Franklin Twp Plans Redevelopment Zone – Letter to the Editor (Gloucester County)

An Open Letter to Members of the Franklin Township (Gloucester County) Planning Board and Franklin Township Committee Concerning the Planned Redevelopment ZoneDear Members of the Planning Board and Township Committee,

The Planning Board is currently considering whether to endorse a study, undertaken at the direction of the Township Committee, which calls for a ‘Redevelopment Zone’ (RZ) to be created at the Malaga Route 55 interchange. This RZ has the potential to create a vast area of commercial and/or industrial development on 380 acres in the heart of Franklin Township, most of which is now forest.

(The reader is free to imagine nearly 400 acres of pavement, massive buildings, bright lights shining at all hours, etc., surrounding one on all sides upon exiting Route 55 or driving into Malaga on Route 40 east, in place of the current forest which seamlessly blends into the area surrounding Malaga Lake. This could include, for instance, multi-story warehousing. Nothing in the current RZ Study precludes this kind of out-of-place, character-destroying commercial/industrial development.)We recognize that elected officials face continuous pressure to lower property taxes, and that the RZ Study represents an attempt by the elected officials of our township to explore a potential avenue in this regard.

Nonetheless, we urge the Planning Board not to recommend the adoption of the findings of this study. Particularly, we agree with Planning Board member Ralph Travaglione in his suggestion that the matter must be considered in conjunction with the new Master Plan, which should be adopted by the township in 2023.The proposed RZ represents a generation-defining choice by the Township. If undertaken in its present form, the RZ has the potential to permanently change the character, complexion, and way of life of our – up to present – rural community. It seems common sense that such a far-reaching decision as the creation of a massive, 380 acre commercial/industrial zone in the heart of our township should be undertaken as part of a public, open, and lengthy process, with sustained input from all stakeholders, which will define the direction of our community for the next generation – i.e. the required formulation of our new Master Plan.

In addition to the approaching redrafting of the Master Plan, there are several salient reasons for Planning Board and Township Committee Members to oppose the adoption of the RZ Study and/or the RZ itself at the present time and in its present form.

These include: • Water and Sewer – The RZ will almost certainly necessitate bringing water and sewer into Franklin Township. It is well known that the primary reason our community has not seen the kind of development witnessed in other areas of South Jersey is due to our lack of these utilities. Once they are brought in – a step which cannot be taken back – there will be enormous pressure going forward to expand them, as developers push for the extension of the utility to new areas of our township to facilitate their own project. • Development as Township Policy – Several members of the Planning Board made statements at the meeting such that ‘this is only a study or a plan, nothing is being developed yet.’

While this is true, once the RZ is adopted, it will be a stated Township policy to… develop the area in question. Thus, concerned citizens who do not wish to see development could then be told, for instance at Planning Board application hearings, ‘well, the town has adopted as a policy that this area be developed.’ In other words, what is being sold to us now as ‘merely a plan,’ ‘nothing to worry about/concrete yet,’ etc., will soon, by the logic of the process, develop into an ironclad reason to develop the 380 acres of mostly-forest. • But It’s Already Zoned Highway Interchange Commercial – Similarly, Planning Board Member Jim Kelly stated that the kind of commercial/industrial development many fear ‘could happen now at anytime,’ because the area is already zoned Highway Interchange Commercial. Mr. Kelly is being honest – in a legal sense, this is true. However, this reasoning ignores the fact that numerous issues have so far precluded such development, including the presence of wetlands, the lack of roads ingressing the property, and the lack of utilities.

As Joe Arsenault stated during the public portion of the December Planning Board meeting – in all likelihood, if this kind of development was going to take place, it already would have. What is happening here, rather, is that the township will be deciding to ensure, as a matter of public policy, that it does take place in some form. Oppositely, the area could be rezoned, and protected, as part of the new Master Plan. • Groundwater Re-Charge – Groundwater recharge is a salient issue for our community due to the use of well-water for all current water utilities. The site in question has one of the highest, if not the highest, rate of ground-water recharge in our entire township.

Developing it could have a serious, negative impact on the quality and availability of drinking water in Franklin Township. • Environmentally Sensitive Area – The natural heritage of our town is a core aspect of our community’s rural character and complexion. In this respect it has real economic and social value, and ought to be safeguarded by our elected officials. Furthermore, this protection should be proactive – it should not be left to the State DEP to demarcate the bare-minimum of legally-required protections.

The township should go above and beyond these requirements and preserve environmentally sensitive areas for future generations. This unbroken area of forest, containing both highlands and wetlands traversed by two running streams and near a large aquatic habitat (Malaga Lake), represents a complete ecological zone which should be preserved in its entirety.

Moreover, the area contains endangered species and, with how weird the weather has been, maybe it’s about time we all started taking climate change a bit more seriously, and left the trees alone… not to mention their role in air quality, which in our town still remains excellent because of our high percentage of tree cover. • Lack of Public Support – During the public hearing on the RZ Study, no member of the public spoke in support of the planned RZ. If there was a significant constituency in the town demanding tax relief by these means, surely at least one person would have attended the meeting.

On the contrary, the meeting was attended by many dozens of people in clear opposition to the plan on a number of grounds, including quality of life, the rural character of our community, and the negative environmental impact of the planned development. • Perception and Real Value – At face value, imagine the difference in the basic, visceral, everyday perception of our town, by ourselves and outsiders, if one is confronted, traveling along or exiting RT 55 or entering Malaga from RT 40, by acres of warehouses, pavement, and (at night) horrible bright lights instead of forest. Taking everything into consideration, including the potential tax revenue that may be derived from development, we believe the highest value this site has to our residents and their way of life is – in its present, natural state.For these reasons we urge our Planning Board and Township Committee to reject the Redevelopment Zone. If there is to be a RZ, it should be decided on and undertaken within the context of the upcoming Master Plan, and contain significant guarantees for the preservation of the rural character of, and mitigation of environmental and quality-of-life impacts on, our town.

Respectfully,Frank B. Scavelli and Frank M Scavelli 3013 Dutch Mill Road, Franklin Township, NJ

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