March 2, 1998
Ms. Donna Lewis, County Planner
Mercer County Planning Division
Mercer County Administration Building
640 So. Broad Street
Trenton, NJ 08610
By Facsimile: (609)989-6546
Dear Donna:
I apologize for being unable to appear in person at the Cross-acceptance meeting held last week. Instead, we are submitting our comments in writing.
As you know, MSM is a private, non-profit organization that promotes sensible development and regional cooperation throughout the MSM region -- that is in Mercer, Somerset and Middlesex Counties. This is our 30th anniversary year. Our membership includes individual citizens, as well as representatives of corporations, development professionals, and environmentalists from around the region. Our agenda is to protect and enhance the quality of community life, now and into the future, in our region. We monitor the ways in which our land is being used, or is proposed to be used, and evaluate that use in terms of our overall mission. Because of this agenda, we have long been supporters of State Planning in New Jersey. It is within this context that I submit these comments.
Task Well Done: First, we congratulate the County planning staff, as well as the municipal representatives who worked with them, who developed this Draft Report. There is a great deal of work represented here. I can see that Mercer County is keeping its reputation, established in the first round of Cross-acceptance, as a planning leader in New Jersey.
Task Complete but Not Clear: Secondly, I feel that the County has responded appropriately to the requests made by the State Planning Commission (SPC). There are, however, more questions raised than answered in the Report, leading us to conclude that it does not tell the SPC, or the public, whether or not planning in Mercer County is consistent with the State Plan. That is the purpose of the Comparison Phase report and is crucial because, as demonstrated by the Impact Assessment of the Interim New Jersey State Development and Redevelopment Plan (Rutgers University, Center for Urban Policy Research, February 28, 1992), it is only through implementing the State Plan -- its Resource Planning and Management System as well as its policies -- that we all will be able to reap the Plan's potential benefits.
It is not the County's fault if the SPC's specifications for the report did not elicit a clear assessment of whether or not the Plan is being implemented. However, the SPC intended to elicit this assessment by introducing the "Key Concepts" as the means by which the comparison should be made. It was intended as an improvement over the Comparison Phase last time, which required a laborious assessment of each policy in the State Plan to each policy in each municipal master plan. But the way in which Mercer County reported on the Key Concepts, did not make the report clear as to how well the Plan is doing in Mercer County. Although there were some examples of the key concepts being applied, there was no local or County assessment as to whether or not these examples would lead to the goals of the State Plan being implemented. For example, a report that meetings were held, is not a comparison as to whether planning is "collaborative and coordinated". The comparison to key concepts could have been more complete with much more analysis as to the expected outcomes of policies or actions.
Every municipality was judged to have plans that are "generally compatible" with State Plan goals. Yet, as mentioned above, the examples of implementation given in the comparison to the key concepts are extremely weak. Being compatible with the State Plan undoubtedly means changing the direction of planning in Mercer County. Either the State Plan policies are not strong enough to change the status quo and achieve the stated goals, or a casual assessment of "generally compatible" is not accurate. From my own experience, I would judge that both are true. The State Plan does need to be clearer and stronger, and we have submitted written comments to the SPC accordingly. And local master plans, although they often have goals and policies that are similar to the State Plan, have practices, zoning and other ordinances which do not implement these goals. For example, some Townships express a desire in their master plans to "keeping their rural character" and yet have zoning that will suburbanize their landscape.
The County has also stated in the Report that it is not seeking center designations at this time. It is our view that unless the County and municipalities have identified centers of growth and can demonstrate programs that will facilitate growth in those areas, and programs that will meet the underlying policy objectives of the PAs, they do not have plans "generally compatible" with the State Plan. To be worthy of all of the time and money spent on it, Cross-acceptance must really tell us whether or not the local and County Plans will achieve the goals and policies of the State Plan.
Suggestion for Negotiation Phase: We can understand that the County is reluctant to judge local plans. And yet, the SPC cannot evaluate 566 local plans. The County needs to do that work. To provide a positive context for this evaluation, the County can, during the next phase of Cross-acceptance, develop growth projections that assigns growth to the various Planning Areas (PAs) and identify the centers where the majority of that growth should go. In addition, an outline of the major programs that are in place that will facilitate that growth in these chosen locations, as well as programs that will protect the environs and implement the policy objectives of each PA, would be a major contribution to Cross-acceptance. If Mercer County can demonstrate that a significant majority of growth will take place in PAs 1 and 2 (metropolitan and suburban) and in appropriate centers throughout, the public can be assured that the County is seriously trying to implement the Plan.
MSM Will Help: MSM volunteers its limited resources to help the County in this task. As part of our Sustainable Development Project we will be developing at least two land use scenarios for the County -- a build-out of current plans, and a State Plan-based future alternative. We will be working on these scenarios throughout the year, and should be within the SPC Cross-acceptance timeframe.
Specific Comments on Report: In general, the County has raised a number of important issues that needs to be addressed in Cross-acceptance. MSM agrees that these are critical issues and promises to help the County be sure that the SPC addresses them satisfactorily. However, there are several specific changes to the County's Cross-Acceptance Report that we strongly encourage the County to make before submitting it to the SPC. These include the following:
- Encouraging the SPC to "endorse" the Transportation Development District (TDD) Plan instead of designating a Regional Center is a mistake. The concept of endorsed plans was not intended to replace center planning, but to encourage more holistic planning for the center and its environs.
- The County should make clear its position on a number of the issues raised by municipalities, such as the Princeton bypasses and the Hightstown/East Windsor dialogue, or other interlocal issues, in which it is clear that the municipality alone cannot implement the policy or proposal.
- The County should clarify the reasons for the Map Amendments. There is very little basis submitted for determining the thinking behind changes to the current map. From the material presented in this draft, some municipalities have too many centers, and some do not have the right ones. For example, it is not clear why Washington Township has two proposed Town Centers, or why West Windsor has changed the identification of the Princeton Junction center from a Town to a Village.
- Although we are pleased that an effort was made to identify cores and nodes, they were not supported by information on what makes these appropriate for identification. We are also disappointed that the County is not planning to pursue center designation. Both tasks are appropriate, and should be encouraged, for the next phase of Cross-acceptance. As we stated above, the County should exercise leadership by distributing the County's growth to the various PAs and work with the municipalities on centers, cores and nodes that will absorb this growth. In addition, the County should encourage local programs that will facilitate development in centers and nodes and programs that will meet the PAs' policy objectives.
In conclusion, we would be honored to work with the County and the municipalities throughout the rest of Cross-acceptance to ensure that the results will benefit all the citizens of Mercer County. Thank you for this opportunity for making our comments.
Yours sincerely,
Dianne R. Brake
President
Copy: County Executive Robert Prunetti
MSM Board of Directors
Mercer County Mayors
Herbert Simmens, Executive Director, OSP