Jim Waltman of Stony Brook-Millstone Watershed Association
The Stony Brook-Millstone Watershed Association recently wrote Governor Jon Corzine a letter, excerpted below and signed by municipal officials and prominent environmental groups:
”Dear Governor Corzine:
”We respectfully request that you use your executive authority to postpone the required date for submission of municipal Housing and Fair Share Plans required by the New Jersey Council on Affordable Housing (COAH), until after the submission date for municipalities to file their Wastewater Management Plans (WMPs), as required by the recently adopted Water Quality Management Plans (WQMP). At present the COAH plans are due by Dec. 31, 2008 and the Water Quality Management Plans are due on April 7, 2009.
”The postponement of the affordable housing plans is necessary in order for municipalities to assess their wastewater capacity and build-out potential accurately, based on in-depth, factual analysis. This has admittedly not been done, or attempted, by the Council on Affordable Housing.
”COAH has commissioned its own studies, which in themselves recognize the inability to accurately determine build out capacity until the WQM Plans are completed and filed, as stated in ‘Analysis of Vacant Land in New Jersey and Its Capacity to Support Future Growth… Final Report May 2, 2008.’
”. . .This wastewater capacity information is the most critical information that will determine where housing and other development can be built, the density of development, the potential costs to property owners for wastewater disposal, the ability of existing and future infrastructure to service proposed development, and whether such future infrastructure costs will render any new or re-developed housing affordable.
”In addition, it makes sense to postpone the due date for COAH Housing Plans because the COAH rules are still being amended and commented upon. . .This uncertainty in the rules is grossly unfair to the municipalities and the citizens of New Jersey, who will be paying a very high price for administrative inefficiency.
”This inefficiency will minimally include: paying for affordable housing, and the costs of repeatedly amending their Housing Plans, possibly suffering needless litigation from failure to comply with COAH rules, which are being regularly and continuously amended, paying the costs of sewers and sewer expansions, and the very real possibility of needless litigation from contradictions with the COAH rules and WQM Plans.
”Therefore, we implore you to take action to postpone the required due date of the COAH Housing and Fair Share Plans until June 2009 at the earliest, in order to provide an orderly, reasoned adoption of necessary amendments to the COAH rules. The most important reason for this postponement is the necessity for an accurate determination by municipalities of their buildout capacities as determined by their Wastewater Management Plan. These WMPs are vital to the health and safety of all New Jersey citizens. There is no question that WMPs will ensure adherence to standards for clean water and environmental integrity within a framework that citizens will be able to afford. Construction of housing without compliance with the Water Quality Management rules will jeopardize clean water for all residents and cannot be tolerated. . .”
Jim Waltman, Executive Director,
Stony Brook-Millstone
Watershed Association

