Don’t pit affordable housing against the environment

Everyone knows it’s expensive to live inNew Jersey. Formore than 20 years, our state has been trying to provide affordable housing. Unfortunately, new rules put out by New Jersey’s Council on Affordable Housing will pit housing needs against clean water, open space and other environmental quality needs of our citizens.

Meeting the need for affordable housing doesn’t have to mean more sprawl, or come at the expense of our water supply, parks, open lands and natural amenities.

New Jersey’s Supreme Court, in its “Mount Laurel” decisions, ruled that every municipality must provide a realistic opportunity through local zoning to accommodate its fair share of low- and moderate-income housing. The state’s Fair Housing Act of 1985 established the Council on Affordable Housing (COAH) to calculate housing need, assign affordable housing obligations and make sure local governments meet those obligations.

One of the main tools has been “inclusionary” development – requiring low- and moderate-income homes to be built as part of larger,market-rate housing developments. In effect, the sale of market-rate housing subsidizes the affordable homes. Over time, this method of providing affordable homes has resulted in thousands of units of marketrate housing being built in rural communities, often on farmland and environmentally sensitive lands. The small percentages of affordable units that have been built are often far from jobs and public transportation.

Now the proposed COAH rules call for more than 115,000 new affordable housing units across the state. If inclusionary development remains the primary way to reach this goal- with four to five new market-priced homes allowed for each affordable unit- a total of almost 700,000 new homes would be required by 2018.

Where would we put all this inclusionary development? COAH’s proposed rules stubbornly refuse to recognize many factors affecting public health, safety and welfare and has targeted more farmland and open spaces for development.

For starters, COAH’s estimate of the state’s “vacant, developable” land is severely flawed. In addition to making blatant errors like including airport runways, highway medians, backyards and even the Picatinny Arsenal (owned by the Department of Defense), the rules completely disregard local ordinances that limit development in order to protect water supply and quality, environmental health and community character. The proposed rules are also not well integrated with other significant, legislatively mandated plans, including the State Plan and the Pinelands ComprehensiveManagement Plan. A lack of coordination with these plans is a recipe for disaster.

The COAH rules guide affordable units into the state plan’s designated growth areas: Planning Area 1 (urban) or Planning Area 2 (suburban), population centers and existing sewer service areas. However, the Department of Environmental Protection is now revising and shrinking sewer service areas because they are decades out of date and not in compliance with current environmental standards. Allowing thousands of new housing units in these old sewer service areas would mean even more sprawl in rural and environmentally sensitive areas.

To make matters worse, the proposed rules cap the amount of future open space and recreation land that can be excluded from the developable area, limiting towns to having, at most, 6 percent of its total acreage as parks and recreation areas.

Instead, COAH should encourage affordable housing to be provided through redevelopment in areas where infrastructure, jobs and public transportation are available, and offer incentives for building affordable housing without the addition of market rate units. Rehabilitation and “buy-downs” of existing housing should also provide a larger share of the state’s affordable housing need.

New Jerseyans are fed up with suburban sprawl and continue to vote for preserving our forests, farmland and open space. But most folks also understand the need for affordable housing. A more carefully thought-out set of rules would prevent these from becoming mutually exclusive goals.

Learn more about the proposed COAH rule at www.state.nj.us/dca/ coah. Contact me at info@njconservation. org/, or visit the N.J. Conservation Foundation’sWeb site at www.njconservation. org for more information.

Michele S. Byers

Executive Director New Jersey Conservation

Foundation

Far Hills