APA-NJ Testimony: Draft State Strategic Plan

Below is the full testimony of APA-NJ in response to the draft State Strategic Plan.  

  1. We are delighted that the Administration has chosen to breathe new life into the state planning process. Recognizing that there are no easy solutions we appreciate the Administration’s willingness to take this on.
  2. Still a Plan for a Plan.  As we stated back in October, this strategy is a good start to a plan. It’s a Plan for a Plan if you will. APA-NJ, the State’s only professional organization of planning practitioners, is poised to work with you to finally adopt an updated and functional State Plan for New Jersey.  However, we believe that this State Strategic Plan is too focused on economic development goals to effectively meet the broad statutory mandates of the State Planning Act, and therefore it would be premature to adopt such a plan at this time.  Instead, we would like to offer some thoughts to help guide you through the statutorily mandated public proceedings and your efforts to align state funding resources over the next year or two.
  3. Public Process and Access to Information:  This State Strategic Plan has not received nearly the level of local review envisioned by the cross-acceptance process – a process that is still mandated by the State Planning Act.  Because the changes from the Draft State Plan to today’s State Strategic Plan have been drastic, it is all the more essential that it receives this high level of public scrutiny.    Plus, since the Office for Planning Advocacy announced its new State Strategic Planning process in early 2011, they have provided little to no information on the actual planning process – input received, summary work products, comment opportunities – nor is it contained within the draft State Strategic Plan.

    This lack of public information is troubling, given the significant structural changes being proposed for state planning, particularly the framework for identifying priority growth and investment areas.  As such, we view this current series of public meetings as an opportunity to comment not only on the draft State Strategic Plan but also on some of the more comprehensive planning issues that it overlooks – issues that will help to make this state truly sustainable for future generations.

  4. Suggestions.   APA-NJ will provide more specific written comments on the content of the Plan.  But we would like to share some general suggestions with you today.
    1. Educating and Engaging the Public through Regional Entities.   There needs to be more of a focus on educating property owners and municipalities so they can make more informed land use decisions and understand the opportunities that planning in a more regional context can provide.  Use the counties, regional planning partnerships and other regional entities to both enhance your outreach efforts to the public and achieve the vertical integration you seek with this plan.  Counties played a central role in the cross acceptance of prior state plans and are well-positioned to continue to do so.
    2. Growth Area Criteria.   This draft plan replaces the current Planning Area framework for designating growth and preservation areas with a new system of Priority Growth Investment Areas and Priority Preservation Investment Areas.   Thank you for releasing the designation criteria to the public on February 10, in advance of these meetings.  Considering the tremendous impact that such designations could have, especially if the state agencies are truly successful at aligning their resources to support these areas, it is essential that the public and numerous stakeholders have the opportunity to provide input. 

      One option to consider before adopting statewide criteria is to institute 10 to 12 pilot projects in the areas we can all agree that the state should incentivize growth now. (For example, the hundreds of acres of prime waterfront parking lots in Trenton). To do this:

      1. Reconvene the State’s Interagency Team to work with these communities
      2. Identify the regulatory and programmatic changes that would be necessary to attract desirable development projects to those sites but that are consistent with the policies of the current State Plan.
      3. Make those changes!
  5. Generate the capital resources to implement the Plan. It’s not simply that we live within our means of the day and the current economic crisis, but that we have a forward looking plan with the necessary capital resources to back it up. There are lots of public-private partnerships and other innovative sources of financing that we ought to be exploring to ensure that the needs of the plan are met and not provide fodder for discussion at these meetings. 

    Now our comments will shift to a more basic challenge facing the state and land use decision-making

    Property Taxes
    We have had a State Planning Act since 1985 and a State Plan since 1992.  However, our growth areas haven’t behaved like growth areas.  Since the State Planning Act was adopted, through 2007, 41% of newly-developed land was low density growth outside of smart growth areas and another 15% was low-density residential development within smart growth areas.  (Hasse and Lathrop, 2010).

    We can rattle off a number of reasons for why this is the case.  Home rule.  Inadequate leadership from the state and lack of incentives to accept new growth.  Resistance to change.  Traffic impacts.  We’ve made progress on how to head off many of these issues.  But until New Jersey figures out how to reduce its reliance on property taxes, local development decisions will continue to be driven by short-term financial interests. 

    The negative impacts of our property tax system are well-documented.  We live in a state where attracting tax ratables is more important than building quality communities.  Where school-aged children have become a negative indicator for a new development.  You can’t blame municipal leaders or developers for working within the system.  But the system is broken and until we, as citizens of this state, confront the problem, we will be compelled to repeat the fiscally irresponsible development decisions of the past. 

    Utilizing this public process to build strong property tax reform recommendations could have the dual impact of enabling more successful regional and state-level planning efforts and alleviating the economic and quality of life burdens our residents face.  End the ratable chase now.


  6. What happened to affordable housing?   The 1985 State Planning Act was clearly intended by the New Jersey Legislature to provide a statewide planning framework to facilitate implementation of the New Jersey Fair Housing Act. The current Draft Strategic Plan is silent on the constitutional issue of affordable housing. The need to re-engage housing in a meaningful way is apparent as housing costs drives economic competitiveness.

In its simplest form, planning and this State Plan are supposed to be about making sure that New Jersey can leverage all of its resources to give its residents the widest possible opportunities for where to live, work and play. We have to cut through the red tape of the “process” and open doors to possibilities. Make no mistake, we are not talking about abandoning the environmental stewardship about which we are all proud and on which we depend.  However, in our efforts to provide fair housing opportunities and environmental protection, we need to be sure we don’t regulate ourselves into gridlock.

Thank you for your consideration.