I wish to offer the following comments with respect to the Office of Smart Growth (OSG) response to Policy Issues raised by Counties:
Re: Critical Environmental Sites
p. 79 – Issue #1 – Mercer County recommends that the designation of Critical Environmental Sites (CES) be much more inclusive, and specifically recommends the following categories (among others): groundwater recharge areas, wellhead protection areas, and critical sub-watersheds (e.g., designated C1 streams, HUC 14 subwatershed level). In response, the OSG appears to agree and indicates its intention to identify all CES through analysis of reasonably available information. I support the recommendation offered by Mercer County and wish to underscore the importance of designation of these key and sensitive water resource protection areas, both for protection of the health of our citizens and the natural environment. In particular, information on recharge areas, wellhead protection areas, and critical areas of C-1 watersheds is readily available, having been developed by NJ Department of Environmental Protection in a statewide effort precisely designed to define those sensitive areas for the very purpose of protection.
p. 79 – Issue #2 – Gloucester County recommends that the State Plan recognize the importance of wellhead protection areas, delineate these areas on the State Preliminary Plan Maps, refer to NJDEP’s source water assessments, and determine an appropriate categorization. I entirely support the comments raised by Gloucester County, and suggest that an appropriate category for wellhead protection areas would be CES. (See Issue #1, above.) In reply, the OSG states that it is beyond the scope of the State Plan map to depict wellhead protection areas. The basis for this statement is unclear; rather, it would seem that identification of critical important water resource protection areas is exactly appropriate for the State Plan map. While it is true that mapping of wellhead protection areas alone does not accomplish protection, the same logic could be applied to any CES (for example, wetlands). However, indicating the location of wellhead protection areas is a fundamental step in enabling protection. While the maps and digital data are readily available from NJDEP/NJGS (and their web site), it is very possible that local government officials and professionals would not understand what wellhead protection areas (and significant recharge areas) are or even that the information is accessible. The OSG could provide a most significant service to local governments who must make critical planning decisions regarding land use, open space, commercial centers, redevelopment areas, stormwater management, transportation, etc., perhaps without appreciating potential implications for water resources—especially the hidden ground water sources of drinking water.
The OSG response goes on to recognize that protection will be accomplished through local and Statewide actions, and points out that the Plan Endorsement Process will require identification of wellheads, well recharge areas and implementation of protection programs based upon available mapping data. (The OSG response to Issue #3 on page 60 also states that municipalities will be required to implement stream corridor protection and wellhead protection programs.) I wholeheartedly support such requirements, and further suggest that OSG and NJDEP establish threshold criteria for acceptability of source water protection programs, including wellhead protection programs.
I respectfully request that the OSG reconsider its position on this matter, and recommend that:
Thank you for the opportunity to provide comment.
Victoria P. Binetti
50 Berkshire Drive
Sewell, NJ 08080
856-228-4458