Thank you for the opportunity to provide commentary on the Draft Highlands Regional Master plan. (RMP)

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1 Mayor Michael Obremski Deputy Mayor Trina Ruane Mitsch Council Members Gary C. Algeier Jay Alpert Edward A. Metz Allen M. Napoliello Arlene R. Price Township Manager John C. Lovell Township Clerk Donna Marie Luciani Telephone (973) FAX (973) Millbrook Avenue Randolph, N.J May 1, 2007 Tom Borden, Deputy Director New Jersey Highlands Council 100 North Road Chester, NJ rn ~ O\!l ~~I "r MAY W ('~:-~~?it7 Re: Draft Highlands Regional Master Plan (RMP) Dear Mr. Borden, Thank you for the opportunity to provide commentary on the Draft Highlands Regional Master plan. (RMP) Morris County Planning Director Raymond Zabihach provided a March 27, 2007 letter addressed to you outlining preliminary comments on behalf of the Morris County Department of Planning, Development and Technology. This document was shared with members ofthe Randolph Township Council for review. Randolph supports and subscribes to the commentary provided by Mr. Zabihach. To that end, the March 27 letter is attached and should be considered a part of the Randolph TO\\oTIshipcommentary on the Draft Highlands Regional master Plan. The Township worked extensively with Morris County in the formulation of the State Development and Redevelopment Map/Cross Acceptance initiative. We believe that the resulting map and designations are sensible for the community. Randolph is concerned that the State Development and Redevelopment map has been brushed aside and summarily dismissed by Highlands staff and consultants. The data utilized by Morris County and Randolph, combined with local knowledge of properties, would seem to make the State Development and Redevelopment map a high value document in the promulgation of a workable RMP in the Planning Area. We ask that you and your staff review the "state map" for guidance on the following issues".

2 PRESERVAnON AREA CONCERNS The portion of Randolph Township falling within the Preservation Area is, for the most part, comprised of publicly held open space. To the best of our knowledge, all other lots included in the Preservation Area are developed with residential structures, with the exception of several commercial sites in proximity to the intersection of Park Avenue and Righter Road included in the Planned Community Zone/Specially Planned Area. The second Planned Community Zone/Specially Planned Area, at the intersection of Park and Pleasant Hill Road, is fully developed with most all housing stock in reasonably good to excellent condition. It would appear that neither Randolph Township nor the Highlands will benefit from any rigorous study of Randolph's Preservation Area. Randolph's local zoning standards for septic development preclude the creation of additional development sites. Why not allow the Township to simply adopt by reference the Highlands zone designation and associated conditions? Simply stated, we perceive little value in engaging in a costly and time consuming effort to implement Master Plan amendments and zoning changes. Again, this realization stems from the fact that all lands are either publicly owned for the protection of the Allamatong Well fields or developed at this time. PLANNING AREA CONCERNS Randolph Township has entered a transition period in its evolution. Not too long ago, the Town experienced a period of rapid development, coupled with an aggressive open space preservation program. The combination of these two factors has left the Township with limited opportunities for future growth. All areas that are proposed for accommodating future development are located within the "Planning Area" as designated in the draft RMP. I have enclosed a map, which overlays the Highlands Land Use Capability map on top of the Township's tax map. When comparing the proposed Protection Zone with actual development, one must question whether the Opt-In initiative makes sense for Randolph, as the mapping data is, at best, contradictory with many fully developed sections of the community contained in the Protection Zone. The Highlands Council's desire to limit the Planning Area to three zone designations is far too confining. Recognizing that the Highlands Council based much of its mapping on the proximity of streams and wetlands, why not embrace an expansion of the Planned Community Zone/Specially Planned areas with companion zoning entitled "Planned Community Zone/Critical Environmental Sites" (lifted from the State Development/Redevelopment Plan)? Several sections of Randolph Township incorporated into the Protection Zone cause immediate alarm as touched upon below:

3 Mt. Freedom Area The area to the west of Brookside Road and north of Woodlawn Avenue is comprised of an abandoned bungalow colony. An approval exists for the re-development of this site. As a condition of approval, the developer is required to provide and share in the cost of significant upgrades to a'sewer system interceptor, critical to the protection of the Whippany Watershed. The Protection Zone designation for this particular area is seemingly senseless and undermines an improvement critical to the long term protection of the environment. Northeast Comer The area north of Rte. 10, east of South Salem Street and bounded by the Denville and Rockaway Township borders is included within the Protection Zone. The area is developed with several older industrial and commercial uses constrained by wetlands and Rockaway River flood hazard areas. The lack of available information with regards to Protection Zone development standards is a cause for concern. This area has several sites that will eventually require redevelopment initiatives. The connotation of a "Protection Zone" leads me to assume that re-use of these sites will be unachievable. Again the need to create additional designations, in this case Planned Community Zone/Critical Environmental Site, is needed to promote the eventual re-use of this section. Rte. 10 Corridor The Protection Zone located south of Rte.10, west of Dover Chester Road, and north of Morris Turnpike, eliminates one of the only remaining areas for future development in Randolph's Planning Area. The land is adjacent to a state highway and enjoys access to both public water and sewer. It is surprising that this opportunity site would not be perceived as a reasonable area for the Planned Community Development designation especially in light of the Highlands' staff commentary to the effect that a balance will be achieved between preservation and future development. Local Government Facilities On Millbrook Avenue, the Municipal Complex has been split by the Protection Zone and Planned Community Zone/Specially Planned Area. The Municipal Complex is located on tax block 119, lot 119. In the last five years, the Township acquired adjacent lots 121 and 122 for the purposes of meeting Randolph's future municipal facility needs. Similarly, the Public Works Complex on Sussex Turnpike, tax block 86 and lots 72.02, 72.03, 73, 74 and 75 has been split between Protection and Planned Community Zones. Much ofthe site falls in the Protection Zone, which will cripple the Township in meeting its future needs. The site is bisected by a NJ Central Power and Light Company right-of-way. Randolph's public works, water & sewer operations, municipal

4 -_u fleet/school fleet maintenance and storage, and animal shelter, as well as a significant recycling center serving the community are all located on site. The Town needs to implement upgrades in the future to meet the new storm water standards and provide an efficient work environment to achieve Randolph's service needs. It is believed that the proposed Highlands designation will delay and possibly eliminate much needed improvements. COAH The conflicts between COAH mandates and the objectives of the Highlands Council must be addressed in a concise and thorough fashion. The state of New Jersey can not have it both ways at the expense of municipal zoning. Randolph is perplexed and frustrated by the Highlands Council's lack ofleadership on this critical issue. Where is the coordination of effort? Can relief from COAH obligations be created as an incentive to protect water resources for much of the state's population? Is there any attempt to move on legislation addressing some realistic balance on this issue? The RMP could serve as a platform for initiating decisive steps to address conflicts. It is not unreasonable to believe that the recent COAH decision upholding the "Builder's Remedy" and mandating assignments of municipal fair share quotas is in stark contradiction to the Highlands proposed "green" zoning. Until such time that the RMP and COAH initiatives are synchronized, the RMP is diminished and can not provide the intended protections. In closing, I again thank you for the opportunity to comment. ReSpeC fu lly ubmitted, Enclosures: 1- Highlands Land Use Capability Map - Randolph 2 - Raymond Zabihach, march 27, 2007 "~Ih. c.c.: Senator Anthony Bucco Assemblyman Richard Merkt Assemblyman Michael Carroll Randolph Mayor and Township Council Darren Carney, Randolph Planning and Zoning Administrator Raritan Highlands Compact Raymond Zabihach, Morris County Planning Director Tina Bologna, Executive Director, Raritan Highlands Compact?!}. / -.\...llnc. Lov I.andolphTownship Manager

5 Corresponding Documents in Admin. Area