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March 2, 2007

Mr. John Weingart, Chairman

New Jersey Highlands Council, 100 North Road, Chester, NJ 07930

RE: RPP Comments on the Highlands Draft Master Plan

Dear Mr. Weingart:

On behalf of the Regional Planning Partnership Board of Directors, I am writing to submit my comments on the Highlands Draft Master Plan. My comments are based on a lengthy involvement with the issues under review since 2001. RPP has been a proponent of the regional planning process for the Highlands as well as the original Highlands Water Protection and Preservation Act.

In general, RPP supports the major policies outlined in the plan. As a 39 year old statewide regional planning organization, we strongly support the recognition of the need to take a regional approach to environmental preservation, transportation and economic development opportunities. Water resource protection is clearly the focus of the Draft Plan and the strongest part of the Plan in terms of targets and restrictions relate to water resource protection.

RPP believes targets should also be developed for other sections for the plan, including regional growth targets that towns negotiate to distribute. The opportunities for growth should be weighed from a three systems perspective that RPP has developed. In the economic system, centered growth can provide the opportunity for a wider range of housing types to match jobs. In the transportation system, RPP is pleased to see the Plan supports Transit Oriented Development. Centered growth can boost the Transit Score for a region, increasing the level of transit service provided thereby reducing the rate of increase in congestion in the region. The environmental benefits of centered growth are well known to council members.

In the final Plan, RPP would like to see further discussion of the opportunities for growth to address social equity as these issues do not come across clearly in the Draft Plan. A central theme of RPP's three systems perspective is consideration of social equity issues such as access to job rich communities through affordable workforce housing or transit services. Access to open space is another social equity issue.

Tools that have been suggested in the plan such as Transfer Development Rights (TDR) and Smart Growth Design Controls will guide development in the Highlands towards a more coordinated approach that will further protect the vast natural resources found in the Highlands. The Final Plan, however, should provide further details on these topics. In particular, build-out for the Highlands are an important piece of information that needs to be completed to help towns understand the zoning changes required to meet the Highlands Plan and their own goals.

The details of how and where future growth will occur need to be further clarified in the plan. The prioritization of "no growth" and "growth" areas is a good start. However, it needs to be strengthened with accurate build-out data, a clear incentive plan to get municipalities to opt-in to TDR agreements and model zoning ordinances to carry out the proposed growth intentions. It is essential to the credibility of the Plan that the policies have vehicles for implementation.

RPP has developed a set of Planning Calculators designed to disaggregate State goals to regional and local actions and we would be pleased to share the Calculator methodologies with the Council and staff to facilitate target setting.

In the area of financing tools, RPP proposes that the Council consider the concept of Tax Base sharing as exists in the Meadowlands in order to curb the ratables chase and provide towns with revenue. Along with the New Jersey Regional Equity Coalition and others, RPP has developed a proposal for statewide Tax Base Sharing.

I hope these comments help facilitate the production of a Plan where promising policies can be effective in the protection of some of New Jersey greatest natural resources and in the stimulation of regional economic growth in region of diverse municipalities.

RPP would be pleased to share our updates to our Goal Oriented ZoningŪ build-out model, plan calculators, and other tools for regional planning with Council staff as you work to implement a final Regional Master Plan.

Yours sincerely,

Dianne R. Brake, President