February 17, 2007
Mr. Neal Ferrari
NJ Department of Environmental Protection
Division of Watershed Management
Re. Holland Townships WMP Request to Extend Sewer Service onto Landscape
Project Threatened and Endangered Habitat at Block 6, Lot 61.
Dear Mr. Ferrari,
We are writing to request that your Bureau maintain its October 3, 2006
correct protocol decision to deny the sewer service extension onto the
Landscape Project Ranked 3 eastern portion of Block 6,
in Holland Townships Wastewater Management Plan.
Hollands Planning Board chairman requested a member of the planning
board, who is also a member or the environmental commission, to write a
report to help exempt this Rank 3 Habitat from the Landscape Project in
order to extend sewer service onto that habitat. If successfully
exempted, a sewer extension could enable a local developer who is
apparently politically-favored to build two apartment buildings behind
the
second oldest house in the Township in the Conservation Zone identified
in
the Highlands Land Use Capability Map.
We find it especially troubling that the planning board, and not the
developer, is petitioning the NJDEP for this exemption. Although
represented as being prepared by the Holland Township Environmental
Commission, the report seeking Landscape Project exemption was crafted
by
David Grossmueller with the help of Planning Board chairman Peter Craig
and just presented to the full Environmental Commission after the fact,
with no input or participation from the full Commission.
Many claims in the report are flawed and slanted toward clearing the way
for this otherwise non-conforming development. The Township is
proposing
to rezone the currently built-out lot to accommodate the high-density
apartment buildings, and is changing ordinances specifically to benefit
this development. The Township represents that the lot is within
the
water service area when, in fact, there are no water pipes to the
subject
lot.
A piecemeal destruction of upland habitat destines all upland habitat to
a cumulative demise. Habitat protection should not be site by
site, but
regional; otherwise any applicant for development will argue the habitat
area is too small.
Wisely, there is currently no process in place to remove (cherry-pick)
lots from the Landscape Project. If Holland Townships request is
somehow
granted, and Block 6, Lot 61 is removed from the Landscape Project, it
would set a very dangerous precedent, which would encourage wide-scale
destruction of habitat, followed by questionable reports like
seeking the same exemptions to promote sprawl through loss of habitat.
The cumulative impact and fragmentation would be devastating to any
habitat protection, which is now barely adequate. Creation of an
exemption process will render the Landscape Project meaningless and set
environmental protection back decades.
Thank you for your consideration of our request that you maintain your
justifiable decision to deny (both sewer extension and habitat
exemption).
Sincerely,
Michael King
Chairman,