Comments on the 1997 Preliminary Plan
To the State Planning Commission
From MSM Regional Council
Presented by Jon Carnegie, PP, AICP
MSM Vice President, Planning
February 25, 1998
Thank you for providing this special opportunity to speak.
My name is Jon Carnegie, and I am speaking today on behalf of the staff,
members and Board of Directors of MSM Regional Council. MSM stands for
the three counties in which we work: Middlesex, Somerset, and Mercer
Counties. MSM is a private, non-profit organization that advocates growth
management and regional planning in central New Jersey.
As planners ourselves, MSM staff knows what a challenge you all face, and the tremendous obstacles that must be overcome to see the vision in the State Plan become a reality. It is our number one message today is to pledge our support for the State Planning Act and to strengthening the process of state planning in New Jersey.
We have chosen to limit our comments today to three areas -- the past, the present, and the future of state planning. As comprehensive as that sounds, I assure you that I will be brief.
First the past. Although I know this is now "water under the bridge", we must state for the record that two years was far too much time for what ended up being the reformatting and wordsmithing of the plan. It has caused more confusion and diverted more energy than it was worth. Imagine if all that time was spent on the more important work -- overcoming the obstacles to implementing the State Plan. Although we applaud the "Key Concepts" and indicators that have been added, and agree with the tightening of individual policies, the overall looseness of the Plan has not been improved. Whatever the intention, the effort did not result in strengthening the Plan enough to warrant the time and energy. This must never happen again.
Now the present. We are currently engaged in the second round of what is undoubtedly the nation's largest discussion group -- cross-acceptance. We have a few comments:
Timeframe: Give the Counties time to do the work well. If the Commission could miss its deadlines, the Counties should be allowed some flexibility. There are ways to keep their feet to the fire, while allowing extensions. No one wants to see reports coming in that just go through the motions.
Make the work for the reports count: We have reviewed at least one County report so far, and found that the comparison of master plans to the Key Concepts is just as meaningless, if not more so, than the enormous effort that went into the Comparison Phase last time, when each policy was compared to master plan policies. It is clear that the comparison of the State Plan to lofty goals in the local master plan or to well-intended studies conducted by the Planning Board, is not going to produce a meaningful assessment of whether or not the Plan is being implemented. Having compatible goals, such as preserving rural land in PA4 or encouraging growth in PA 1 or in centers, is cold comfort when the programs and regulations in place we know will not achieve these goals. We must not be in the business of comparing rhetoric. Talking the talk and walking the walk are two different things. If we are going to spend all of this time and energy in cross acceptance, walking the walk is all that should matter.
Towards that end, the Counties should do growth projections by Planning Areas and then delineate appropriate centers and nodes throughout the County to accommodate the projected growth, while keeping within the policy objectives of the Planning Areas.
This is very different from working with trend projections. County planners, like planners at every level, must determine what they want for their future -- and that includes how much development and where -- and then determine what needs to be done to make it work. To be acceptable to the State Planning Commission, County planners cannot simply accept trend projections and extend existing land use patterns in suburban sprawl. The Commission must see demonstrated how growth will be redirected to meet the State Plan's goals.
Make the County perspective meaningful: The County's report cannot be simply a compilation of municipal reports. The whole is greater than the sum of the parts. The State Planning Commission cannot negotiate with 566 municipalities to implement the State Plan, it must have the Counties providing the regional perspective.
Hold the line on Planning Areas: The ability of the State Plan to achieve its goals rests almost entirely on our ability to change land use patterns from suburban sprawl to compact development. The compromises that were necessary to get the first Plan adopted meant that we drew lines around existing patterns of development and said, okay, here is where we are today, and this is where we are going to hold the line. Although our State Plan is not set up to hold the line the way they do in Oregon, it does propose to hold the line the way we agreed in the consensus on the first State Plan -- we encourage growth in Planning Areas 1 and 2, and accommodate growth in Planning Areas 3, 4, and 5. Throughout the State, development is allowed. That policy is the reason we have an adopted State Plan. But remember the other half of the commitment -- development is allowed throughout the state in centers. If we do not identify these growth centers, and if we do not implement policies that channel new growth into more compact land patterns, we will not achieve any of the goals of the State Plan.
All of our hopes are pinned on our ability to identify centers and create incentives for growth to go there. For this reason, we cannot let centers happen first-come-first-served. They must be part of a regional plan to ensure the growth pattern is supportable. For this reason, we cannot designate a string of no-growth centers, as we have, where preservation is the focus rather than growth. Those centers will take up all of the discretionary funding available for centers, without those funds creating investments for growth. We cannot designate centers without protection of the environs, or we will create density and sprawl.
As we stated before, the Counties must do growth projections by Planning Areas as well as a regional delineation, if not designation, of centers. Counties must demonstrate that they have plans that will direct the vast majority of growth to PAs 1 and 2, and that the vast majority of all growth will be in centers, and not in the environs or dispersed throughout any Planning Area.
NOTE: The "endorsed plans" concept in the Preliminary Plan has already demonstrated itself as an unacceptable change in direction. If the intention was to include environs in centers planning, it will not work in any centers in which the environs are in other towns. Furthermore, the way in which we have heard it proposed to be used is an unacceptable watering down of the centers concept, with too much accommodation of suburban sprawl. We will fight strongly to strengthen and facilitate centers, done regionally, rather than accept the endorsed plan concept.
Our final word is for the future. If cross-acceptance achieves what we have just outlined, then we will have succeeded in bringing on board local and county plans and their planning boards. Then we must fulfill our part. We statewide advocates, and you State Planning Commissioners, must ensure that State Agencies do what must be done to provide local governments with what they need to make their plans work:
We cannot ask communities to hold the line on growth as long as they must pay major infrastructure costs like schools and sewer plants by themselves. Without a change in the dependence on local property taxes, local governments have to take part in the ratables chase. We must reduce the reliance on local property taxes.
We cannot ask local governments to change land use patterns to denser development unless we provide public utilities and, particularly, public transportation. Centers will not work without these services.
We cannot ask cities and downtowns to accept more growth without explaining how their quality of life will be enhanced -- all these years we planners have been telling them that density is bad. We now have to tell them why it can be good if it's planned properly, and how it can be made to work to improve their lives. We have to replace the equity that downtown residents lost as we supported suburban development.
And we cannot ask rural communities to hold the line on growth without providing them with Density Transfer Programs and other such tools to ease the change in development patterns.
Well, although I could go on, I will stop here today. That's not such
a long list, is it?
I will end with the statement with which I began. We at MSM pledge our
support for the State Planning Act and strengthening the state planning
process. We hope that you will be the ones out front, but if necessary
we will be. Thank you.