May 16, 2017
Followers of CFR will know that we are very conservative about new development in town, especially on previously undeveloped property. We have been following the Township’s proposal to build affordable housing units at Nelson Street in Whitehouse Station; last October we shared an article on the Nelson Street tract and based on information available at the time we were supportive of the proposal (1). Since October there has been heightened discussion about state affordable housing (AH) mandates, and further hearings and information on the development. We are keenly aware of the opposition to it by some residents in the vicinity of the development. So it won’t surprise you that we’ve been taking a fresh look at the proposal, which has recently been approved by the Planning Board.
We applaud the community for recognizing that the town needs to continue to demonstrate its proactive approach to meeting its affordable housing (AH) obligations as defined by the State. To call this an imperative is not melodramatic – the implications for Readington losing its immunity from ‘builder’s remedy’ lawsuits could turn the town upside down.
While the Nelson Street development will yield 144 units of credit to our AH plan for building 72 rental units, the objections are that it: will impact local wetlands, increase traffic, and remove wooded space from the downtown area. These are legitimate concerns. Let’s review them.
Wetlands: Wetlands are defined and regulated by the DEP. There are identified wetlands on a portion of the 7-acre tract – approximately ¾ of an acre. We have reviewed a copy of the Environmental Impact Statement for the development. The report demonstrates a comprehensive and thoughtful review of over a dozen categories of potential impact. Some encroachment on the wetlands has already been approved by the DEP under a previous plan, and final approvals will require an updated permit based on the current plan. The report notes that the encroachments have been designed to meet the necessary conditions to secure approval, indicating a proactive approach to the issue. In fact, the report elsewhere actively praises the careful attention to the natural resources of the site in the planning, allowing most adverse environmental impacts to be avoided or minimized by design. Mitigation activities are built into both the construction phase and the as-built phase, including careful adherence to the Standards for Soil Erosion and Sediment Control Plan.
Traffic: Route 523 in general, and the Main Street section especially, is where Readington residents actually experience rush hour traffic. Most of the time navigating the area is not a problem, but people returning home from work can find it very slow. Adding 72 residences to the downtown will add to the congestion. On the flip side, our AH obligations are going to require that we add housing units, and they will certainly be in our more densely populated areas because of the need for sewer and water.
The State’s rationale for encouraging development in town centers is to revitalize them and reduce dependency on car travel in NJ. Opposing this particular development simply kicks the can down the road. Depending on our final AH obligations, we will likely have to accept the building of more units in the downtown section and along the Route 22 corridor, where we already have many of our affordable units. Development on Route 22, of course, puts most people out of walking distance to schools and the train station increasing the dependency on automobile traffic.
We obtained a copy of the Traffic Impact Study for this development. The traffic engineers studied existing traffic patterns and counts and considered such things as trip distribution patterns, demographics, intersection capacities, and peak hour traffic operations. While they recognize that the current Level of Service for traffic flow on Main Street is not optimal, they also find that the impact of the development will be negligible, even at peak hours.
General concerns about traffic on Main Street should be addressed outside of this issue. Parking availability, traffic flow, and the railroad crossing do warrant attention regardless of this particular project.
Open Space: It’s harder to get over this. We wouldn’t diminish the value residents place on having the buffer. The new development will still maintain a substantial buffer of open space – over one-third of the tract will be dedicated to open space located between the new homes and Whitehouse Village. The Planning Board is leaving it to the residents of Whitehouse Village whether the existing bridge and walkway will remain open.
There have been suggestions by residents that such a development be located elsewhere. This would require land purchases, negotiations, and all the delays associated with starting from scratch. The Nelson Street tract has been part of the Township’s plan since 2009 and is still far from putting a shovel in the ground. Other places along Main Street that have been suggested would still add the same volume of traffic onto Main Street. Relocating the development could bring even be more traffic if the new location doesn’t provide equivalent bonus units that Nelson Street has. Locations further out on Route 22 may not meet walking-distance needs of concentrated AH. Furthermore, next year and in the years afterwards Readington will probably need to build more AH units.
It’s also important that we remember this development is consistent not only with State objectives of encouraging development to be located in town centers, but with Readington’s own Master Plan and is “agreeable with the Township’s Environmental Resource Inventory by utilizing existing infrastructure and minimizing disturbance of natural resources”(2).
There are a number of positive attributes to the development in addition to the critically important affordable housing credits:
It will create an opportunity for seniors, families, and young professionals who couldn’t otherwise afford to live here.
Ground-floor units, typically attractive to seniors, will be wheelchair- and walker-accessible.
The development could bring economic support to Main Street businesses, which has been a recurring theme in local forums.
The developer has a solid reputation and track record for maintenance and upkeep of their properties, and will have an on-site property manager.
The units will be low-profile and attractively designed and landscaped.
The developer appears to show insensitivity to the community by using the name “Whitehouse Urban Renewal” on their application. We’ve learned that this is consistent with naming conventions requested by the State, and does not indicate that the developer is tone-deaf to Readington’s core values. In other dealings with the town we’ve heard and observed that they have a good understanding of the character of the town.
For decades the township has used foresight and planning to comply with the letter and the spirit of the affordable housing regulations. We’ve been protected from builders’ remedy lawsuits, a level of compliance achieved by only about 1 in 10 municipalities. This immunity expires on August 31st; the Township hopes to qualify for an additional extension.
CFR is opposed to some of the provisions in the State’s AH plan, and the setting of required AH units by parties who aren’t vested in the master plans in each municipality. We are not fans of PILOT (payment in lieu of taxes) programs. CFR would definitely like to see the Township Committee dedicate a reasonable portion of the PILOT funds to the school district to offset increased costs from additional children in the district. We don’t like the assumption that the northern sections of town will bear the brunt of future AH obligations.
Given the changes that additional affordable housing mandates will bring, Readington is going to see more higher-density development than we would like. We all need to urge the State Legislature to pass a better plan than the one the courts are left with. Still, AH needs will not go away, and we are left with the reality that significant deviation from our AH plan will trigger unpleasant penalties. Accordingly, CFR maintains its original position supporting the Nelson Street development.
(2) Environmental Impact Statement for Willows at Whitehouse Station, EcolSciences, Inc.