Below is a short list of talking points to help you prepare oral comments (optional) for the public Hearing on NJ Department of Environmental Protection (NJDEP) Highlands Rule Proposed Amendments. Please bring along anyone you can, the more supporters that attend the better.
Time: 6:00 pm Wednesday, June 1, 2016
Location: NJ Highlands Council Offices, 100 North Road (Rt. 513), Chester 07930-2322
1. Do not degrade Highlands Water. The overriding purpose of the 2004 Highlands Water Protection and Planning Act was to protect the Highlands Region’s critical water supply for over six million people. The NJDEP was charged with creating and implementing stringent regulation of development in the most environmentally sensitive, largely forested, half of the Highlands -- the Preservation Area -- in order to achieve this protection. The changes now proposed regarding nitrate dilution and septic density violate the intent and the letter of the Law: among other issues, non-degradation of the aquifer provisions in the Act.
2. The increased residential development permitted by the proposed changes will threaten not only water supply, forests, farmland, and wildlife habitat, including that of rare, threatened and endangered species, but the increased impervious cover from more roofs, roads, driveways, patios, etc. will degrade surface water quality and increase flooding.
3. NJDEP has many more appropriate and pressing issues to address than weakening regulations that protect our critical water resources. For example, the presence of lead and other toxins in NJ water, inefficient and failing infrastructure that wastes up to 25% of our treated water and updating the State’s Water Supply Master Plan, now twenty-five years out of date.
4. Bad science. NJDEP has inappropriately utilized data from populated areas of the Highlands to calculate acceptable septic waste loads for the undeveloped, forested areas, which were intended by the Highlands Act to retain their pristine condition, in order to protect their water quality and water supply protection capabilities.
5. With this rule, the NJDEP is responding to the complaints of land speculators and developers. The rule changes are designed to help them circumvent the Highlands Act. Described by DEP with phrases like “common sense changes” or “onerous regulation,” NJDEP has crafted arguments based on dubious science. New Jersey has critical water quality and water supply issues that are addressed by the Highlands Act, but New Jersey does not suffer from a critical lack of suburban and exurban sprawl development. The NJDEP has no legitimate mandate to address developers’ challenges in conforming to essential water protection regulations. To the contrary, the State is charged with protecting its water supply as a matter of the public trust.
6. NJDEP should focus on redevelopment as opposed to new “greenfields” development in the Highlands. Redevelopment has been a fundamental Highlands Act theme. Promoting new development in the core forests of the Highlands Preservation Area rather than focusing on development opportunities in existing developed areas is contrary to the central objectives and goals of the Highlands Act.
7. Once a water resource is lost to development it is lost forever! The contiguous forests of the Highlands Preservation Area act as a natural and cost free water filtration system. Conversion of forested land by development permanently destroys the ecological services provided by the forest cover, reducing the ability of the Preservation Area to provide these services. This natural forest filter reduces the need for expensive chemical treatment of water supplies. The State has a fundamental responsibility to protect these natural resources and the values they provide us --not further degrade them.
PLEASE PLAN TO ATTEND THE HEARING!
The more supporters, the more we will be heard!
Below is a map of towns that rely on the highlands for clean drinking water, please invite anyone who has a stake in clean NJ water!