Thank you for the opportunity to
offer additional comments in regard to the SDRP and the Cross Acceptance
discussions now underway. I offer
the following points for your consideration:
Structure
Reconcilitation Statement – There
needs to be a statement of reconciliation between the various state agencies and
OSG acknowledging that the planning function should and will drive the
regulations that exist or will be proposed. Where there needs to be greater clarity
and flexibility the rules should be modified to be consistent with the adopted
SDRP. Additionally, heavy emphasis
must be given the need for expeditious action on applications to the state
agencies. Delays in the process add
tremendous costs to both development and preservation, all of which are borne by
the taxpayers of the state.
#2. This is more a
matter of economics and available public moneys to subsidize service. Densities are a surrogate for adequate
demand.
#10. Municipal plans, particularly those
having received designation or endorsement must be made part of any regional
plan.
#14. From a practical persepective, existing designated centers, if they have
followed the PIA or other agreements, should be able to use an update process
rather than a full scale PE application to retain their
designation.
Public
Investment Priorities
#3. The SDRP should
acknowledge that there are serious tax related impediments to proper land use
planning. As NJ Future notes, a
statewide property tax may e an alternative to the local property tax that would
eliminate the competition for rateables. Alternatively, regional tax sharing (as
in the Meadowlands) might also provide a disincentive to municipal competition
for rateables.
Both would also avoid the avoidance of housing and the consequent bias
against children that is funding based. (See also Infrastructure Investments
#4)
Critical
Environmental Sites
#16. We recommend
that language making this point clear be added to the SDRP.
#20. Strongly agree with both the comment and
response.
Eric K. Snyder
Sussex County