to the east, tends

to make the proposed village more irregular in shape.

Social and Economic Activity

The Historic Core Area commonly referred to and thought of as Greenleaf has a

significant history and a distinct economic and social identity. Prior to 1850, the area

was covered by dense white pine forests and inhabited by the Menomonee people.

European settlers began between arriving between 1850-1870 drawn by lumber and

agricultural opportunities. Soon mining became an opportunity too as a quarry became

established to take advantage of rock from the Niagara Escarpment. Spurred by the new

quarry, a rail line was constructed in 1873 to connect Greenleaf to Green Bay and Fox

Valley communities. The rail line resulted in further rapid growth and Greenleaf became

a major hub in northeast Wisconsin and many services sprang up to support the

burgeoning community. In fact, Greenleaf previously attempted incorporation in 1959;

however the referendum vote by residents failed by just 19 votes

TABLE 1 shows current Greenleaf economic and employment opportunities, which

include a Post Office, bank, a gas station with a convenience and hardware store, a farm

supply store, three restaurants, a bowling alley, a fire station that includes a large

community meeting space, the Wrightstown Town Hall, a Brown County public works

facility, a church, among others. The table shows total of 209 people work full- or part-

time in Greenleaf, the largest employer being Cornette’s Farm Supply with 37

employees.

TABLE 1: Greenleaf Employment Business Category Full-Time

Employees

Part-Time

Employees

Greenleaf Wayside

Bank

Bank 17 2

Mally’s Spare Time Bowling Alley

Bar & Restaurant

1 6

Flippers Cove Bar & Restaurant 0 8

Slammer Inn Again Bar & Restaurant 0 10

D & G Restaurant Restaurant 4 15

St Paul’s Lutheran

Church

Church 1 1

Economy Roofing Construction & Services 1 0

Brick Plumbing Construction & Services 2 0

JC Enterprises Construction & Services 1 0

Joe Brice Cabinets Construction & Services 9 3

J Own Construction Construction & Services 2 0

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SCG Solutions Construction & Services 3 0

Little Devils Pet

Grooming

Construction & Services 1 0

Improved Living SVC Construction & Services 16 0

Complete Storage Construction & Services 1 0

Cornette’s Farm Supply Farm Supplies 23 14

Greenleaf BP Gas/Convenience/Hardware 1 2

US Post Office Public Authority 2 0

Greenleaf Volunteer

Fire Department

Public Authority 0 45

Brown County Shop Public Authority 10 0

Wrightstown Town

Hall

Public Authority 4 0

Sanitary District Plant Public Authority 2 0

Wh Development

(MHP)

Rentals 1 0

BJ Grandviews Estates Rentals 0 0

Total Employees 209

Greenleaf has several social organizations, some dating back over 100 years to the

community’s beginnings, including:

• Greenleaf Volunteer Fire Department – originating in the late 1800s, the Fire

Department has been a steady community fixture. The Department owns and

maintains the 6-acre Fireman’s Park in Greenleaf and hosts an annual all-day

festival at the park each July with food, games and music.

• Greenleaf 4-H Club – formed in 1943, the club has 60 members. Its activities

include cleanup at the Greenleaf Fireman’s Picnic, a yearly Brat Fry, Christmas

caroling, exhibiting crafts, art, photography, bakery and animals at the Brown

County Fair, and various community service projects.

• St. Paul Church - established in 1909, the 40 plus members gather weekly.

• Greenleaf Riders Snowmobile Club - organized in 1972, the club has 80 members

who work to maintain a network of 25 miles of trails within Greenleaf and the

surrounding area. The Club also contributes to various community programs,

school athletics, college scholarships, and snowmobile safety.

• Greenleaf–Wrightstown Optimist Club - founded in 1991, the club meets monthly

and sponsors Youth Day in the Park and an annual Easter Egg Hunt.

The Fox River Trail which runs through Greenleaf is another social and recreational

opportunity. The trail extends from Green Bay and travels through the communities of

Allouez, De Pere, and Rockland, before reaching Greenleaf and then extending further

south. The Trail runs adjacent to Fireman’s Park.

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Topography The areas major topographic feature is the Niagara Escarpment, which extends along the

proposed village’s east side. The escarpment is a nearly 1,000-mile-long-limestone ridge

that runs through Wisconsin and extends through New York and Canada. The DNR

identifies the Niagara Escarpment as a Legacy Place. Additionally, the escarpment creates

its own unique micro-climate and environmental conditions. As a result, it contains

plants and animals found nowhere else. By DNR’s latest county, at least 240 unique

species, many of them rare, threatened, or endangered, live on and along the Niagara

Escarpment.

Drainage Basins The proposed Village falls within two drainage sub-basins which both flow west to the

East River. MAP 3 shows that most of the territory falls within the Fox River sub-basin,

while a portion of the Ledge Area falls within the East River sub-basin.

Transportation Access Greenleaf has historically functioned as a major hub in Brown County, lying at the

crossroads of State Highways (STH) 32-57 and STH 96, as well as the rail line which has

been converted into the Fox River Trail. Traffic counts through the community range

from 4000-5000 daily. The Historic Greenleaf Core Area features a grid-style network of

local streets and a sidewalk along main street, and the Fox River Trail enabling bicycle

and pedestrian commuters to travel as far as Green Bay. MAP 4 shows the existing

streets and highways, as well as several planned future roadways. Additionally,

Petitioners indicate that it purposefully designed roads in a stub-end fashion to enable

easy future extensions.

Schools Students within the Town of Wrightstown primarily attend Wrightstown Community

School District. No District schools are located within the proposed Village. Some

students also attend private school at St John’s Lutheran School or St. Clare Catholic

School. TABLE 2 provides the enrollment of these schools and shows that many

students reside within the Greenleaf community.

TABLE 2: School Enrollment

School Name & Type Proposed Village of

Greenleaf Students

Remnant Town of

Wrightstown Students

Wrightstown Elementary

School

62 79

Wrightstown Middle School 29 50

Wrightstown High School 35 97

St John’s Lutheran School 6 11

St Clare Catholic School 11 23

Total 143 260

Utility Districts The Town of Wrightstown provides public sanitary sewer and water service to residents

within the Town of Wrightstown Sanitary District #1 (Sanitary District). MAP 5 shows

the District’s boundaries along with Brown County’s approved Sewer Service Area

which is the areas eligible for future Sanitary District service. Roughly 350 acres, or

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58% of the proposed village lies outside of the approved Sewer Service Area. MAP 5

shows that excluded areas are below and atop the Ledge.

In 2018, the Town of Wrightstown completed a cost estimate study for extending sewer

and water service to the Ledge, and determined it would cost approximately $4.6 million

dollars due to the topographical challenge, which currently is cost prohibitive. Due to

this high cost, there are no plans to extend sewer and water services atop the Ledge area.

Instead, these residents will continue to utilize private wells and on-site wastewater

treatment systems.

Population Distribution The proposed village has an estimated population of 814 people. MAP 6 shows that the

Historic Greenleaf Core Area contains the greatest concentration of Town of

Wrightstown residents. TABLE 3 shows that the proposed village’s population density

compares favorably to past Board determinations which met this standard.

TABLE 3: Population Density

Community Population Density

(sq. mi.)

Harrison 1572

Brookfield 1482

Fox Crossing 1174

Greenleaf 859

Somers 581

Greenville 570

Bloomfield 474

Summit 316

Bristol 254

Land Uses

The Town of Wrightstown is primarily rural in nature, while the proposed village tends to

be urban. TABLE 4 shows that while only 10.67% of the Town contains urban

development, 64.13% of the proposed village contains urban development. The Town’s

comprehensive plan has encouraged this trend, recommending that new development

occur within Greenleaf and served with public sewer and water.

TABLE 4: Existing Land Uses Land Use Existing

Town

(acres)

(%)

Proposed

Village

(acres)

(%)

Residential 1,366.34 6.46% 235.63 38.96%

Commercial 12.93 .06% 3.85 .64%

Industrial 68.27 .32% 51.93 8.59%

Transportation 781.61 3.6% 88.03 14.56%

Communication &

Utilities

22.07 .10% 3.8 .63%

Institutional 26.98 .13% 4.52 .75%

Total Developed 2,278.2 10.67% 387.76 64.13%

Parks & Recreation 249.55 1.18% 15.73 2.60%

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Natural Areas &

Woodlands

3,284.55 15.52% 75.04 12.41%

Agriculture & Open

Space

15,345.2 72.53 126.23 20.87%

Total Undeveloped 18,879.3 89.23% 217 35.88%

Total Area 21,157.5 100.00% 604.8 100.00%

Greenleaf contains a diversity of housing options available to residents, more typical of a

mid-sized city or village than a small community of 814 persons. Specifically, the Town

of Wrightstown contains 54 duplex units, 91 apartment units, and 64 mobile home units,

the majority of these being located within the Historic Greenleaf Core Area.

Furthermore, within the historic Greenleaf core, single-family housing units tend to be

older in age, on smaller lots, and more affordable in price, falling between $100,000 -

$200,000 in cost. This contrasts sharply with housing immediately above and below the

Ledge which is exclusively newer single-family homes, larger in size and built on larger

lots.

Financial Information The Board examines financial information to ensure that the proposed village and Town

Remnant have the capacity to successfully operate as governmental entities. During the

Board’s review, it became apparent to Department staff and Board members that what

Petitioners had proposed as a budget for the new village was extremely minimal. As a

result, following the Board’s September 22, 2020 meeting, Petitioners submitted

revisions to some of the budget categories, and they also submitted updated equalized

value totals for the proposed village and Town Remnant. This determination utilizes

these revised and updated numbers.

Equalized Value - TABLE 5 shows Greenleaf’s equalized value, along with the current

Town of Wrightstown and Town Remnant The Table shows Greenleaf contains just 22%

of the current Town’s value, and that most of the value would stay with the Town

Remnant after incorporation.

TABLE 5: Equalized Value

Proposed Village of

Greenleaf

$50,371,243 22%

Town Remnant $193,655,757 78%

Town of Wrightstown $244,027,000 100%

TABLE 6 compares Greenleaf’s value with similar-sized Villages across the state and

shows that Greenleaf compares favorably.

TABLE 6: Comparison of Equalized Value

V. Stratford 824 $106,146,900

V. Pepin 828 $69,595,100

V. Valders 952 $55,344,000

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Greenleaf

(Proposed)

814 $50,371,243

V. Coon Valley 742 $46,583,100

V. Shiocton 926 $41,566,900

V. Benton 963 $41,457,500

V. Elmwood 794 $40,335,700

V. Whitelaw 758 $39,906,800

V. Saint Nazianz 762 $37,706,000

V. Auburndale 715 $36,077,100

V. Lone Rock 880 $34,716,400

V. Birnamwood 793 $33,946,400

V. Bruce 759 $26,434,600

V. Tigerton 716 $21,516,800

Debt - The Town of Wrightstown has $204,047 in outstanding debt. Its debt limit is

$11,489,955, indicating that the Town is utilizing only 2% of its statutory debt limit.

Petitioners’ proposed budget, described below, anticipates that the new village would

take responsibility for all of this debt due to the fact that much of it is related to the

Sanitary District. Following incorporation, the Sanitary District will dissolve and

become a utility of the new village.

Proposed Budget - TABLE 7 provides a condensed version of the Town’s current budget as well as the anticipated budgets for both the proposed village of Greenleaf and Town Remnant. A more detailed budget can be found at APPENDIX B.

TABLE 7: Budget of Existing Town, Proposed Village of Greenleaf, and Town Remnant

Revenues

Taxes $650,334 $177,163 $473,171

Intergovernmental $239,003 $177,163 $181,105

Licenses and Permits $37,100 $57,898 $27,457

Intergovernmental

charges for services

$4,000 $4,000 -

Public charges for

services

$124,550 $44,740 $79,810

Miscellaneous $8,500 $2,204 $6,296

Total Revenues $1,063,487 $295,648 ($288,437) $767,839

Expenditures

General Government $163,690 $56,490 $107,200

Public Safety $361,426 $128,731 $232,695

Public Works $$65,309 $75,415 $389,894

Health and Human

Services

$100 $50 $50

Conservation and

Development

$27,000 $14,000 $13,000

10

Capital outlay $26,500 $1,500 $25,000

Debt service

Principal $14,646 $14,646 -

Interest and Fiscal

Charges

$4,816 $4,816 -

Total Expenditures $1,063,487 $295,648 $767,839

Services - The following paragraphs and TABLE 8 summarize how incorporation will

impact local services such as fire protection and EMS rescue service, police protection,

sewer and water service, among others.

Greenleaf Volunteer Fire Department is a non-profit entity separate from the Town of

Wrightstown. It currently serves the Town of Wrightstown, as well as portions of the

Towns of Holland and Rockland. The Department’s 7,000 square-foot fire station is

located in Greenleaf’s historic core area. Incorporation will have no effect on fire

protection services, and both the new village and Remnant will continue to have the same

level of service at the same cost.

County Rescue Services is a non-profit entity separate from the Town of Wrightstown

which provides EMS rescue service to Brown County communities, including Greenleaf.

Incorporation will have no effect, and the same level of EMS rescue service will be

provided to the new village of Greenleaf and Town Remnant at the same cost rate.

The Town of Wrightstown relies on the Brown County Sheriff’s Department for police

protection. Because Greenleaf’s population is well below 5000 persons, Wisconsin statutes do

not require that the new village provide its own police protection. Instead, Brown County

Sheriff’s Office will continue to provide the existing level of service at no additional cost.

The proposed budget assumes that the new village would make the Town Hall building

available to the Town Remnant for a nominal fee of $100 per month. TABLE 8: Services Before & After Incorporation Services Current Status Post Incorporation

Town Remnant Proposed Village

Law Enforcement Brown County

Sheriff’s Office

No change No change

Fire Protection Greenleaf Volunteer

Fire Department

No change No change

Ambulance Service County Rescue

Service and

Wrightstown Area

First Responders

No change No change

Schools Wrightstown School

District, primarily

No change No change

Garbage & Recycling Contracted service, No change No change

Sewer & Water Sanitary District No change No change in service,

Sanitary District

absorbed by Village

Building Permits &

Inspections

Contracted No change No change

Snow Plowing Brown County No change No change

11

Highway Dept

Ordinances & Zoning Town of Wrightstown

& Brown County

Planning Department

No change No change

Tax Rate - TABLE 9 shows the current Town’s tax rate as well as the rates anticipated

for the proposed village and Town Remnant. The Table shows the proposed village to

remain at the same $2.95 rate, with customers of the Sanitary District paying $4.43, while

Town Remnant residents will see a slight reduction to $2.85.

TABLE 9: Tax Rates

Existing Town Proposed Village Remnant Town

Equalized Valuation $244,027,000 $50,371,243 $193,655,757

Taxes Levied $572,198 $122,051 $434,997

Mill Rate $2.95 $2.95 ($4.431) $2.85

1 Tax rate paid by residents receiving public sewer and water service from the Sanitary District.

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CHARACTERISTICS OF THE TERRITORY - DETERMINATION

The standard to be applied is found in §66.0207(1)(a) and is as follows:

The entire territory of the proposed village or city shall be reasonably

homogenous and compact, taking into consideration natural boundaries, natural

drainage basin, soil conditions, present and potential transportation facilities,

previous political boundaries, boundaries of school districts, shopping and social

customs.

In addition to the statutory factors cited above, the court in Pleasant Prairie v. Department

of Local Affairs & Development2 held that the Department may also consider land-use

patterns, population density, employment patterns, recreation and health care customs.3

In addition, because this petition is for an Isolated Municipality, the statutory standard

requires:

a reasonably developed community center, including some or all features such as

retail stores, churches, post office, telecommunications exchange and similar

centers of community activity.

The historic core area of Greenleaf has a long history as a community due to the lumber,

mining, and farming industries, at one point being a major hub for commerce in Brown

County. These social and economic patterns continue today, albeit to a lesser extent.

Greenleaf currently includes a variety of businesses and services in the Historic Greenleaf

Core Area to comply with the community center requirement under the statute. These

include a Post Office, bank, a gas station with a convenience and hardware store, a farm

supply store, three restaurants, a bowling alley, a fire station that includes a large

community meeting space, the Wrightstown Town Hall, Brown County’s public works

facilities, a church, a 6-acre park, and the Fox River Trail. Additionally, the

neighborhoods surrounding the community center contain the densest residential

development pattern, with small lots and a grid-style street network. Greenleaf’s social

and recreational opportunities indicate that it has a distinct social identity and

cohesiveness. Economically, twenty-four (24) businesses or organizational entities

operate in Greenleaf, employing 209 people. This shows that Greenleaf residents have

some economic and social opportunities within the community available to them, in

addition to those in the Fox Valley.

The proposed core village boundaries are relatively compact. However, as shown in

MAPS 1 and 2, inclusion of the Ledge tends to make the shape of the new village

somewhat irregular. Additionally, the Ledge Area is physically isolated from the Historic

Greenleaf Core Area by the 100-foot Niagara Escarpment. The statute suggests that

natural features be used to identify boundaries and make them compact, not separate

them as this topography does. Also, the vacant agricultural lands and active quarry along

the Escarpment tend to further physically isolate the Ledge Area.

2 Pleasant Prairie v. Department of Local Affairs & Development, 108 Wis.2d 465 (Ct.App. 1982), affirmed, 113

Wis.2d 327 (1983). 3 Ibid, page 337.

14

Transportation access throughout the proposed village is generally good, owing to a

network of grid-style streets within the Historic Greenleaf Core Area, the intersection of

STH 32/57 and STH 96, as well as the Fox River Trail. Access to the Ledge is currently

limited, with only STH 96 currently providing access atop the Ledge and Fair Lane

providing access below the Ledge. There are no connections between the top and

bottom of the Ledge.

Schools tends to be a characteristic showing homogeneity, as the Wrightstown

Community School District serves the entire proposed village area, with many students

coming from within Greenleaf.

Sanitary District boundaries are a characteristic showing homogeneity of the Historic

Greenleaf Core Area, but not the Ledge, which lies outside of the approved Sewer

Service Area plan and does not receive sewer or water service from the Sanitary District.

Nor is service to the Ledge anticipated in the future, due to the high $4.6 million cost.

Analysis of watershed boundaries also shows the Ledge Area as not being compact and

homogeneous. MAP 3 shows that while the Historic Greenleaf Core Area falls within

the Fox River drainage sub-basin, the Ledge Area falls within the East River sub-basin.

Population is densely is concentrated within the Historic Greenleaf Core Area. TABLE

3 shows that the proposed village’s population density of 859 places it favorably among

communities which have met this statutory standard.

Land uses within Greenleaf tend to be urban in nature rather than rural. TABLE 4 shows

that 64.13% of Greenleaf is developed. The Town’s comprehensive plan has encouraged

that development occur within Greenleaf utilizing public sewer and water and this policy

continues to be in place.

Generally, as described above, the Historic Greenleaf Core Area compares favorably to

the characteristics used to determine compactness and homogeneity. However, the Ledge

Area does not. The following are characteristics that tend to show the Ledge as lacking

compactness and homogeneity:

• The Ledge area is physically isolated from the rest of the proposed village by the

100-foot Niagara Escarpment, as well as active farmland and an active quarry

along the Niagara Escarpment;

• The Ledge is outside of Brown County’s approved Sewer Service Area plan and

not served by the Sanitary District, nor expected to be served in the future;

• The Ledge is located in a different sub-watershed than the rest of the proposed

village;

• Accessibility to the Ledge is limited and is not interconnected with the core area.

Therefore, the Board cannot find that this standard is met. However, the Board does

believe that this standard could potentially be met if the petition were to be revised and

resubmitted to include primarily the Historic Greenleaf Core Area.

15

TERRITORY BEYOND THE CORE - DETERMINATION

The standard to be applied for isolated communities is found in s 66.0207(1)(b), Wis.

Stats. and reads as follows:

The territory beyond the most densely populated one-half square mile

specified in s. 66.0205(1)… shall have an average of more than 30

housing units per quarter section or an assessed value, as defined in s.

66.0217(1)(a) for real estate tax purposes, more than 25% of which is

attributable to existing or potential mercantile, manufacturing or public

utility uses.

Most Densely Populated One-Half Square Mile MAP 7 shows the most density populated one-half square mile, with approximately 690

people and 251 housing units, or an average 125.5 housing units per quarter section. The

total population of this most densely populated core area is approximately 690 people.

The Village of Wrightstown disagrees with how Petitioners identify the most densely

populated square mile. Using a slightly different methodology, the Village’s calculation

adds an additional parcel to the most densely populated square one-half square mile.

Waived Territory The Board has authority under s. 66.0207(1)(b), Wis. Stats. to waive territory from the

standard “to the extent that water, terrain or geography prevents the development”.

Petitioners request waiver of 46 acres due to active quarrying, which prevents their being

developed as residential housing. Constructing housing on such terrain is not feasible.

Therefore, the Board waives the 46 acres being quarried from the standard because the

terrain and geography currently prevents development of housing units, and will continue

to prevent it well into the future.

Territory Beyond the Core MAP 7 shows the territory beyond the most densely populated one-half square mile

which is subject to the standard, a total of 0.375 square miles in area with 126 residents

and 50 housing units. TABLE 10 shows 33.34 housing units per quarter section, which

meets the standard.

TABLE 10: Territory Beyond the Core Population in Territory Beyond the Core 126

Average Household Size 2.75

Housing Units in Territory Beyond the Core 50

Total Land Area in Territory Beyond the Core .447 sq. mi.

Undevelopable Quarry Land .072 sq.mi.

Developable Area Remaining in Territory Beyond the Core .375

Housing Density of Territory Beyond the Core (Housing

Units/Quarter Section

33.34

Using the Village of Wrightstown’s methodology for calculating the most densely

population square mile, the territory beyond the core has 49 housing units. However,

16

even if the Board were to adopt the Village of Wrightstown’s methodology, the result

would be a housing density of 32.66 housing units per quarter section, which would also

meet the standard.

Petitioners point out that, of the 13 additional residential lots available within the territory

beyond the core, three of these are currently under development. Thus, even without

waiver of the quarry lands, Petitioners would soon meet the standard.

17

FINANCIAL CAPACITY - DETERMINATION

The standard to be applied is found in s. 66.0207(2)(a), Wis. Stats., and provides as

follows:

"The present and potential sources of tax revenue appear sufficient to defray the anticipated cost of governmental services at a local tax rate which compares favorably with the tax rate in a similar area for the same level of services."

The Financial Capacity standard helps ensure that proposed incorporated communities

have the financial resources to function as a city or village. Factors considered include

the proposed village’s equalized value, current debt, the proposed budget, and the

proposed tax rate.

TABLE 5 indicates that the proposed village only accounts for 22% of the current Town

of Wrightstown’s equalized value, or $50,371,243, while the Town Remnant retains 78%

of the total Town’s value. Nonetheless, Greenleaf’s equalized value compares favorably

to other similarly sized villages throughout Wisconsin.

Regarding debt, the current Town of Wrightstown has only $204,047 in outstanding debt,

utilizing only 2% of its statutory debt limit. However, Petitioners’ proposed budget

transfers responsibility for all this debt to the new village because much of the debt is

related to the Sanitary District whose boundaries roughly approximate the boundaries of

the Historic Greenleaf Core Area. Following incorporation, the Sanitary District will

dissolve and become a utility of the new village. Incorporation will mean that the

Sanitary District may no longer rely on the larger Town of Wrightstown for financial

assistance should operation, maintenance, or upgrade costs overwhelm the Sanitary

District customers. Fortunately, the Sanitary District’s debt payment decreases by 30%

in 2021 and will be paid in full in 2024. Even shouldering all the Sanitary District’s debt,

the proposed village will still utilize only 12% of its statutory debt capacity.

Petitioners’ proposed budget is summarized in TABLE 7, and shown in full in

APPENDIX C. The updated Town of Wrightstown’s equalized value increased by

almost $15,000,000, with an estimated property tax revenue increase of $35,000, with the

proposed village’s share being $4,000. Petitioners’ revised budget increased spending for

several budget categories, such as for Conservation & Development which is increased to

$6,000. However, the budget remains conservative.

Petitioners support their proposed budget by saying that levy limits imposed by the

Legislature have required all Wisconsin municipalities to work with very tight budgets.

However, TABLE 11 compares the proposed village of Greenleaf’s tax rate with similar-

sized communities. The table shows that of all Wisconsin villages between 7000-1000

persons, Greenleaf’s tax rate would almost be the lowest. The comparison villages in

TABLE 11 are communities across Wisconsin which have had the experience of

operating as separate and distinct communities over a period of many years.

Incorporated communities such as villages typically provide higher level services than do

unincorporated towns, in part due to the urban nature of cities and villages and the desire

18

of residents to receive a higher level of services such as sewer and water, sidewalks,

parks and recreational programs, among many others.

Table 11: Tax Rate Comparison

Village Population Tax Rate

V. Necedah 916 $12.82

V. Milltown 904 $11.49

V. Plain 758 $10.02

V. Footville 819 $9.93

V. Arena 824 $9.60

V. Cambria 757 $9.46

V. Wonewoc 799 $8.89

V. Shiocton 926 $8.86

V. Dresser 904 $8.65

V. Elk Mound 868 $8.62

V. Coleman 719 $8.55

V. Bloomington 730 $8.49

V. Brandon 865 $8.46

V. Crivitz 950 $7.70

V. Blue Mounds 969 $7.51

V. Saint Nazianz 962 $7.40

V. Centuria 950 $7.23

V. Wyocena 727 $6.96

V. Montfort 724 $6.95

V. Plainfield 848 $6.94

V. Valders 952 $6.81

V. Valders 952 $6.78

V. Cassville 930 $6.76

V. La Farge 703 $6.39

V. Blanchardville 812 $6.37

V. Siren 792 $6.06

V. Rib Lake 872 $6.02

V. Sister Bay 966 $5.88

V. Arlington 833 $5.85

19

V. Iron Ridge 923 $5.74

V. Friendship 730 $5.66

V. Coon Valley 742 $5.48

V. Tigerton 716 $5.40

V. Birnamwood 816 $5.37

V. Stratford 824 $4.45

V. Pepin 828 $4.42

V. Whitelaw 758 $4.33

V. Auburndale 715 $4.21

V. Elmwood 794 $4.00

V. Lone Rock 880 $3.77

V. Whitelaw 758 $3.69

V. Benton 963 $3.53

V. Greenleaf 814 $2.95

V. Bruce 759 $2.60

V. Hewitt 846 $2.02

The Board finds that the proposed village’s high equalized value and low debt level

indicate a strong financial capacity to raise sufficient revenue to operate as a village.

Furthermore, the fact that residents’ current tax rate is low indicates that they have

substantial room for increase if necessary. The Board finds the proposed budget to be

minimal. If Petitioners choose to resubmit with altered boundaries, they may wish to

adjust their budget amounts. But in the current petition, the Board finds the standard in

s. 66.0207(2)(a), Wis. Stats. to be met.

20

SECTION 2(B) LEVEL OF SERVICES

The standard to be applied is found in s. 66.0207(2)(b), Wis. Stats., and provides as

follows:

The level of governmental services desired or needed by the residents of the

territory compared to the level of services offered by the proposed village or city

and the level available from a contiguous municipality which files a certified copy

of a resolution as provided in s. 66.0203(6), Wis. Stats.

Because no intervenors filed a certified copy of a resolution to annex the entire petitioned

territory with the Brown County circuit court, this standard is not applicable.

21

SECTION 2(C) IMPACT ON THE REMAINDER OF THE TOWN

The standard to be applied is found in §66.0207 (2) (c), Wis. Stats., and provides as

follows:

“The impact, financial and otherwise, upon the remainder of the town from which

the territory is to be incorporated.”

This standard is meant to ensure the well-being of the proposed town remnant and its

residents following incorporation. Incorporation should not have a detrimental effect and

leave behind a town remnant too small or fragmented to efficiently govern itself, and

with too few assets and revenue sources with which to provide municipal services.

Factors considered to determine the likely well-being of the Town Remnant include

population, compactness of shape, and financial capacity.

Population Incorporation of Greenleaf would result in the Town of Wrightstown’s population

declining by over 36%, from 2, 221 to 1,407. TABLE 12 shows the Town is currently

among the more populous towns in Brown County but would drop to among the least

populous. However, looking at other Wisconsin towns outside of Brown County, the

Remnant’s population compares favorably.

Table 12: Population T Ledgeview 6,555

T Lawrence 4,284

T Scott 3,545

T Pittsfield 2,608

T Wrightstown 2,221

T Green Bay 2,035

T Rockland 1,734

T Morrison 1,599

T New Denmark 1,541

T Holland 1,519

T Eaton 1,508

Town Remnant 1,407

T Humboldt 1,311

T. Glenmore 1,135

Physical Boundaries MAP 1 shows that Town Remnant territory will not create any town islands, isolated

areas, or other fragmented areas which would be difficult to serve. An isolated area is

found at the Town’s northwest corner, cut off from the rest of the Town by the Village of

Wrightstown and the Fox River. However, this isolated area is not created by this

Greenleaf petition, nor would it be worsened by it.

Financial Capacity As mentioned in the previous section, the Town Remnant retains 78% of the current

Town’s equalized value, or $193,655,757, which compares favorably to other Brown

22

County towns and towns throughout Wisconsin. Additionally, Petitioners’ proposed

budget allocates payment of all current Town debt to the proposed village, which will be

a benefit to Town Remnant residents. Furthermore, the proposed village becomes

responsible for all costs related to operation, maintenance, and expansion of the Sanitary

District, which will be a benefit to Town Remnant residents. Some Remnant residents

adjacent to the proposed village and within the Sewer Service Area will continue to

receive services from the Sanitary District.

The current Town is already affected by the Village of Wrightstown on annexation and

extraterritorial land use issues. This incorporation would add a second village for the

Town Remnant to contend with.

Nonetheless, despite these potential risks, the Town Remnant is overall in a good position

to continue as a separate jurisdictional entity and the Board finds that the standard in

s. 66.0207(2)(c), Wis. Stats. is met.

23

SECTION 2(D), IMPACT UPON THE METROPOLITAN COMMUNITY

The standard to be applied is found in s. 66.0207(2)(d), Wis. Stats. and is as follows:

The effect upon the future rendering of governmental services both inside the

territory proposed for incorporation and elsewhere within the metropolitan

community. There shall be an express finding that the proposed incorporation will

not substantially hinder the solution of governmental problems affecting the

metropolitan community.

This standard is not applicable because Greenleaf’s petition is for an Isolated community,

rather than a Metropolitan community as defined in s. 66.0201(2), Wis. Stats.

The Village of Wrightstown requests the Board to consider this standard, contending that

the statute gives the Board discretion to consider this standard even for Isolated

communities. Specifically, the Village points to language in s. 66.0201(2)(c), Wis. Stats.

saying “unless the context requires otherwise” as giving the Board discretion to consider

this standard under special circumstances and contexts. The Village argues that the

special circumstances and context in this case are that Greenleaf’s location immediately

between the Green Bay and Appleton metropolitan areas means that it functions

economically and socially like a metropolitan community. Second, the Village contends

that the Wisconsin Court of Appeals4 requires the Board to consider all six of the

statutory standards. Third, the Village contends that Petitioners and the Town of

Wrightstown Remnant plan to re-combine immediately following incorporation of

Greenleaf by utilizing either annexation or a boundary agreement, a process they refer to

as the “Harrison 2-Step” after the newly incorporated Village of Harrison attached the

remaining Town of Harrison in 2013 using a boundary agreement. As support for this

contention, the Village of Wrightstown cites numerous newspaper articles quoting Town

of Wrightstown officials’ stating an intent to immediately re-combine.

Regarding the Village’s first contention, Greenleaf’s proximity to the Green Bay and

Appleton metropolitan areas, the statute defines Metropolitan Community as being:

“…territory consisting of any city having a population of 25,000 or more, or any 2

incorporated municipalities whose boundaries are within 5 miles of each other

whose populations aggregate 25,000, plus all the contiguous area which has a

population density of 100 persons or more per square mile, or which the

department has determined on the basis of population trends and other pertinent

facts will have a minimum density of 100 persons per square mile within 3 years.5

Therefore, the Legislature’s definition functions in a black or white numbers-fashion, so

that either territory satisfies the numerical requirements and is a Metropolitan

community, or it does not satisfy the numerical requirements and is an Isolated

Community. In this case, Brown County Circuit Court Judge John Jakowski found that

4 Walag v. Wisconsin Department of Administration, 247 Wis.2d 850 (Ct.App. 2001). 5 s. 66.0201(2)(c), Wis. Stats.

24

Greenleaf met the standards for an Isolated community. As a result, even though

Greenleaf is obviously impacted by its proximity to the Green Bay and Appleton

Metropolitan areas economically, socially, and in many other aspects, for purposes of the

incorporation process set forth in ss. 66.0201-66.0209, Wis. Stats., the proposed

Greenleaf is an Isolated Community because it would be “entirely outside any

metropolitan community at the time of its incorporation.” S. 66.0201(2)(bm), Wis. Stats.

Therefore, consideration of the effect upon “the metropolitan community,” s.

66.0207(2)(d) (emphasis added), would be inapplicable in this case, so the Metropolitan

Impact standard is not applicable. The Department requested Petitioners’ methodology to

understand how they determined an Isolated community status.

Regarding the Village’s second contention, that the Court of Appeals requires the Board

to consider all six of the statutory standards, the Board does not disagree with this as a

general matter. In Walag v. DOA, the Court of Appeals upheld the Department of

Administration’s determination to dismiss an incorporation petition for failure to meet

one of the six standards. Under Walag, the Board must “dismiss an incorporation petition

if it determines that one of the six requirements was not met.” Walag v. DOA, 2001 WI

App 217, 33, 247 Wis.2d 850(2001). However, Walag does not prohibit the Board from

finding one or more of the standards inapplicable to a given petition. In this case, the

Board has not determined that the petitions fails to meet the Metropolitan Impact

standard. Rather, the Board has considered this Metropolitan Impact standard to

determine whether it applies to this petition. Only if it applied would the Board need to

consider whether it is met.

The Village’s third contention is that the Metropolitan Impact standard should apply

because Petitioners and the Town Remnant intend to re-combine immediately following

incorporation by utilizing a process that the Village refers to as the “Harrison 2-Step”.

The Village contends that this would cause detrimental harm to the Village by

eliminating the Village’s annexation and extraterritorial authorities in the Town of

Wrightstown. However, even if annexation is a future possibility, it has not yet occurred.

While annexation is a statutory authority that the new Village of Greenleaf would

acquire, whether the new Village will in fact use this authority to merge with the Town

Remnant is uncertain. Annexation is largely a landowner-driven process, which means

that sufficient landowners and residents must consent to the annexation. Following

incorporation, landowners and residents in the Town Remnant may decide that joining

the new village is not in their best interests. Because future annexations would depend on

separate legal processes that have not yet been initiated, they are not part of the

incorporation petition currently before the Board. The Board’s findings “shall be based

upon facts as they existed at the time of the filing of the petition.” Wis. Stats. s.

66.0203(9)(g). The Board cannot look to the future when determining whether the area

proposed for incorporation is currently within a “metropolitan community” as defined in

s. 66.0201()(c), Wis. Stats. Instead, the Metropolitan Impact standard applies only in

relationship to the “territory proposed for incorporation.” S. 66.0207(2)(d), Wis. Stats.

As explained above, the Circuit Court has already determined that the territory proposed

for incorporation would be an isolated village, which by definition is not part of a

“metropolitan community” as that term is defined in s. 66.0201(2)(c).

Even though the Board’s determination considers the facts only as they exist at the time

of the filing of the petition, the Board observes that this is not the first time it has been

25

faced with concerns such as those expressed by the Village of Wrightstown. Because

several communities have in fact re-combined immediately following incorporation, the

Legislature may wish to consider whether this result is consistent with the current

incorporation standards, and if not, whether changes to the incorporation or annexation

processes are necessary. Specifically, the statutory standards in s. 66.0207, Wis. Stats.

require the Board to approve only those proposed cities and villages that are compact and

urban in nature rather than rural. However, if newly incorporated cities and villages can

easily annex or attach the rural territory which comprises the remaining town, an observer

may be forgiven for questioning the reason for the statutory standards requiring a

compact urban form. The Board expresses no opinion on what, if any, changes are

necessary, and it emphasizes that such policy considerations form no part of the basis of

its decision on the petition before it. However realistic the Village’s concerns may be,

they reach beyond the scope of the statutory standards in s. 66.0207, Wis. Stats.

For the above reasons, the Board finds that the Metropolitan Impact standard is not

applicable to this petition.

I

Appendix A: Incorporation Review Board

The Incorporation Review Board was created by 2003 Wisconsin Act 171. It is charged

with reviewing incorporation petitions forwarded by the circuit court in order to ensure

that these petitions meet the public interest standards in s. 66.0207 Wis. Stats. The board

advises the circuit court on whether incorporation petitions should be granted, dismissed,

or resubmitted with new boundaries. The Board is also authorized to set and collect an

incorporation review fee to pay for the costs of reviewing the petition. The Board has

currently set the fee at $25,000.

Members

Department of Administration Member and Chair

Dawn Vick, Chair of Incorporation Review Board

Administrator, Division of Intergovernmental Relations

Wisconsin Towns Association Member #1

William Goehring, Chairperson

Town of Sherman

Wisconsin Towns Association Member #2

Sharon Leair, Chair

Town of Genesee

Wisconsin League of Municipalities Member

Steve Ponto, Mayor

City of Brookfield

Wisconsin League of Municipalities Member

Rich Eggleston

Staff

Renee Powers

Erich Schmidtke

II

APPENDIX B: PROPOSED VILLAGE BUDGET

LICENSES AND PERMIT

INTERGOVERNMENTAL CHARGES FOR SERVICE

MISCELLANEOUS

PUBLIC WORKS

CONSERVATION & DEVELOPMEN

III

APPENDIX C: Maps

Map 1 Proposed Village of Greenleaf & Town of Wrightstown Remnant

Map 2 Proposed Village of Greenleaf

Map 3 Area Watersheds & Drainage Basins

Map 4 Area Transportation System

Map 5 Sanitary District & Sewer Service Area

Map 6 Population Density

Map 7 Territory Beyond the Core

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