Princeton Hydro, a highly respected water quality consultant retained by Save Barnegat Bay, has found the stormwater management plan submitted by Paramount Homes to be extremely inadequate. If NJDEP is serious about protecting “C-1 Waters“, they must deny this CAFRA application.
906-B Grand Central Avenue
Lavallette, NJ 08735
August 26, 2003
Willie deCamp or Jen O’Reilly 732-830-3600
Michele R. Donato, Esq. 732-830-0777
STORMWATER PROPOSAL HIGHLY DEFICIENT
A professional evaluation of the Traders Cove Environmental Impact Statement (EIS) submitted to the Department of Environmental Protection has found the developer’s stormwater protection plan highly deficient.
“The proposed stormwater management system for the Mantoloking Cove project shows that the water quality of Barnegat Bay will not be protected and that the anti-degradation policy established by NJDEP for C1 waters will be contravened,” according to a nine page study of the project submitted by Dr. Stephen Souza, president of Princeton Hydro, a stormwater expert retained by Save Barnegat Bay. [pp. 8-9]
The application proposes 62 luxury condominium units, a restaurant, and an upgraded marina on an eleven acre site immediately adjacent to the Forsythe National Wildlife Refuge. Under Brick Township’s Master Plan the tract is designated for open space and recreation.
“The information supplied by the applicant fails to support a no impact conclusion and actually shows that the project will result in a deleterious impact to the quality and natural resources of the Bay,” Dr. Souza states in the report. [p. 9]
The report identifies dozens of major defects in the applicant’s Environmental Impact Statement. Among them:
– “There was no data or narrative analysis available for the stormwater management plan that could be used to quantitatively critique the system’s performance capabilities. This precludes the ability for any reviewer (including the NJDEP) to conduct a detailed, comprehensive assessment of the stormwater management system. [pp. 5-6]
– “The site is adjacent to a federal wildlife refuge, yet the EIS makes no mention of the impact of this development on the refuge.” [p. 4]
– “No stormwater management provisions are provided on the plans for the compacted gravel parking lot that will service the restaurant and the marina.” [p. 5]
– “The expansion of use of [the gravel parking lot] results in an overall increase in both vehicular and boat traffic of the parking area and the adjacent waterways, thus increasing the opportunity for additional pollutant loading to the Bay. 
– The stormwater detention basin is undersized due to the fact that the applicant has used incorrect assumptions as to the permeability of the existing soils. [p. 6]
– Even if the stormwater basin were redesigned using a correct runoff co-efficient, it would not come close to meeting the state’s standards for removing solid particles and nitrogen from runoff. [p. 6]
– “The (applicant’s) EIS does not address how the change in the intensity and magnitude of the site’s use will affect the shellfish and aquatic resources of the site and immediate neighboring areas.” The site is adjacent to waters used for shell fishing. [p. 5]
– The applicant acknowledges that submerged aquatic vegetation will be disturbed, but does not offer a solution in compliance with the state’s regulations. (NJAC 7:7-3.6) [p. 4]
“The gross deficiencies that Princeton Hydro has found in their scientific analysis only reinforce our impression that the developer is relying on his political connections rather than sound planning,” said William deCamp, Jr., President of Save Barnegat Bay.
“We believe the Traders Cove proposal is beyond repair and should be denied by the Department of Environmental Protection,” said deCamp. “It is far too dense and unacceptable as a neighbor to a federal wildlife refuge”.