Appeal Exhibits A - P.pdf

Susan Solomon Petitioner V City Of Southfield Respondent · 26-002839-TT

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APPEAL OF 2026 ASSESSED VALUE INCREASE



City of Lathrup Village City of Southfield



 UNIMPROVED PORTION OF

 MEADOW DOWNS SUB NO. 1

 31 Parcels (15 acres total)



 Subject Parcel #: 76-24-24-176-008 EXHIBIT

 A

EXHIBIT B (improved)



 Property SUBDIVISION Subject (unimproved)



 Lot135 R-O-WINCREASE

 Road SUBJECT

 MeadowoodVALUE Southfield

 of

 CityASSESSED

 Village2026 Village) EastOF Lathrup St. Lathrup

 of of

 City City

 byAPPEAL Meadowood

 (vacated

EXHIBIT C



 APPEAL OF 2026 ASSESSED VALUE INCREASE



LOCATION OF FORMER MEADOWOOD ST. EAST

 (West access road to subdivision)



 Meadowood St. East (former)



 (60-foot wide unimproved public right-of-way – Vacated 1973)



 City of Lathrup Village, MI

EXHIBIT D

 APPEAL OF 2026 ASSESSED VALUE INCREASE

Adjustment

Value

Land

=

LVA

EXHIBIT E

 APPEAL OF 2026 ASSESSED VALUE INCREASE City of Southfield

 26000 Evergreen Rd. • P.O. Box 2055 • Southfield, MI 48037-2055



 July 15, 1992



Milton Solomon

25635 Concourse

Southfield, MI 48076



Dear Mr. Solomon:



I am writing in response to an inquiry made by your son, Ken Solomon regarding property

that you own on Meadowood (Sidwell parcel 2424-176-008). Nik Banda and I met with

your son last week to discuss this vacant property and the possibility that you plan to sell

it for the development of a house.



We determined that there is currently a right-of-way leading to the property with water

and sewer already in place, but no roadway improvement. In fact, the right of way access

has been barricaded to prevent dumping in and around this vacant area. Mr. Solomon

asked if this barricade could be removed. It is our understanding that you have contacted

Mr. Habowski regarding the removal of the barricade which is to be worked out with the

Department of Public Works.



Additionally, our maps show that this property is contained within a wetlands area that is

larger than two acres and would, therefore need to be reviewed by the Michigan

Department of Natural Resources as well as by the City to determine the actual extent and

boundaries of the wetlands. This review is required before a permit can be issued that

would allow for construction of a house. We discussed that it may be difficult to sell the

property without knowing whether the property can be developed with a house. Mr.

Banda stated that no other property in this area has been reviewed by the DNR for

wetlands, so we do not have an indication of what the DNR's findings will be. However,

without any input from the DNR, our opinion is that according to our maps, the land is

covered by wetlands and is therefore undevelopable without mitigation of the wetlands

area. If you want to proceed with wetlands review, applications for the DNR and city

review are available from the City of Southfield Planning Department.



We also discussed the possibility of offering to sell the property to the neighbors to the

south of the property. Another possibility is to donate the land to the city and use the

value of the property as a tax write-off.



 Mayor Council President City Clerk City Treasurer City Administrator

 Donald E Fracassi Suzanne Goldstein Mary A. Bonner Roman J. Gronkowski Robert R. Block

 City Council

 Denise R. Alexander Peter J. Cristiano Vicki Goldbaum Steve S. Hurite Sidney Lantz Eli E. Robinson

Milton Solomon EXHIBIT E

July 15, 1992

Page 2



Finally, we suggested talking to the City Assessor to discuss reducing the assessed value

of the property and therefore the amount of taxes to be paid.



If you have any questions regarding this matter please call me at 354-9540.



Sincerely,



Barbara McBeth

Planning Technician

EAST ACCESS TO SUBDIVISION (May 2026)



 EXHIBIT

 F

EAST ACCESS TO SUBDIVISION (2013)



 EXHIBIT

 F

EXHIBIT G



 APPEAL OF 2026 ASSESSED VALUE INCREASE



 DOCUMENTATION OF CONDITION OF

 1 of 2 FIRE HYDRANTS & WATER VALVE BOXES

 (Unimproved section of Meadow Downs Subdivision No. 1)



 2026

 2 MISSING HOSE NOZZLE CAPS

 (1 each on East & West sides)



 BROKEN WATER VALVE BOX

 With missing cover



 BROKEN PIECE OF

 WATER VALVE BOX



Note: The photos above (2026) & below (2019) of the same fire hydrant, demonstrate the above-ground

utility fixtures have been effectively abandoned by City of Southfield DPW for many years. Another

earlier photo, excluded herein, shows some of the same damage in 2013, corroborating that such

abandonment likely began well before 13 years ago. Such photos depict at least one of the fire hydrants

has been missing both of its hose nozzle caps, exposing the nozzle threads to damage and the hydrant

barrel to debris collection and rapid corrosion along two sides, affecting the performance of, and/or

potentially damaging, downstream supply lines and pump equipment. The hydrant also has a cracked

lower standpipe (see photo - next page). And, the water control valve box that serves the hydrant has

been both broken and coverless, exposing the underground valve to corrosion and other damage.

EXHIBIT G

 APPEAL OF 2026 ASSESSED VALUE INCREASE



 DOCUMENTATION OF CONDITION OF

 SAME FIRE HYDRANT & WATER VALVE BOX

 (Unimproved section of Meadow Downs Subdivision No. 1)



2019



 2 MISSING HOSE NOZZLE CAPS

 (1 each on East & West sides)



 BROKEN WATER VALVE BOX

 With missing cover



 BROKEN PIECE OF

 WATER VALVE BOX



 CRACKED

 LOWER STANDPIPE

 (East side)

1 " = 100 ' Meadow Downs Sub No 1 CITY OF SOUTHFIELD WETLANDS MAP (6-29-26) µ



 St APPEAL

 Pierce OF

 2026



 Meadowood Rd ASSESSED SUBJECT PROPERTY

 VALUE

 INCREASE



 THIS MAP WAS PRODUCED BY THE CITY

 OF SOUTHFIELD ON 6/29/26, IN RESPONSE

 Cedarcroft PlPotential Wetlands from Historical Planning Dept. Map TO FOIA REQUEST # 26-359

2005 Friends ofRdthe Rouge Potential Wetlands Ct Dr All data and graphic information appearing on this plan includingEXHIBIT

 locations of existing utilities are shown based upon the bestTax Parcels Woodvilla available records. No guarantee is made by the City of Southfield Cornwall Castleton as to the completeness or accuracy of the information provided. Pl Oakcrest H1

USFWS DRAFT NATIONAL WETLANDS BOUNDARY MAP (2015)



 Approximate location

 of subject property



 EXHIBIT

 H2

CITY OF SOUTHFIELD WOODLANDS MAP



 APPEAL

 OF

 2026



 SUBJECT PROPERTY ASSESSED

 VALUE

 INCREASE EXHIBIT



 I

EXHIBIT J



 APPEAL OF 2026 ASSESSED VALUE INCREASE



 DOCUMENTATION OF

 BAD FAITH BY THE CITY OF SOUTHFIELD



The City lacks any/all objectivity to fairly assess property values for either the subject property or any

other properties in the unimproved section of the Meadow Downs Subdivision No. 1, given its extensive

history of regulatory abuse and conflicts of interest therein. This is best demonstrated by the City’s

exploitation of the development constraints it imposed on the subdivision to become both its largest

landowner and the master developer, as discussed further below:



a) Exclusion or misrepresentation of value-reducing factors on assessor’s card - as described in main

 narrative.



b) Due process violations - The City imposed every one of its property constraints without providing

 direct notice to affected property owners or other procedural due process.



c) Selective enforcement & Harassment – The City, long-ago, via its initial barricade at the entrance to

 the subdivision, prohibited access to, and thusly maintenance of, the subject property, causing it, and

 the entire subdivision, to evolve into the current forest. Furthermore, the subject property is located in

 the center of the subdivision, and is unfenced, its boundaries are unmarked, and it contains no

 unique features to distinguish it apart from any of the other identically forested properties around it, in

 the subdivision.1 Despite such indisputable facts, the City farcically claims to have found the subject

 property, often multiple times a year for 12 years2, to harass my family with code violation notices and

 bills for dubious maintenance it allegedly performed thereon, unilaterally, under the guise of nuisance

 abatement:

  The City billed for near-biannual, alleged “mowing” or “cutting” grass and/or weeds on the subject

 property, despite neither vegetation type existed due to the property being densely forested.

  The City billed for such services inconsistently, either based on the length of property frontage or

 on an inconsistent and erroneous square footage - always exceeding the property’s actual size.

  The City billed multiple times for dubious “litter removal”, despite no vehicular access thereto.

  Most egregious, the City falsely billed for five years (early 1980’s) for non-existent “Dust Control”3

 services. Despite admitting to its initial error and issuing a delayed refund for the first 2 years, the

 City continued to bill for the same for another 3 years, requiring a second refund, also delayed.

  The City often overcharged, alleging unintended “error”, requiring a refund, albeit long delayed.

  All or most bills contained additional, often significant (20%), administrative fees.

  In the few instances that the City actually issued a refund, it was always substantially delayed,

 often by years and, in one instance, by six years after a wrongful charge.



 Given the entire unimproved section of Meadow Downs Subdivision No. 1 is forested and

 inaccessible, other property owners therein are reasonably assumed to have experienced the same.



1 The subject property cannot be found via line-of-site measurement, due to obstruction by the dense trees, and

 hand-held GPS devices were not commercially available until 1989.

2 Refers to 1976–1983 and 1988-1991.

3 The “Dust Control” services, which were never performed, were allegedly for the (former) unimproved

 Meadowood Road in the subdivision that, due to the City’s abandonment of maintenance thereof, disintegrated

 into the current forest and ceased to exist.

EXHIBIT J

 Page 2



d) Hypocricy of wetlands protections by City – Per the above, the City had unilaterally “mowed” the

 subject property, near-biannually, for 12 years, at my family’s expense, effectively, repeatedly

 destroying the very same wetlands it’s been using for the past 35 years to preclude development

 thereon. The City last “mowed” the subject property (i.e., wetlands) in 1990, notably, six months after

 it had drafted its “official” wetlands map, and six months before it had formally adopted said map, per

 available records.



e) Regulatory takings – The City, via its development constraints, has effectively seized all or most

 properties in the subdivision, having caused upon each the following:

  Severe loss of market value.

  Loss of all practical and economically viable use.

  Loss of salability,4 without further financial loss.

  Loss of donatability to all but the City.



f) Forced property disposal – The City’s development constraints have financially forced the disposal,

 thus far, of 16 (52%) of the subdivision properties, all at significant financial loss, notably, nine via tax

 foreclosure. Further relevant, the City directly or via tax-foreclosure acquired most (11) of these

 properties, while one of its two development partners5 acquired another, all cheaply, far below market

 value, most via tax foreclosure and the balance via donation or purchase.



g) City is largest landowner - The City and its development partners now own, thus far, 12 (nearly 40%)

 of the subdivision properties and, as such, is the largest landowner therein.



h) Pretextual & conflicting public purposes – The City, for the past 45+ years, via its constraints, has

 prevented or, at best, impeded development and maintenance of the properties in the subdivision,

 while abandoning most of the public infrastructure therein, causing the entire subdivision to

 deteriorate and depreciate. The City did all of this under the guise of public purposes, e.g., nuisance

 abatement, wetlands protection, and woodlands protection. The City then exploited the devastation it

 caused by acquiring, thus far, nearly 40% of the same properties, all cheaply, well below market rate.

 And the City, contrary to its earlier alleged public purposes, is now spearheading development of the

 very same properties it devastated, but for contrary and absurd public purposes. The City is now

 claiming, at least for some of its tax-foreclosed acquisitions (properties), the elimination of “blight”,

 neighborhood revitalization, and protecting property values, to undue the very conditions it created.6



 Further contradictory, the City has publicly committed to protecting only one of its wetland-designated

 properties,7 but even that, given the City’s history, is doubtful. As to the “Woodlands” designation,

 which affects all properties in the subdivision, the City has not publicly committed to protecting any

 such habitat, particularly on its own properties.



i) Shifting political directions – The City clearly supported development of the subdivision for its first 30

 years of platted existence, as demonstrated by its earlier maintenance of the (former) Meadowood

 road and right-of-way, and installation of the water and sewer systems. In the 1980’s, however, the



4 According to the City, itself, “it may be difficult to sell the property” due to the wetlands, per letter from Barbara

 McBeth, Planning Technician, Southfield Planning Department, to Milton Solomon, 7/15/92.

5 The City of Southfield established two closely aligned development partners, the Southfield Neighborhood

 Revitalization Initiative (SNRI) and Southfield Non-profit Neighborhood Corp (SNPNC). Both are city-backed,

 city-resourced, and governed by a Board of Directors, led, in part, of City officials. The SNPNC, the financier

 behind the SNRI, mandates that City officials serve on its board for oversight.

6 The City declared two of the tax-foreclosed properties it acquired as “Blighted” “Brownfields”, per the Brownfield

 Plan - SNR Project 2018, as adopted by Southfield City Council on 10/15/18.

7 Refers to Lot #136 (parcel #76-24-24-176-007), which abuts west of the subject property, and was acquired by

 the City “to protect it as a wetland”, per City Council Meeting Minutes, 2/21/95.

EXHIBIT J

 Page 3



 City inexplicably changed course and, first, barricaded the subdivision and then imposed its

 environmental constraints, and abandoned most of the infrastructure, all clearly anti-development

 actions. Now, however, the City again not only supports, but is spearheading, development of the

 subdivision, at least the properties it now owns.



j) The City as master developer – with the power of government - The City, according to public records,

 is spearheading development of its properties in the subdivision, via its development partners, as

 demonstrated, in part, below:

  Land banking & assembly: The City and its development partners have amassed, thus far, nearly

 40% of the subdivision properties.

  Placemaking & vision: The City acquired at least some its properties allegedly to eliminate “blight”

 and revitalize the neighborhood via building a market rate home on each lot, where possible.

  Parceling: The City has transferred, thus far, two of its properties to its development partner,

 SNRI, for $1 each, to “facilitate” construction of home thereon.

  Infrastructure investment: The City intends for at least two of its properties to use Tax Increment

 Financing (TIF) and Local Brownfield Revolving Fund (LBRF) monies for infrastructure

 improvements for said properties.8

  De-risking development: Given the primary source of funding is the City’s development partner,

 SNPNC, public funds will be used to ensure the economic feasibility thereof.

  Subsidizing development: The City has declared, thus far, two of its properties as “Blighted”

 “Brownfields” to utilize TIF & LBRF monies to facilitate development thereof.

  Entitlement streamlining: The City has already demonstrated an eagerness to fast-track

 development by bypassing entitlement, environmental review, and permit processes, when it

 serves its purpose(s).



k) Severe conflicts of interest – The City has multiple inherent conflicts of interest by simultaneously

 functioning as the assessor, collector, and controller of property taxes, the creator, regulator, and

 enforcer of local laws, the largest landowner, and master developer, in the subdivision. The City is

 not a passive regulator and is an active participant and manipulator of the local market, massively

 disadvantaging private landowners, by controlling the fate of all properties in the subdivision, while

 holding its properties tax-free and subsidizing, streamlining, and de-risking development of its lots,

 and increasing taxes on all but two of the private-owned properties in the subdivision.



 Prepared by: Ken Solomon



8 Per the Brownfield Plan - SNR Project 2018, as adopted by Southfield City Council on 10/15/18.

Appt. Date 03/02/2026



 Petition to Board of Review EXHIBIT Kt EXHIBIT K1

 TO BE COMPLETED BY OWNER OR OWNER'S AGENT



 Owner's Name (Please Print or Type) Petitioner's Name (If Other than Owner, a LETTER OF AUTHORIZATION IS REQUIRED)

 SOLOMON, S & SOLOMON, K



 Township or City County

 CITY OF SOUTHFIELD OAKLAND



The undersigned protests the assessed value and/or the tentative taxable value and/or the property classification and/or the qualified agricultural property exemption of

the following described property:



 Property Identified (Parcel code required. Property address & legal description optional) :



 Parcel #: 76-24-24-176-008



 Address: MEADOWOOD RD TIN,R10E,SEC 24 52 MEADOW DOWNS SUBDN NO. 1 LOT 135



 Neighborhood: 424A NEIGHBORHOOD 24A



 Protested Item [Assessed Value [Tentative Taxable Value [J Classification O ence Glande

 1. PROTEST OF ASSESSMENT TREY EdSmEVOR

 (Complete this section for a protest of assessed value and/or tentative taxable value for tax year: 2026



 aq A: “Gane: d 10,800 Tentative: Taxable 973 21,600 | ASSESSOR INPUT: | Satine

 Owner's Estimated ~~ — Owner's Estimated + | owners Estimated PETMONER INPUT: [miei & [maim 6 |ovme

 / 7

 2. PROTEST OF CLASSIFICATION

 (Complete this section for a request to change the classification. The Board of Review must make their decision regarding classification in accordance

 with section 211.34c of the Michigan Compiled Laws. The Board of Review shall not be influenced by the effect that a particular classification has on

 that property's status as a homeowner's principal residence or qualified agricultural property.)



 Classification of property on this year's assessment roll is: 402 (RESIDENTIAL-V, ACANT)



 Classification should be: (Please check one of the following)



 [I Agricultural [1 Industrial OJ Timber Cutover [utility (Personal Property Only)

 O Commercial [J Residential [J Developmental



 3. PROTEST OF EXEMPTION FOR QUALIFIED AGRICULTURAL PROPERTY

 (If the assessor has denied or changed the percentage of the exemption from the 18 mills of local school operating tax for qualified agricultural property,

 the owner may appeal this action to the March Board of Review. THE BOARD OF REVIEW HAS NO AUTHORITY TO CONSIDER OR ACT UPON THE

 EXEMPTION FROM THE 18 SCHOOL OPERATING MILLS FOR HOMEOWNER'S PRINCIPAL RESIDENCE PROPERTIES.)



 Percent Qualified Agricultural Exemption Granted by Assessor: Enter 0 if exemption is denied) Percent Qualified Agricultural Exemption Requested by Owner: (Enter 100 if full

 exemption requested)



 4. REASON FOR PROTEST



State reason(s) for protest of assessed value/tentative taxable value/classification/qualified agricultural property exemption (attach additional pages if necessary).



CERTIFICATION; ~ ( / ;



 Address - ) Phone Number Uc om Fees

25635Grand Concourse STIL) 28 557/15 7



Form: MC-MBOR PETITION-SIDE 1 ONLY (#2) (2011)

EXHIBIT - K1 EXHIBIT K1

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04/02/2026 11:54 AM

 2026 BOARD OF REVIEW DECI HIBIT K2—

 FROM PROPERTY IDENTIFICATIL.».EXHIBIT K2

 CITY OF SOUTHFIELD 76-24-24-176-008

 26000 EVERGREEN RD

 SOUTHFIELD, MI 48076 MEADOWOOD RD



 NAME AND ADDRESS OF OWNER OR PERSON NAMED ON ASSESSMENT ROLL: T1N.R10E,SEC 24 52 MEADOW DOWNS SUBDN NO. 1

 LOT 135



 SOLOMON, S & SOLOMON, K

 25635 GRAND CONCOURSE ST

 SOUTHFIELD MI 48075-1748



 THIS PROPERTY IS CLASSIFIED 402 (RESIDENTIAL-VACANT)



 Pursuant to Michigan Compiled Laws (MCL) 211.30 (4), each year the assessor shall notify each person who appealed the

 value on their property tax assessment in March, or were authorized by the owner to make such an appeal in March. Such

 notification shall be mailed by the first Monday in June.



 The City of Southfield Board of Review has completed their review of your appeal regarding the 2026 assessed and/or

 taxable value, and has made the following decision(s):



 Board of Review Comments:



 DENIED - COMPARABLES SUPPORT VALUE



 2026 ORIGINAL ASSESSED VALUE 10,800 |



 2026 "BOARD OF REVIEW" ASSESSED VALUE 10,800



 (If the above amounts are the same, no revisions have oc



 2026 ORIGINAL TAXABLE VALUE 973



 2026 “BOARD OF REVIEW" TAXABLE VALUE 973



 2026 PRINCIPAL RESIDENCE EXEMPTION/QUALIFIED AG % 0.0000



 Please feel free to contact the assessor at the address listed above or call if you have any questions.



 Valuation Appeals - If you decide to protest this decision, pursuant to MCL 205.735a, it may be further appealed to the Michigan

 Tax Tribunal by filing a petition that can be obtained at www.michigan.gov/taxtrib (click Small Claims Tab). A copy of this letter

 and a completed petition should be mailed to Michigan Tax Tribunal, P.O. Box 30232, Lansing, Michigan 48909.

The deadline for filing an appeal is as follows:



 Residential and Small Claims July 31, 2026

 Commercial and Industrial Real May 31, 2026

 Personal Property” May 31, 2026



 *you must provide a copy of the Personal Property Statement you timely filed



Classification Appeals: (to or from residential, commercial or industrial) should be directed to the State Tax Commission, P.O.

Box 30471 Lansing, MI 48909 not later than June 30, 2026

EXHIBIT L

 APPEAL OF 2026 ASSESSED VALUE INCREASE

 File No. Meadowood Rd Land



 Real Estate Appraisal Report



 Subject Property: 76-24-24-176-007 Meadowood Rd



 Date of Appraisal: 01/08/2024



 Appraiser: Brad Tarnopol.



 Appraisal Purpose: To estimate the market value of the subject property as of 11/20/2023.



 Property Description:

 The subject property is a 81x222, 17,990 square foot, 0.41 acre parcel of land located in the City of Southfield,

 Michigan. The property is completely inaccessible, having no road access, easements, or designated access points. It

 lacks any scenic value or unique natural features that might provide alternative utility. Due to zoning restrictions and

 lack of accessibility, the property cannot be developed for any traditional real estate uses.



 Highest and Best Use:

 In light of the aforementioned limitations, the highest and best use of the subject property is undetermined. It cannot be

 utilized for traditional residential, commercial, or agricultural purposes. Future zoning changes or potential alternative

 uses are outside the scope of this appraisal and in the future can be changed by the city of Southfield's zoning

 department if a potential builder purchases the entire area as a new subdivision project.



 Market Approach:

 Due to the unique and restrictive nature of the property, traditional market sales comparisons (comps) are not available

 or applicable. Consequently, the market approach cannot be utilized to estimate the subject property's value.



 Market Value:

 Based on the above analysis, and considering the limitations and restrictions of the subject property, I cannot assign a

 market value to the parcel at this time. It is important to note that unforeseen changes in zoning, access, or potential

 utilization could alter the future value of the property. However, as of today, there is no basis for a reliable market

 valuation.



 See Aerial Map for site View



 If the property is donated to the city of Southfield there could possibly be a tax deductible value. The tax deductible

 value would be determined by the city of Southfiled.



 If the land is not donated and in the future a builder does end up wanting to purchase the 31 sites on Meadowood Rd to

 build single family dwellings on a monetary sales value would be determined between the current owner and the

 potential builder.



 Market Value as of 11/20/2023: $0



 Appraiser: Supervisory Appraiser:

 Name: Bradley E. Tarnopol Name:



Additional Text Addendum Produced using ACI software, 800.234.8727 www.aciweb.com TXT2 01282013

EXHIBIT L



Produced using ACI software, 800.234.8727 www.aciweb.com Form EDOC

LOCATION MAPBorrower: Priscilla Solomon Trust File No.: MeadowoodEXHIBITRd Land L

Property Address: Meadowood Road Case No.:

City: Southfield State: MI Zip: 48076

Lender:

AERIAL MAPBorrower: Priscilla Solomon Trust File No.: MeadowoodEXHIBITRd Land L

Property Address: Meadowood Road Case No.:

City: Southfield State: MI Zip: 48076

Lender:

EXHIBIT L

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EXHIBIT N



 APPEAL OF 2026 ASSESSED VALUE INCREASE



 CITY-DESIGNATED

 HIGHEST AND BEST USE IS INDETERMINABLE



The Highest and Best Use (HBU) for the subject property is indeterminable, according to the

independent real estate appraisal, see EXHIBIT L. Such determination is based on the multitude of

severe development constraints on the subject property. As such, the same applies to the City of

Southfield’s designated HBU for the subject property, single-family residential. However, further

substantiation that the latter fails “The Four Tests” is provided further below.



Chief among the constraints on the subject property is the City’s designation of wetlands thereon.



Wetlands – Given the existence of wetlands on the subject property, as shown on the City’s official

wetlands map, the City, in 1992, further clarified that the subject property “is covered by wetlands and is

therefore undevelopable without mitigation of the wetlands”, see EXHIBIT E. The City had also deemed

the property effectively unbuildable, and thusly unusable, and potentially unsellable. Despite the age of

such determinations, absolutely nothing has since changed to diminish their validity today.



The only way to validate the City-designated HBU or, in the words of the City, to determine “whether the

property can be developed with a house”, then and now, is to subject the property to “wetlands review”

by both EGLE1 and the City. Such process, however, would require a professional survey of the property,

particularly given it is forested and its boundaries are unmarked, also a professional wetlands

delineation, and compliance with other onerous requirements, which, combined, are cost prohibitive,

particularly for an individual property owner, as discussed further herein. The fact that no such review

has occurred for any of the properties within or near the subdivision,2 despite the wetlands were first

identified 35 years ago, demonstrates the improbability of such process proving beneficial to the

landowner. The City, itself, which now owns many of the other wetlands-constrained properties in the

subdivision, also has not, to date, subjected any of its properties to “wetlands review” by the EGLE,

despite its clear intentions to develop at least some thereof.



Cost aside, the outcome of “wetlands review”, particularly for the subject property, is utterly and

completely unpredictable. Therefore, the City-designated HBU has been purely speculative and baseless

since 1991 - when the property was first designated a wetland. The City, in 1992, confirmed such

uncertainty: “we do not have an indication of what the [EGLE’s] findings will be”, again see EXHIBIT E.

Such unpredictability is due to the EGLE’s dominant authority in said review, and that it has not visited,

reviewed, or verified any “wetlands in [the] area” of the subdivision to date.3 The EGLE also does not

recognize any wetland boundary on any map, including the City’s official wetlands map, unless/until it

has reviewed and verified an “on-the-ground wetland delineation”, which has not occurred within or near

the subdivision to date.



1 EGLE = the Michigan Department of Environment, Great Lakes, and Energy, i.e., Michigan’s environmental

 regulatory agency, formerly Department of Environmental Quality (DEQ), and further prior to that, DNRE.

2 Per email exchange with the Warren District Office of EGLE, Jun 2026.

3 Ibid.

EXHIBIT N

 Page 2



Absent “wetlands review”, sufficient evidence exists to readily refute the City-designated HBU as

imaginary. Three particular sources of such evidence, all of which involve “approximation” of the wetland

boundaries on the subject property, are identified below:



 City of Southfield’s official wetlands map, undated (speculatively adopted in 1991), see EXHIBIT H1

 Friends of the Rouge (FOTR)4 wetlands map, dated 2005, see EXHIBIT H1

 USFWS Draft National Wetlands Boundary Map, dated 20155, see EXHIBIT H2



The relevant differences between the three wetland maps, above, aside from their ages, are,

speculatively, that the first (oldest) is based on some physical site inspection and the other two (most

recent) are likely based mostly on remote review via aerial imagery, GIS technology, and other methods

and sources, with some physical site sampling. Most significantly, the first (oldest) map shows about

48% wetland coverage on the subject property, while the two more recent maps both show about 85%

wetland coverage. Despite the differences, all three identify the subject property as, effectively,

undevelopable, as discussed further herein. The City appears to have historically relied solely on its

wetland map in its decision-making and ignored the other two maps.



Results of “The Four Tests”



Below are general facts corroborating that the City-designated HBU fails each of the four tests:



 The City earlier declared the abutting property to west, now owned by City, which shares part of the

 same wetland, is “unusable due to the wetlands”.6 The wetland covers about 75% of that property,

 per my calculations, per the City’s official wetlands map.

 Multiple attempts by different builders/developers to aggregate the subject property with others to

 develop a home on each have all failed, due to the wetlands.7

 None of the 31 vacant residential properties in the 84-year-old subdivision has been built to date.



Below are additional, more specific demonstrations of the failure of the City-designated HBU under each

of the enumerated tests:



1. NOT LEGALLY PERMISSIBLE



 a) Currently:

  The subject property is undevelopable, absent mitigation of the wetlands, see EXHIBIT E.

  Since the property is not developable today, the City-designated HBU is prohibited today.



 b) Near-future:

  The City’s presumption of reasonable probability that its designated HBU is legally

 permissible in the near-future has been purely speculative and baseless since 1991 - when

 the City designated the subject property a wetland.

  The only way to validate the City-designated HBU is via “wetlands review”, per EXHIBIT E,

 which is infeasible, as discussed further herein.



4 Friends of the Rouge (FOTR) is a non-profit environmental organization in southeast Michigan.

5 EGLE suggests the 2015 (USFWS) map may be more accurate than 2005 (FOTR) map “because the

 technology/techniques got better”.

6 Letter from Southfield City Administrator Robert R. Block to Hon. Mayor and Council, re: DONATION – LOT 136

 MEADOW DOWNS SUBDIVISION #1, dated 2/13/95, re: parcel #76-24-24-176-007.

7 In one example, a developer was given possession of the subject property for 3 years (1996-98), to obtain City

 entitlements, which resulted only in litigation and further financial loss, due to the wetlands.

EXHIBIT N

 Page 3



 Absent “wetlands review”, the probability is far greater of the City-designated HBU proving legally

 impermissible, in perpetuity, based alone on the fact that the independent licensed real estate

 appraiser found that the subject property “cannot be utilized for traditional residential” or other

 stated purposes, due to the limitations thereon, see again EXIBHIT L.



2. NOT PHYSICALLY POSSIBLE



 a) Currently:

  The City cannot and will not issue a permit to construct a house on the subject property,

 absent “wetlands review” and “mitigation of the wetlands”, see again EXHIBIT E.

  Since a building permit is not issuable today, the property is functionally unbuildable today.



 b) Near-future:

  The City’s presumption of reasonable probability that its designated HBU is physically

 possible in the near-future has been purely speculative and baseless since the City

 designated the subject property a wetland in 1991.



 Absent “wetlands review”, the probability is far greater of the City-designated HBU proving

 physically impossible, in perpetuity, based on the following facts:



 1) Best-case scenario (City of Southfield’s official wetlands map):

  The City’s wetlands map, see EXHIBIT H1, which shows the least amount of wetlands

 coverage on the subject property, for purposes herein, is the best-case scenario.

  In this case, the wetland occupies 48% of the subject property, per my calculations, see

 ATTACHMENT 1 hereto, based on the City’s wetlands map.

  Given the wetland is situated forward of the rear property line, it creates another 11% of

 inaccessible wasteland between the rear of the wetland and rear PL, increasing the total

 undevelopable and/or unusable area to 59% of the subject property.

  However, after applying the City’s standard front yard setback (40 feet) and a minimum

 speculative wetland buffer (50 feet)8, there is no plausible buildable area remaining on the

 property, without impacting, and costly mitigation of, the wetland.

  In the unlikelihood that the setback and buffer, above, are reduced by 50% each, the

 resulting home would prove impractical and unmarketable due to its size and, when

 combined with the lack of encroachable rear yard, the property would remain useless.

  The added liability and burden of perpetually maintaining and protecting a wetland on 48%

 or more of an occupied property, by itself, is unreasonable and impractical.



 2) Worst-case scenario (2005 FOTR and 2015 USFWS wetlands maps):

  The two most recent of the three available wetland maps, see EXHIBITS H1 and H2,

 which show near identical wetland coverage amongst each other, represent the worst-

 case scenario, given they show far greater wetland coverage than the City’s older map.

  In the worst-case scenario, the wetland occupies about 85% of the front of the subject

 property, leaving only 15% of the inaccessible rear yard unimpacted, rendering the subject

 property flat-out undevelopable, without disturbing the wetland.



 3) Other facts that further reinforce the undevelopability of the subject property under all

 scenarios above:

  “Due to zoning restrictions and lack of accessibility, the property cannot be developed for

 any traditional real estate uses,” per the independent licensed real estate appraisal, see

 again EXHIBIT L.



8 Absent a single national, state, or local standard for a wetland buffer, a 50-foot wetland buffer was applied,

 based on the typical range of 25-100 feet, per multiple sources.

EXHIBIT N

 Page 4



  Other non-traditional residential uses, e.g., passive recreation, wetland mitigation banking,

 or conservation, are also improbable, given the property, by itself, is too small.



3. NOT FINANCIALLY FEASIBLE



 a) Currently:

  Again, the City cannot and will not issue a permit to construct a house on the subject

 property, absent “wetlands review” and “mitigation of the wetlands”, see again EXHIBIT E.



 b) Near-future:



 As previously demonstrated herein, any reasonable and/or practical development of the subject

 property would require the disturbance of the wetlands thereon. The costs of such disturbance,

 however, are financially infeasible, particularly for an individual property owner, and would far

 exceed, at a minimum, the assessed value alone. Such costs are categorized below:

  Wetland permit application submittal requirements for “wetlands review”

  Wetland permit issuance requirements: avoidance and minimization of wetland impacts

  Wetland permit issuance requirements: mitigation of wetlands impacts

  Wetland permit issuance requirements: long-term monitoring of protected wetlands



 A new realm of financial infeasibility is achieved when the above costs are combined with the

 other mandatory development costs, below, which would far exceed the property’s market value:

  Tree protection and replacement per the City’s Woodlands designation

  Site preparation involving a forested property and right-of-way

  New public road

  New and replaced public utilities

  Possible assemblage with another property



4. NOT MAXIMALLY PRODUCTIVE



 Any residential use is purely speculative, unrealistic, and improbable.



ATTACHMENTS:

 1. Wetland calculations



 Prepared by: Ken Solomon

EXHIBIT N

 Attachment 1

 APPEAL OF 2026 ASSESSED VALUE INCREASE



 WETLAND CALCULATIONS



 7,337 sq. ft. (41%)

 Subject property



Wetland boundaries 8,708 sq. ft. (48%)

 per City of (Unusable)

 Southfield's

 "Official" Wetland

 Map



 Square footage

 calculations per

 Southfield's GIS Viewer

 1,937 sq. ft. (11%) measuring tool.

 (Unusable)



 Wetland boundary source: City of Southfield GIS Viewer webpage (July 2026)

424A = Meadowood and Coral Gables area

 424C = Alta Vista and sourrounding area



 Parcel Number Street Address Sale Date Sale Price Land Sale Instr. Terms of Sale Adj. Sale $ Prev. Asmnt. Asd/Adj. Sale Cur. Appraisal Land Residual Est. Land Value Effec. Front Depth Land SF Land Sale/SF Net Acres Total Acres Dollars/FF Dollars/Acre Dollars/SqFt Actual Front ECF Area Liber/Page Other Parcels in Sale Land Table Gravel Paved Inspected Date Use Code Class Rate Group 1

76-24-24-126-008 17098 CORAL GABLES 12/30/24 $351,000 $70,200 WD 03-ARM'S LENGTH $351,000 $165,450 47.14 $344,763 $61,117 $54,880 82.8 209.0 16944.8 4.1 0.39 0.39 $738 $157,113 $3.61 81.00 424A 59943/692 NEIGHBORHOOD 24A 0 1 4/20/2005 401 STANDARD LOT

76-24-24-127-006 17143 CORAL GABLES 05/29/24 $47,500 $47,500 WD 03-ARM'S LENGTH $47,500 $28,190 59.35 $56,375 $47,500 $56,375 89.6 239.0 19602.0 2.4 0.45 0.45 $530 $105,556 $2.42 82.00 424A 59425/780 NEIGHBORHOOD 24A 0 0 1/8/2025 401 STANDARD LOT

76-24-24-179-002 26256 CASTLETON 05/22/24 $350,000 $70,000 WD 03-ARM'S LENGTH $350,000 $162,310 46.37 $323,624 $98,151 $71,775 84.5 165.0 12371.0 5.7 0.28 0.28 $1,162 $345,602 $7.93 75.00 424B 59388/307 SHERWOOD VILLAGE FARMS 24B 0 1 8/27/2024 401 STANDARD LOT

76-24-24-180-015 17255 MARGATE 03/03/23 $275,000 $55,000 WD 03-ARM'S LENGTH $275,000 $137,560 50.02 $273,589 $65,911 $64,500 0.0 0.0 28749.6 1.9 0.66 0.66 #DIV/0! $99,865 $2.29 0.00 424C 58457/806 NEIGHBORHOOD 24C 0 1 11/8/2004 401

76-24-24-202-015 26835 GREENLEIGH 04/18/23 $300,000 $60,000 WD 03-ARM'S LENGTH $300,000 $142,190 47.40 $281,844 $76,978 $58,822 113.2 224.0 23958.0 2.5 0.55 0.55 $680 $139,960 $3.21 107.00 424A 58557/865 NEIGHBORHOOD 24A 0 1 10/30/2023 401 STANDARD LOT

76-24-24-203-005 16108 MEADOWOOD 06/05/23 $225,000 $45,000 WD 03-ARM'S LENGTH $225,000 $104,010 46.23 $206,876 $75,760 $57,636 101.9 230.0 21867.1 2.1 0.50 0.50 $744 $150,916 $3.46 95.00 424A 58657/099 NEIGHBORHOOD 24A 0 1 10/30/2023 401 STANDARD LOT

76-24-24-204-005 16239 MEADOWOOD 05/25/23 $341,500 $68,300 WD 03-ARM'S LENGTH $341,500 $159,060 46.58 $309,099 $88,143 $55,742 86.5 228.0 18469.4 3.7 0.42 0.42 $1,019 $207,884 $4.77 81.00 424A 58644/065 NEIGHBORHOOD 24A 0 1 8/27/2024 401 STANDARD LOT

76-24-24-227-003 15957 MEADOWOOD 09/26/24 $203,000 $40,600 WD 03-ARM'S LENGTH $203,000 $127,540 62.83 $263,058 ($3,413) $56,645 89.6 251.0 20081.2 2.0 0.46 0.46 ($38) ($7,403) ($0.17) 80.00 424A 59723/856 NEIGHBORHOOD 24A 0 1 7/14/2016 401 STANDARD LOT

 Totals: $2,093,000 $2,093,000 $1,026,310 $2,059,228 $510,147 $476,375 648.2 3.72 3.72

 Sale. Ratio => 49.04 Average Average Average

 Std. Dev. => 6.56 per FF=> $787 per Net Acre=> 137,136.29 per SqFt=> $3.15



 Land Sale/SF



 6.0



 5.0 12500.0015000.00 $5.00$4.25 $50,000$52,500

 20000.00 $3.10 $55,000

 25000.00 $2.00 $57,500

 4.0 30000.00 $2.00 $60,000$0

 $0

 $0



 3.0



 2.0



 1.0



 0.0

 0.0 5000.0 10000.0 15000.0 20000.0 25000.0 30000.0 35000.0



 APPEAL OF 2026 ASSESSED VALUE INCREASE



 THIS DOCUMENT WAS PROVIDED BY

 SOUTHFIELD DEPUTY ASSESSOR VIA

 EMAIL ON 5/8/26

 EXHIBIT

 O

MEADOWOOD RD EXHIBIT P

 SOUTHFIELD, MI 48076

 4 Parcel #76-24-24-127-029

 Property Owner: SOUTHFIELD NON-PROFIT



Owner and Taxpayer Information

 SOUTHFIELD NON-PROFIT Taxpayer SEE OWNER INFORMATION

 NEIGHBORHOOD CORPOwner 19785 W12 MILE RD # 458

 SOUTHFIELD, MI 48076-2584 p

General Information for Tax Year 2026

Property Class 402 RESIDENTIAL-VACANT Unit 76 CITY OF SOUTHFIELD

School District SOUTHFIELD PUBLIC SCH DIST Assessed Value $0

MAP # No Data to Display Taxable Value $0

FILE CODE 0 State Equalized Value $0

CURRENT USE Not Available Date of Last Name Change Not Available

MISC Not Available Notes Not Available

Historical District Not Available ensus Block Group Not Available

STATUS Not Available Exemption No Data to Display

Principal Residence Exemption Information

Effective Date No Data to Display

 Principal Residence Exemption June 1st Final

2026 0.0000% 0.0000%

Previous Year Information

 Year MBOR Assessed Final SEV Final Taxable

 2025 $0 $0 $0

2024 $2,670 $2,670 $352

2023 $2,670 $2,670 $336

Land Information

Zoning Code Not Available Total Acres 0.415

Land Value $0 Land Improvements $0

Renaissance Zone No Renaissance Zone Expiration Date No Data to Display

ECF Neighborhood 424A NEIGHBORHOOD 24A Mortgage Code Not Available

Lot Dimensions/Comments No Data to Display Neighborhood Enterprise Zone No

 Lot(s) Frontage Depth

 Lot 1 81.00 ft 223.00 8

 Total Frontage: 81.00 ft Average Depth: 223.00 ft

Legal Description

T1N,R10E,SEC 24 39 MEADOW DOWNS SUBDN NO 1 LOT 122

Land Division Act Information

Date of Last Split/Combine No Data to Display Number of Splits Left 0

Date Form Filed No Data to Display Unallocated Div.s of Parent 0

Date Created No Data to Display Unallocated Div.s Transferred 0

 creage of Parent 0.00 Rights Were Transferred Not Available

Split Number 0 ourtesy Split Not Available

Parent Parcel No Data to Display

Sale History

 Sale Date Sale Price Instrument Grantor Grantee Terms of Sale Liber/Page

 03/28/2024 $6,000.00 WD WEBERMAN, MIRIAM-LIFETIME SOUTHFIELD NON-PROFIT 03-ARM'S LENGTH 59264/759

 04/07/2016 $0.00 QC WEBERMAN, HARRY AND MIRIAM WEBERMAN, MIRIAM-LIFETIME 03-ARM'S LENGTH 49239/180



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