August 21, 2006

Chairman John Weingart

New Jersey Highlands Council

100 North Road

Chester, NJ 07930

Dear Chairman Weingart,

On behalf of the Association of New Jersey Environmental Commissions I am pleased to provide comments on the two of the draft technical reports that will be part of the Regional Master Plan’s Smart Growth Component. Thank you for providing us with the opportunity to comment on the draft reports prior the issuance of the draft RMP. Our comments pertain to the proposed methodology, therefore we are submitting them before the full Smart Growth Component is complete.

Potential Growth Area Identification Report

The data analysis provides for a comprehensive review of a number of parameters related to proximity to developed areas and available infrastructure. ANJEC recommends that sites with critical environmental constraints be identified up front and removed from further evaluation as a first step of this analysis. Otherwise we are concerned that sites with critical Highlands resources could considered for growth if other desirable factors are present. In the Highlands, growth areas should not contain sensitive environmental resources.

Methodology for Determining Redevelopment Area Potential Report

This report fails to differentiate itself from the Potential Growth Area Identification Report in the following key way: Redevelopment in the Highlands need not be a mechanism to facilitate growth.

The definition of redevelopment used by the Highlands Council (“a process to rebuild or restore an area in a measurable state of decline, disinvestment, or abandonment”) includes site restoration, in addition to rebuilding. The legal requirements for redevelopment in the Highlands Act in both the Preservation and Planning Areas are to “promote brownfield remediation and redevelopment (10.b.7, 10.c.8)”. However the proposed redevelopment scenarios included in this report do not allow for the identification of brownfield sites for conversion to green spaces. Densely developed areas in the Highlands would benefit from parks and open spaces that provide opportunities for recreation and other environmental gains such as air and water quality. Amendments to the New Jersey Brownfield and Contaminated Site Remediation Act provide matching grants for municipalities and other redevelopment entities for remedial costs for open space or conservation projects. The methodology proposed actually prevents these opportunities from being identified by the Highlands Council. The Council should establish a “Scenario D” with these types of projects in mind. Otherwise municipalities may have difficulty in acquiring funding and getting permits for developing new parks or recreation fields on brownfield sites, particularly in the Preservation Area.

Thank you for your consideration of our comments and we hope that you will adopt these recommendations as you more forward in identifying potential growth opportunities in the Highlands. Please contact our Highlands Project Director, Tina Bologna, if you’d like to discuss our comments further.

Sincerely,

Sandy Batty, Executive Director

Cc: Dante DiPirro

Tom Borden

Steve Balzano