In this half of our testimony to the Office of Smart Growth we have been able to be a little more comprehensible to the average citizen. It contains more information about neighborhoods.

SBB’s Dover Township comments continued —

Numerous studies exist proving that a decline in water quality can be seen in relation to land use/impervious coverage amounts. Some studies show a decline starting with impervious coverage amounts as low as 10%. (Build out analysis, Grant F. Walton Center for remote sensing and spatial analysis, 5/01 Cook/Rutgers University).
http://www.crssa.rutgers.edu/projects/runj/buildout.html

Additional reports and documents on watershed based planning should be incorporated into the review of this petition. We recommend a thorough review of the Final Comprehensive Conservation and Management Plan, 2/01, Barnegat Bay Estuary Program to help determine appropriate future growth parameters.

The State of New Jersey Shellfishing Chart which Mr. deCamp submitted at the hearing, shows much of the water off Dover Township already degraded. Further development can only exacerbate this trend.

The watershed of Long Swamp Creek, which is fully within Dover, is already over-developed and suffering the consequences.

Interested parties, including Save Barnegat Bay, have recently begun the petition process for the Toms River to have recognition by the New Jersey Department of Environmental Protection as a Category One waterway. Dover Township should support and encourage the 300-foot buffer protection for this waterway through plan endorsement.

Dover Townships recent development has occurred while designated as a CAFRA Coastal Center which has allowed for proposals up to 80% impervious coverage with minimal amounts of required forest preservation. This intense development scenario that continues today leaves us to wonder if any further intense growth is appropriate and/or sustainable. The geographic extent of all the combined centers should be greatly curtailed. The underlying Suburban Planning Area (PA2) would allow a more appropriate intensity of development proposals in the majority of the township. Limiting center boundaries and encouraging a process through which Dover Township could improve the development that already exists is more desirable. Similar to residents in most areas that have become examples of uncontrolled sprawl, Dover citizens are looking for ways to improve their quality of life; not further degrade it.

We support the Townships “investigation of the establishment of a cross jurisdictional planning effort with regard to stormwater runoff in the Toms River basin to achieve compliance with the new stormwater regulations” as part of plan endorsement.

We support the inclusion of the area located to the south and east of Hooper Avenue in the proximity of Fischer Boulevard as PA 5 for protection of Silver Bay tributaries and wetlands.

The comments below are based on Information gathered through documents submitted with the plan endorsement proposal as well as an actual groundtruthing of existing conditions:

o The East Route 37 center should include the addition of the Anchor Reef Property, including any adjacent waterfront properties, for public acquisition and recreation and be included in the Townships Open Space, Recreation and Conservation element.

o This parcel is listed in the Century Plan and would serve as an important addition to the Open Space and Recreation component within the Township.

o This area is within the FEMA boundary.

o The Anchor Reef area should not be allowed to be partially developed, and should not be allowed to be made part of a redevelopment zone. This is the only suitable site for a public boat launch and general public access on Dover Township’s waterfront. To permit a nonpublic access function in the Anchor Reef area would constitute a tragic failure in planning.

o The 80% Impervious Coverage Toms River Regional Center should be reduced in geographic extent and not include any proposal for redevelopment that would affect existing public open space at the Emerald Apartments located at the “Dover Mall”

o A stream corridor protection plan should ensure no further degradation to the Long Swamp Creek, a tributary of the Toms River.

o The Fischer Boulevard Center appears to promote sprawl through further corridor-based development. We oppose ANY consideration of a Fischer Boulevard extension to the Garden State Parkway. In addition to wetland destruction, this will cause hellacious aggravation of local traffic as people try to cut the corner from the GSP to the Seaside Bridge.

o We oppose center designation along Fischer Boulevard. Even with future road improvements, the road will barely be able to handle the existing load of traffic. The locals do not want it. It will create a lot of traffic on parallel roads.

o In addition, high amounts of impervious coverage are not desirable in this location adjacent to Cattus Island County Park.

o The Silverton Center should have refined boundaries and not promote sprawl through corridor based development.

o The area North of Hooper Avenue appears to have wetlands that may be within center boundaries. The center boundaries should be clipped back on the North end.

o NO consideration should be given to any extension of Fischer Boulevard through sensitive wetland areas.

o The Northwest Dover Center is an area of the municipality with large areas of open space and/or farmland, and is therefore not appropriate as a center.

o The center has limited potential for infrastructure improvements.

o The area of Whiteville Rd/McPherson appears to have wetlands or a tributary within the center boundary.

o This center should be removed from the proposal and left to function as an “environ” with limited development. This would allow for an area of aquifer recharge in an otherwise highly developed municipality with large amounts of existing impervious coverage.

o The 571/Parkway Center encourages development in an area of Community Water Supply Wells.

o We do not support the designation of this center.

o A Wellhead Protection Ordinance is necessary to safeguard these public potable water supplies.

Although many of our comments focus on specific changes to the centers, we also note the need for additional overall improvements to the application as guided by other statewide policies, goals, and strategies.

These improvements include:

• Utilization of DEP Landscape Mapping for protection of portions of the Township with potential threatened and endangered species habitat
• Implementation of a Stream Corridor Protection Plan
• Implementation of a Wellhead Protection Ordinance
• Proof of a sustainable water supply through a Utility Services Plan and appropriate studies

We are concerned that various proposals for redevelopment may encompass pristine areas immediately adjacent to developed areas, thereby reducing the amount of open space or encroaching on environmentally sensitive areas. We urge the Office of Smart Growth to scrutinize all proposed redevelopment in this regard.

We would also like to take this opportunity to note that a current trend is emerging where “Redevelopment” projects are creating instances for abuse of Eminent Domain. It is unclear to us where Dover Township is in the official process of declaring certain areas “In Need for Redevelopment”, however, we strongly urge that if and when appropriate, that a requirement for a condition to the Township resolution prohibiting the abuse of Eminent Domain be included. We believe that this practice is necessary to ensure the extent and character of the coastal communities development will remain unchanged.

Thank you for your consideration of these comments. We believe that the inclusion of our recommendations in the Plan Endorsement process will result in an improved application for Center designation in our sensitive coastal region.

Respectfully Submitted,

Helen Henderson, Project Manager
William deCamp Jr., President

cc: Lisa P. Jackson, Commissioner, NJ DEP
Rick Brown, Office of Policy & Planning, NJ DEP (via e-mail)
Jung Kim, Office of Smart Growh, DCA (via e-mail)

* * * * * * * * * * * *

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”.