Response to COAH on regulations

[wcody]

It would be great if many citizens from Cranbury could send in comments to COAH on the proposed regulations. For your information, following is what I sent today.

You can send an email to coahmail@dca.state.nj.us

I did not realize this forum was out here, it is great that people in Cranbury are communicating online.

I will also post this on my blog http://cranburynj.blogspot.com where I had posted other information on COAH.





Dear Ms. Voorhoeve,

I want to express my concern over the round three proposed regulations for COAH and the impact on the town of Cranbury. While affordable housing is a worthy goal, the new regulations will have a devastating effect on Cranbury which has diligently worked to fulfill its housing obligations.

Cranbury has been working well with COAH to meet and stay ahead of its affordable housing obligations. However, the new regulations are extremely punitive and it seems that Cranbury is being especially punished. The new regulations could require a one to one ratio of affordable homes for each existing home in Cranbury. The burden on the township would be tremendous in terms of new taxes necessary to support the housing and supporting services. I am sure you are getting flooded with messages from Cranbury. We had a township meeting which overflowed the room with almost 300 people (about 25% of the adult population). I want to point out a few issues:

• Making the rules retroactively effective back to 2004 is completely unfair. There are major new obligations based on commercial property already built or in progress. Making changes based on previously built property does not give the town the opportunity to assess appropriate fees to developers for affordable housing.

• The revised warehouse calculations for number of employees are completely inaccurate. There are far fewer employees in the warehouses than assumed in your new square footage calculation. In fact, the original ratios are also high.

• I don’t understand why there is a need to double the affordable housing inventory in the state. This is especially confusing in this economy.

• New Jersey is already very crowded and we don’t need to double the housing stock in our town. Growth needs to be managed carefully and these rules make development out of control. Small towns are a benefit to the state and we don’t need to turn the entire state into one overcrowded suburb.

• There will be a negative impact with these changes. The new regulations would require a massive tax increase and change in schools. This will chase a lot of people out of the town (and state) and depress property values. The depressed property values will require higher tax rates and make the affordable housing tax burden even [/list]more expensive.

I appreciate your attention to these concerns and sincerely hope you review the proposed regulations and change the obligations so that they will be closer to the previous regulations.

Thank you,

Winthrop Cody
Cranbury

[Traveler]

Well said Winthrop. Here is the comment I submitted ...


I am a resident of Cranbury, NJ. I want to raise my concern over the COAH Third Round Rule that ultimately will have a direct negative impact on this wonderful community. On Monday, March 17 I attended a public meeting that drew approximately 300 residents. Also on hand were Assemblywoman Greenstein and Senator Baroni. Each person was there to express their concerns over the change in the COAH Third Round Rule.

As a common people, we as a community of upstanding tax paying citizens, have fully complied with the COAH First and Second Round Rule process. We were well on our way to complying with the COAH Third Round Rule until suddenly the rules of the game dramatically changed.

Cranbury strongly believes in it's moral commitment to allow for affordable housing. However, the number of units being proposed are totally unrealistic and the land on which to construct them is practically non-existent.

[late2meeting]

Did anyone get the actual figures that HomeDepot warehouse manager stated at the meeting, I came in late but was told by another resident about the first public comment. Please share the actual number of employees/sqft for both warehouses and also the info about VW warehouse as data points.

Thanks

[Guest]

I don't remember the exact square footage number, but he gave as an example one of the HD warehouses, which is about 1,000,000 sq. ft. Under the proposed rules (1.5 jobs per 1000 sq ft - is this right?), this warehouse would generate 1500 jobs. The actual number of employees at this warehouse is 55.

[radiculous]

[Guest]

Ms. Voorhoeve,

We are residents of Cranbury, NJ, and have recently heard about the proposed COAH 3rd round obligations.
Cranbury has always fulfilled (even exceeded) it's affordable housing obligations, but the changes in the 3rd round obligations will destroy our community.
The math behind the new obligations make no sense. For example, an approximately 1,000,000 Sq. Ft. Home Depot warehouse in Cranbury that is part of the obligation calculation is estimated to generate 1000 or more jobs according to your calculations. It actually has 55 employees. According to your rules, we must increase the population of Cranbury by about 50%, and pay for the building of these houses ourselves. This has nothing to do with "Not in my backyard" thinking... Affordable housing or not, we cannot support a population increase of 50%. It will destroy our schools and community. Cranbury has always used careful zoning and prudent financial decisions, while fulfilling affordable housing needs, to allow our town to remain a vibrant, successful community that is a recognized model of a great town.

Another problem is the retroactive nature of your new rules. We cannot recoup the fees from developers of already-built or already-approved projects, so the burden is on the taxpayers.

I cannot understand why your group is attempting to destroy one of New Jersey's most valuable assets. You talk about "moral responsibility", but your thoughtless actions will take away what we have worked so hard to create and maintain, not just for our benefit, but for the benefit of New Jersey, and the country as a whole. I can't think of anything more immoral than that.

[EdandNancy]

This is the warehouse data we wrote down from meeting, just wanted to validate and share :


==================
As my wife and I drive home from one of the largest town meetings in Cranbury history, I am leaving the meeting with deep despair. The “broad brush stroked” policy making approach to affordable housing rules from CoAH (round 3) will destroy my beloved and historic Cranbury, and I’d like to address some points to help correct the wide discrepancy.

As the meeting progressed from our 112yr old schoolhouse, overcrowded and standing room for most, we were told repeatedly by our local officials that no one knew exactly why the calculations were raised dramatically and what fact based data supported these affordability home growth rates that resulted in the recent rule changes. But the changes adversely affect Cranbury, and will force us to build 1 CoAH home for every 2 residents, and in the near future could change to 1 to 1 ratio.

But as we think about our current economic situation in NJ, our foreclosure rate at its highest in known history, and the amount of empty and vacant homes around the state – We have to ask the very simple and poignant question: Why Force Cranbury to Build More Houses? The plain facts do not support our new CoAH obligation nor the demand.

Just some quick local facts you may not know about our town. Cranbury has successfully planned a controlled growth and proactively addressed our affordable housing needs with great success. Our township plans are well documented, public and in town records on how we manage our finances, obligations and infrastructure. Cranbury’s town plans have had a consistent general growth strategy for many decades.

We are a model for smart growth and fiscal responsibility and partner with our neighboring towns to share infrastructure and costs. We share our high school with Princeton, our waste treatment service with S.Brunswick and our Courts with Plains borough so we can remain small and control our growth. But CoAH rule changes on warehouse sq/ft calculations and retroactive inclusion of growth from 2004 will derail all our past efforts and >50yrs of smart planning.

Cranbury has always proactively met our CoAH obligation and done an exceptional job in the last two rounds. We were even well on our way to address our 3rd round obligation ahead of schedule, until calculations were drastically changed in Jan 22, 2008. Its hard to justify building 469/950 additional houses in my small town when we have worked sooo hard to control our growth and protect our public and treasured resources.

The new rules calculations will force Cranbury to build 1 new CoAH home for every resident in the near future. We know of no other NJ town that has been forced to build so many homes and meet this ratio. Even the warehouse managers disputed the employee formulas that were used in the new 3rd round calculations, both Home Depot and VW both shared actual employee/sqft calculations that were a magnitude order difference. In one of the largest warehouses they had 55 employees .vs. what the new CoAH rules would calculate at 1100 (that’s 20 times lower then the formula calculates for growth for our largest two business) Every resident believes the growth formula is flawed and needs to be corrected to represent reality vs the inaccurate employee formula based on sq/foot.

It is also unfair, and in our opinion, violates the Fair Housing Act to apply harsh growth penalties on our township retroactively to 2004. You are asking our Cranbury taxpayers to fund 68mil in new construction costs for this subsidized housing. All without the possibility of retroactive fees from the original developers back in 2004. As a policy we would recommend we rehabilitate existing vacant homes in NJ and use foreclosures for this purpose as opposed to building new affordable housing in these worsening economic times in Cranbury.

To sum up, Cranbury’s proactive affordable housing planning and controlled growth is one of the key reasons for our good lifestyle and quality of life here. Its the reason our small town is soo desirable to live in, its the reason our schools are so highly ranked, our town is soo safe, and our cultural mix keeps growing at a modest pace. Please don’t force us to build more housing than what’s needed and that our infrastructure can not support. We hesitantly still support Cranbury’s voluntary co-operation with CoAH, and feel optimistic that you can address these inaccurate estimates of our town obligation. The next time you drive through our Cranbury, please envision how in 10yrs the current CoAH rules would forever ruin one of the unique small towns in NJ. Please join us in protecting this historic gem in NJ.

Nancy and I would appreciate your attention to these concerns and sincerely hope you review my input and propose change that would address the correct growth obligation for our Cranbury.

Ed and Nancy Kietlinski, 83 smain st.

[wcody]

All the emails being sent are great.

I am very impressed that someone at COAH is reading and responding to these personally. A couple of people have already received responses from emails sent yesterday.

Keep the emails going!

[Guest]

[FL]

I think Cranbury should join Princeton to lead the fight against this nonsense COAH. All this COAH stuff is based on socialist idea and against free market system. I would think over 70% of municipalities in new jersey are not happy with this crap. The case should not be stopped in trenton, which is one of the most corrupt state governments in the nation.

http://www.nj.com/news/times/index.ssf?/base/news-4/120529476985730.xml&coll=5

[Guest]

No argument that COAH's current proposal is lame. That said, opting out of it should be a very last resort given the history of those who have before.

Consider that Cranbury requested the courts to let them opt in to COAH because the alternative was proving much worse in terms of forced affordable housing requirements. And then there is West Windsor who decided to fight them and the builder (in this case Toll Brothers). On the plus side, they delayed the project about 15 years. But in the end it cost them a fortune to fight it and in the end the NJ Supreme Court ruled in favor of the builder. In the end, Toll got to build over 1,100 units in a swamp. And because they fought them, Toll didn't have to give any on the concessions builders typically do so now West Windsor is having to spend even more expanding roads, updating utilities, expanding schools, etc.

[Guest]

Yes, but even with the COAH rules Toll would have still built the 1100 homes. The issue with Toll was not COAH, but the 1100 homes they wanted to build that WW did not want to allow. That lawsuit would have happened regardless. The only difference I can see is that WW did not get a builder concession for the COAH liability and they spent money on the lawsuit.

The builders lobby is powerful and our courts are done with political appointees. So it is no surprise Toll won.

[Guest]

if these new third run rules goes through, west windsor has to build more affordable housing since a lot of toll homes were built after 2004. it would be interesting to hear their reactions too.

[Guest]

Although his NY Times article about "smart growth" in our neigboring Wahsington Township is one year old, it clearly tells you that you will certainly get screwed if you believe in trenton beureacracy.

http://www.nytimes.com/2007/04/09/nyregion/09smart.html?_r=1&oref=slogin

[Guest]

[Guest]

"Builders Remedy - the builder's remedy allows a developer to exceed local density limits if it can show that the municipality has fallen short of its Mount Laurel obligations and the proposed development sets aside at least fifteen percent of the units for affordable housing. "

So, If COAH wants Cranbury to retroactively build 469 low-moderate income houses for approx 68 million (which by the way Cranbury must pay). I hate to say - Builders remedy doesn't seem so bad.

By adding the homes COAH wants us to have - we will have to expand our school, roads, sewer obligations, etc. ALL of which is the at the expense of the Cranbury tax payers. We are talking about a 1:3 residential retroactive ratio and will probably change to 1:1 residential ratio for future obligations.

Now call me crazy, but doesn't it seem that if we opt out of COAH and a builder comes in to build the single family homes and also some low income homes we will have the same number of homes? So, the ratio will be where it is now and the costs will be on the builder rather than us taxpayers.