A developer has quietly run a “pre-application” for a 10-building housing project by the Inland, Wetlands and Watercourses Commission, but the plan could attract residents’ attention by the time it moves through to the zoning board because it will probably have an affordable housing component.

A pre-application allows a developer to run a project by the commission before filing formally, to gauge what the issues might be so some of them can be addressed before the formal process.

The commission last week voted unanimously that the project was a “significant activity,” meaning it would need a public hearing.

They were not aware of any “affordable housing” component, as that likelihood at application time was disclosed by a member of the developer’s team the meeting.

A similar project by the same group in the same location was rejected last year by the Town Plan and Zoning Commission after the public voiced strong opposition. In that case, the affordable housing statute wasn’t used.

Under the state’s 8-30g affordable housing statute likely being used in round two, the TPZC would be hard pressed to deny the project because the burden of proof would be on it to show the project was a danger to the health or safety of residents.

Affordable housing is a hot button issue in the town of single-family homes typically on one- and two-acre lots.

Under the statute, intended for suburbs to share in providing affordable housing, municipal boards can feel pressured to give approval because they almost always lose appeals by the developer and it is costly.

Miland LLC, represented by Milford attorney Kevin Curseaden and Codespoti & Associates in Orange, wants to build 10 buildings, with 60 bedrooms, although they haven’t determined how many bedrooms will be in the units.

They want to build the project on four parcels of about 22 acres near Turkey Hill Road and Route 15, off Grassy Hill Road.

Experts told the commission there are nine wetlands over two acres of the property and no wetlands would be filled, although they would be working near wetlands.

Engineer Robert Wheeway, of Codespoti & Associates, told the commission the soil has been tested extensively and 150 holes dug for percolator tests regarding a septic system.

Another member of the Codespoti team, environmental planner Jeff Gordon, said when they file the application it is likely to be under the 8-30g affordable housing statute.

Gordon said that, under the statute, 30 percent of the complex would be “affordable housing” which is different than low-income housing. Those who live in such complexes must make a minimum amount of money to qualify for rents that could be upward of $1,400 per month.

Gordon said they see senior citizens and students from the University of New Haven, whose graduate campus is just down the road, as potential tenants. Gordon said there is a possibility the complex could be age-restricted.

Under 8-30g, a municipality must reach having 10 percent of its housing stock as “affordable” before it is no longer held to the statute. Orange is currently at 2 percent, Gordon said.

Gordon said he doesn’t know when the regular application will be filed.