SBB has recently submitted comments on Dover Township’s Planning to the NJ Office of Smart Growth. Bottom line: Too much is development is proposed. This is the eye-glazing half of our testimony, that highlights the enormous gulf to be crossed in translating your desire for less development into the language state employees speak. SBB Project Manager Helen Henderson was the principal author of SBB’s comments.

May 24, 2006

Via Electronic and Regular Mail
Eileen Swan, Executive Director
Department of Community Affairs
Office of Smart Growth
101 S. Broad Street
PO Box 204
Trenton, NJ 08625-0204

Re: Dover Township Petition for Initial Plan Endorsement

Dear Ms. Swan:

Please accept these written comments in addition to public testimony that was provided on behalf of Save Barnegat Bay at the April 24th hearing regarding Dover Township’s Petition for Initial Plan Endorsement.

We are grateful to the Office of Smart Growth(OSG)for giving the public the chance to express itself at the local hearing.

Our comments seek to ensure that the process of plan endorsement and the proposed planning initiatives of Dover Township adequately address the Statewide Goals and Strategies and Policies of The State Development and Re-Development Plan as well as consistency with CAFRA and the Rules on Coastal Zone Management.

We believe that the current plan is not in accord with the overwhelming desire of Dover Township citizens to see rampant development curtailed. We are also concerned that the ecology of Barnegat Bay cannot sustain the level of development proposed. We are relying on the Office of Smart Growth to vindicate our democracy and our ecology in dealing with the proposed plan.

Our review of the petition finds that portions of the proposal are inconsistent or flawed. The petition and proposed map changes are not consistent with CAFRA or the Coastal Rules (NJAC 7:7E).

Given that Dover’s historic coastal center was reinstated by rule as a result of OSG’s completeness determination prior to 3/15/06, it is imperative that the petition and map changes not only comport with the State Plan but also with CAFRA’s requirements for, among other things, minimizing impacts on coastal resources and resource capacity as well as limiting adverse secondary and cumulative impacts of growth on local and regional coastal resources.

Additionally, the OSG should hold coastal centers like Dover accountable to performance standards set forth in the Coastal Rules regarding the protection of Special Resource Areas and other natural systems affected by growth associated with center-based development. CAFRA is directly linked by rule to the State Plan, so decisions about the appropriateness of development made pursuant to State Plan requirements and policies are only half the equation. The same consistency determination must also be made for plan endorsement petitions located in the CAFRA zone, like Dover, with respect to CAFRA and the Coastal Rules.

The following are our recommendations for a more consistent Plan Endorsement submission identified by specific policies of the State Plan. Some concerns are identified through a specific problem in a proposed center.

• A build-out analysis is proposed as part of plan endorsement. In light of the problems with water supply and non-point source pollution entering the Barnegat Bay, this issue must be addressed immediately. A clear coordination between growth and sustainable water supply is imperative as well as further studies on the impacts additional development will have on the Bay and coastal resources. Risk and hazard planning are not properly addressed in relevant proposed centers. In particular the proposed plan should be scrutinized against the following Statewide Policies:

Water Resources, “Protect and enhance water resources through coordinated planning efforts aimed at reducing sources of pollution and other adverse effects of development, encouraging designs in hazard-free areas that will protect the natural function of stream and wetland systems, and optimizing sustainable resource use:
• #3 Watershed Resource Planning: Institute a watershed-based resource planning and permitting program which addresses sustainability of ground and surface water resources including, at a minimum: water quality, water supply, wastewater management, land-use planning and regulation, nonpoint and point source pollution abatement, flood control and effects of inter-basin transfers.
• #34 Flood Control in Tidal Areas:Implement federal flood hazard reduction standards in areas subject to tidal flooding to reduce flood damage.”

Coastal Resources, “Acknowledge the statutory treatment of the coastal area under federal and state legislation, coordinate efforts to establish a comprehensive coastal management program with local planning efforts, undertake a regional capacity analysis, protect vital ecological areas and promote recreational opportunities.

…“The success of New Jersey’s shore economy is due to the number and quality of its varied resources. As development pressures increase, the quality of the resources responsible for the surge in development begins to decline. Traffic congestion, water pollution and beach deterioration result in adverse impacts to the shore’s otherwise strong economy. Increased development results in exacerbated stormwater runoff, waste disposal problems and accelerated water quality impairments in the ocean and back bays. Consequences can be measured in terms of storm-related property damage, commercial losses from declines in tourism and fishing, and threats to the public health and safety. Improving the integrity of the coastal ecosystem, therefore, will have economic benefits, as well.”
• #5. Coastal Resource Management: Promote well-planned and revitalized coastal communities that sustain economies, are compatible with the natural environment, minimize the risks from natural hazards and provide access to coastal resources for the public use and enjoyment.
• #7. Disaster Planning and Mitigation: Coordinate growth management plans and policies with response planning and mitigation for disasters, including major storm events and events that can result in loss of life, extensive flooding and shorefront erosion.
• #12. Aquifer Protection and Water Conservation: Conserve water resources in the coastal area, particularly those areas dependent on ground water withdrawals, to reduce water demand so that withdrawal does not exceed aquifer recharge, to prevent saltwater intrusion that could degrade or destroy ground water resources and to maintain and preserve flows to streams and wetlands.”

Click here for Part Two of Comments.

Also, Read SBB’s comments at the April 24 public hearing.

To learn more specifics online visit the Office of Smart Growth Plan Endorsement, and then scroll down to “Dover”.