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Environment Must Be Considered in Affordable Housing Review

Date : Tue, 9 Feb 2010 15:05:31 -0500

For Immediate Release
February 9, 2010 Contact: Jeff Tittel, NJ Chapter Director, 609-558-9100

Environment Must Be Considered in Affordable Housing Review

Governor Chris Christie has announced a moratorium on COAH and plans to implement a five-member panel to review affordable housing in New Jersey. While the Sierra Club is glad that the Governor is addressing this issue, we believe the environment must be taken into consideration as affordable housing in New Jersey is reviewed.

"Abolishing COAH will have a bigger impact on land use and development than any other law in New Jersey's history," NJ Sierra Club Director Jeff Tittel said.

The Sierra Club strongly supports affordable housing in New Jersey. If towns are going to grow, they must provide their fair share of affordable housing. However, affordable housing cannot be used as a tool to undermine environmental protections or promote growth in inappropriate places. Furthermore, housing should be located where the jobs are, which helps prevent sprawl and pollution while providing people with economic opportunities.

It is obvious that the current system under COAH is broken. It doesn't provide adequate housing and is bad for the environment. However, we are concerned that in the name of reform, we could actually make things worse. Our biggest concern is that affordable housing projects will lack environmental review or scrutiny.

The following concerns should be considered when reviewing COAH:

* Environmental criteria should be used to ensure inclusionary development and other affordable housing projects go in appropriate locations. Affordable housing should be placed in approved waste water management areas under the adopted Water Quality Management Planning Rules and areas with adequate water supply. * We must protect our drinking water, C1 streams, and habitats for threatened and endangered species by not permitting inclusionary zoning in environmentally-sensitive areas. Inclusionary zoning should not be used as a mechanism to move water and sewer lines into environmentally sensitive areas. Doing so would only promote sprawl, overdevelopment and environmental degradation. * Inclusionary zoning should be restricted in the Highlands and the Pinelands. In those areas, we must develop a system to meet the needs of the community without harming the environment. Ways to accomplish this would be through infill development, group homes, or having the municipality or nonprofits build affordable housing. * Inclusionary zoning should be promoted in areas with existing infrastructure, town centers, and locations close to the transportation network, as well as near jobs for the people who live there. * The State Planning Commission should not be granted authority over affordable housing. Otherwise, we'll simply be replacing COAH with another agency and bureaucracy. The State Plan has been a failure and the State Planning Commission doesn't function. It is filled with developers and people who work for developers. If you think that the COAH rules are arcane and hard to follow, try following the State Planning Commission's Plan Endorsement. * Designating affordable housing as "inherently beneficial" will put towns at the mercy of developers. Developers will be able to use the inherently beneficial designation as a way to overturn local zoning and get permission to build projects in environmentally-sensitive areas. This would be a major step backwards to the days in the 1980s, when builders remedy lawsuits undermined good planning and resulted in some of the worst sprawl projects in state history. * A fiscal analysis must be done as part of inclusionary zoning or else we'll be seeing more large lot development. The fewer units built, the lower the affordable housing obligation. One solution to this problem is to base inclusionary projects on the value of the housing built. For instance, developments with 8,000 square-foot McMansions could require one affordable unit for every two market rate built. Moderately priced condos could require one affordable unit for every four condos. * Workforce housing should not be considered the same as low- and moderate-income housing. While the Sierra Club supports the development of workforce housing in New Jersey, we're concerned that towns will choose to build workforce housing instead of the low- and moderate-income housing that is needed more. There also should be restrictions to make sure workforce housing is not sold at higher market values down the line.

"We strongly support the development of affordable housing in New Jersey. If a box store can be built, affordable housing can too. We just want to ensure that as we address affordable housing needs, we protect natural resources and provide good, balanced growth in the appropriate locations," Tittel said.

Kara Seymour, Program Assistant NJ Sierra Club

145 W. Hanover Street Trenton, NJ 08618


(f) 609.656.7618


Received on 2010-02-09 12:05:31

New Jersey Sierra Club, 145 West Hanover St., Trenton, NJ 08618, USA
tel: 609 656 7612, fax 609 656 7618
or email Nicole Dallara, Outreach Coordinator, at

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