The Enclave at Holmdel – CILU Statement for Zoning Board

Good evening. Karen Strickland, co-president of Citizens for Informed Land Use, speaking on behalf of the CILU Board.

At the last Zoning Board public hearing, it was noted that the time for comments was limited. The CILU statement which was intended to be read into the record in its entirety is being completed this evening.

CILU is concerned about the long term risks associated with an approval for the Enclave development due to inconsistencies with Holmdel's Master Plan, noncompliance with Holmdel's existing Zoning ordinances, negative impacts from increased impervious surfaces, massive movement of soil, and increased downstream flooding. The approval of a use variance tonight could establish a precedent for future use variances and the incentive to introduce sewers into a Planning Area 5, which is considered to be the most environmentally sensitive land by the state of New Jersey.

For the following reasons, CILU urges the Board to deny this Zoning Variance.

First, the proposed Enclave development will increase impervious surfaces and storm water runoff, which will undoubtedly cause more severe flooding This land is at the headwaters of the Waackaack /Mahoras stream system, a system which already has contributed to continuous and increasing flooding in the Middle Road and Palmer Road areas of Holmdel. Current flooding downstream is already a crisis. As the owner of 280 Middle Road testified, the Waackaack/Mahoras stream on his property is 10-feet-wide and is totally clogged. His property is increasingly compromised by flooding. Holmdel has received similar flooding complaints from Palmer Square, The Orchards, and Fox Chase developments.

Holmdel has allocated over $350,000 to study storm water management throughout the town and will undoubtedly spend more to mitigate flooding downstream. It makes no sense for the Board to approve a development that will exacerbate a problem that the town is spending a large amount of money to correct.

Moreover, the impervious coverage proposed by the applicant is 21.94%, while the maximum allowed is only 15%. The applicant’s analysis of proposed coverage does not include internal roadways as impervious. These areas are claimed as pervious because the applicant is using pervious pavers, but the pavers will eventually degrade with constant daily vehicle movements of laundry, food and refuse to and from the buildings and subsequently will become impervious areas, thereby making the 21.94% analysis incorrect.

In addition, the development requires significant resculpting of the site. The resulting massive soil movement and compaction of the soil will impair the natural groundwater recharge and exacerbate stormwater runoff and flooding. This small version of “a mountain top removal” of 22,000 cubic yards of cut and fill to level the top of the hill will rearrange a 12.6-acre area of disturbance of the total 18.55 acres, resculpting approximately two-thirds of the property.

The new “Green” DEP Stormwater rules only require stormwater runoff to be decreased by 20% of the current farm runoff. That run off is calculated according to NJDEP rules using 1999 precipitation levels. According to a NJDEP study, by 2020 NJ had already experienced 1/3 of the anticipated precipitation increase for the entire century. Though the development is designed to accommodate the remaining 80% of what is calculated to be currently running off the property, the design is not sufficient to handle all stormwater that will be generated with ever increasing storms. While the applicant is not required to anticipate DEP's prediction of ever-increasing storms over the next 20-30 years, we all know that they will happen. Climate change is inevitable. Last year, in a 24-hour period, Hurricane Ida dropped more than 9” on northern NJ, in some places at a rate of two to three inches per hour.

Contrary to the new Green Stormwater regulations, the applicant’s Infiltration Basins/Rain Gardens are located on the edge of the site rather than distributed throughout the property every 2 ½ acres. In a heavy storm event, CILU maintains that water will by-pass the structural components of the storm water system and run through designed and constructed spillways in sheet flow to Van Schoick culverts. This will dump the stormwater directly into the Mahoras Brook, thereby causing flooding, eroding steep slopes and depositing pollutants.

CILU’s second objection to the approval of the use variance is that the granting of a variance that is inconsistent with our Master Plan and Zoning Ordinances will set a precedent to disregard the standards to protect the environment. Every exemption to our Zoning Ordinances and Master Plan facilitates further land use degradation and negative consequences.

Sewering an unsewered area will set a precedent for future high-density development. What happened at Bell Works should be a reminder of what could happen in the future. The exemption granted to allow one sewer pipe to process Bell Labs Clean room chemicals now supports 225 residences on land that was originally set aside as permanent open space to compensate for the intense use of the 6 story 2,000,000 square-foot building.

The R40-B zone that applies to Potter's Farm was designed to handle single family housing in an environmentally sensitive area. If these 18 acres were a cluster development of seven single family homes using septics, with 15% maximum impervious coverage, as allowed now in the R-40B zone, the wastewater produced would not be discharged to the Atlantic Ocean but instead serve to recharge the groundwater. Note, the average 5000 square foot footprint of each of the 15 proposed Center buildings is more than twice the footprint of a large Holmdel home. The excessive footprint of the proposed Enclave buildings and the concentrated impervious coverage will contribute to the loss of natural groundwater recharge and downstream flooding.

While the financial feasibility of the applicant’s project is not CILU’s concern, if the project were to fail financially, which is certainly a possibility during times of economic uncertainty, Holmdel would be left with a sewered 18 acres at the intersection of Exit 114 of the Garden State which could accommodate potentially unlimited development.

There is a reasonable expectation from neighbors that Holmdel's zoning would be immutable. CILU maintains that the imperiled Waackaack/Mahoras watershed must be protected with a vote that recognizes the environmental implications. Other sites exist in Holmdel that are more suitable for this development, which was originally designed for urban areas in the Netherlands. These other sites have services already zoned for this use, such as RT35H zone, and would not require variances.

In sum, CILU urges the Zoning Board to deny the current application in order to protect the imperiled Waackaack/Mahoras watershed and adhere to the vision of Holmdel's Master Plan.

Read by Karen Strickland on September 21, 2022.