June 10, 2004
Colonel Richard J. Polo, Jr.
Commander and District Engineer
New York District, U.S. Army Corps of Engineers
Regulatory Branch, ATTN: Route 92 DEIS
26 Federal Plaza, Room 1937
New York, New York 10278-0090
Dear Mr. Polo:
Having spoken briefly at the hearing held in South Brunswick on May 20th on the Draft Environmental Impact Statement (DEIS) on Route 92, I am writing to supplement my statement.
The Regional Planning Partnership (RPP) is a not-for-profit organization founded in 1968 in central New Jersey to support sound land use decisions and regional cooperation. We are one of the few organizations whose agenda includes multiple goals - the economic, social, and environmental outcomes that can be achieved through land use planning, regulations and infrastructure investments that will result in the future quality of community life.
In pursuit of this agenda, RPP has done a significant amount of work over the years on the connection between land use and transportation. Through an FTA grant in the early 1990s, RPP demonstrated that if land use patterns changed from low density, single use development to denser, mixed use centers, with considerable open space preserved outside of growth areas, the increase in traffic could be reduced by as much as 60% over 20 years. We have been working on getting such a change in land use patterns ever since.
Since we were founded over 35 years ago, we have built a track record of support for environmental protections, in particular, advocating strong protection for wetlands. For this reason, we were pleased to see that the DEIS was a thorough document, demonstrating that the wetlands impact associated with the project were minimal compared to the need for the project, and that the significant amount of mitigation and preservation associated with the project were adequate.
Although RPP feels that the NEPA process has some limitations, we do feel
that the process worked well in the case of Route 92. When the project
was first proposed, over 33 acres were to be impacted. Today, the project
will impact only 14 acres, with about
55 acres of wetlands mitigation and over 200 acres preserved. (It is ironic
that the 200-acres preserved by the Turnpike Authority would have been
a large-scale housing development today if the land had not been bought
for the project.)
I reported at the hearing that RPP has favored Route 92 since the mid-1970s, when we opposed connecting I-95 to New Jersey through the Hopewell Valley and the Sourland Mountains, an area that was environmentally sensitive and had little development and infrastructure. Instead, we advocated making the Turnpike the preferred I-95 Corridor, promoting a connection between I-95 in Pennsylvania to the Turnpike somewhere near Philadelphia and Camden.
Consistent with that position, we supported Route 92 in central New Jersey since that connection would improve the east/west between the Turnpike and Route 1. Unlike the Hopewell Valley, the Route 1 Corridor already had considerable infrastructure and development, and remains today the economic engine of the region.
I heard a great many people at the hearing opposing Route 92 on environmental
reasons. I know that the Sierra Club has named Route 92 as one of the 10
most sprawl-inducing projects in the country. They think that policy-makers
can only prove their Smart Growth credentials by denying the permits Route
92 needs to get built.
It is RPP's position that this view is based on the inappropriate application
of a good idea. Whereas we agree that land use and transportation decisions
should result in reducing the growth in auto traffic, and we agree that
we simply building more roads will not solve our congestion problem, we
emphatically do not agree that this means never building another new road
anywhere.
Research demonstrates that new highway capacity only induces new development in areas where there is little economic activity. In areas that are already significantly developed, like the Turnpike's Exit 8 A as well as Route 1, where there are 10s of millions of square feet of commercial development and at least 10 million square feet more already approved, and where there is already significant demand for new capacity, new highways do little to induce new traffic.
A multi-faceted package of solutions is needed to solve New Jersey's transportation problems -- new infrastructure (transit and highways), transit services, land use and demand management practices. Route 92 is a project that is needed in that package: it is appropriately located, connecting two growth areas delineated in New Jersey's State Development and Redevelopment Plan on an alignment that will have strict limitations on access and designed to minimize the impact on the environment; it will serve existing and approved development, attracting traffic that would otherwise be on residential roads; it will provide a means to separate regional from local trips; and it will provide a means to improve road-based transit services by improving the inadequate east/west network in the region. It is already under study by New Jersey Transit as a gateway location for the proposed Bus Rapid Transit service on Route 1.
The Central Jersey Transportation Forum supports Route 92. The Forum is a group made up of officials from 20 municipalities, the 2 MPOs, the 3 Counties and some corporate and non-profit interest groups. When it was founded five years ago, they reached consensus on a goal to improve the east/west connections in the Route 1 Corridor. The Forum oversaw a traffic model of the region that clearly demonstrated the need for Route 92 and the improvement in congestions that its construction would make on the local roads in its vicinity.
I urge the Corps to issue the permit for the construction of Route 92 as soon as possible. It is a project that is decades overdue.
In closing, I also ask that you pass on our congratulations to the hearing officers conducting the May 20th meeting. They handled what could have been a tumultuous meeting masterfully. They demanded - and got - respectful behavior from an audience who had demonstrated that they would have rather booed and hissed at speakers who did not share their opinion. As a speaker from a small group of supporters present at the evening hearing, I certainly appreciated their command!
Yours sincerely,
Dianne R. Brake
President
C: Hon. James McGreevey, Governor, State of New Jersey
Mr. Michael Lapolla, Executive Director of the NJ Turnpike Authority
Hon. Jack Lettiere, Commissioner, NJ Department of Transportation
Hon. Bradley Campbell, Commissioner, NJ Department of Environmental Protection