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The test adopted by North Carolinas2 and a growing number of other state courts to evaluate exactions is the "rational-nexus" test.33 The test embodies three principles: (1) the attribution principle, (2) the proportionality principle, and (3) the benefit principle. In determining whether an adequate connection exists, it first must be shown that the development will create a need for new capital facilities, the so-called "attribution" principle. A local government need not prove that exaction requirements were assessed to meet a need so/e/y generated by a particular subdivision. Instead, as the Wisconsin Supreme Coud held in a case involving development fees to fund new schools, a rational nexus is sufficiently established if the local government can demonstrate that a series of developments have generated a need to provide educational facilities for the stream of new residents.34 The second principle, proportionality, has been described by the North Carolina Court of Appeals as requiring that a "subdivider can be required 'to bear that portion of the cost which bears a rational nexus to the needs created =2. The North Carolina Court of Appeals adopted this test in Batch v. Town of Chapel Hill, 92 N.C. App. 601,376 S.E.2d 22 (1989), rev'don other grounds, 326 N.C. 1,387 S.E.2d 655 (1990), cert. denied, 496 U.S. 931 (1990). It was applied by the same court in Franklin Road Properties v. City of Raleigh, 94 N.C. App. 731,381 S.E.2d 487 (1989). The North Carolina Supreme Court has nol addressed this matter. 33. For a full discussion of the specifically and uniquely attributable test, the rational nexus test, and reasonable relationship lest, see Blaesser and Kentopp, 'Impact Fees," 55, 64; Smith, "From Subdivision Improvement Requirements," 5, 10. See also Ducker, 'Taking Found for Beach Access Dedication Requirement," 2. 34. Jordan v. Village df Menomonee Falls, 137 N.W.2d 442 (Wis. 1965). 38