Great Swamp association urges public to oppose Harding condos at DEP virtual hearing, March 9

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Morristown Green Contributor
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From the Great Swamp Watershed Association:

The Great Swamp Watershed Association is urging the public to voice its concerns about a proposed Harding condo development, at a March 9, 2023, virtual hearing organized by the state Department of Environmental Protection.

The proposed project is in Harding, but would be accessed via an office park in Morris Township.

The online hearing runs from 2 pm to 4 pm. Access details are here.

Here is more about the association’s concerns. (A video replay of the nonprofit’s informational session can be viewed here.)

From the Great Swamp Watershed Association:

CONDO Development Plan may significantly DEGRADE
our GREAT SWAMP WATERSHED Conservation Management Area.

The proposed S/K Mt. Kemble development plan is for a 96-unit residential, multi-family condominium complex including affordable housing with a community clubhouse, playground, pool, and dog park.

This 15.5-acre, triangular shaped, forested parcel flanks Route 287 on one side and the Mt. Kemble office complex on another side. The third side bumps up against wetlands which connect to GSWA’s 73-acre Conservation Management Area (CMA) under Route 287.

Converting woods to pavement and rooftops significantly increases impervious surface cover. This increases stormwater volume, likely resulting in downstream flooding, added nonpoint pollutant loading, and erosion of both Silver Brook and Great Brook.

GSWA strongly opposes this proposed development* and we are deeply concerned about the environmental impact we anticipate on our freshwater wetlands, water quality, recharge, and stormwater.

Following are some of our major concerns:

Encroachments into freshwater wetlands, encroachments into and alteration of the wetland transition areas (buffers). In some cases, these wetland encroachments would necessitate importing large amounts of fill that would be needed to re-contour buffer areas or will be covered by impervious surfaces.

Significant increases in pollutant loading to Silver Brook due to the fact that the portion of the site proposed for development is currently fully wooded. We would also expect measurable increases in sediment, phosphorus, nitrogen, and salt loading to Silver Brook.

Potential lack of recharge of any of the site’s post-development runoff. This will result in increased flood volume hitting the Silver Brook and a reduction in base-flow during fair weather as this runoff rushes away from impervious surfaces and is no longer absorbed.

Changes to the Northeast Water Quality Management plan map of sewerage coverage to include the development, creating significant additional effluent discharge, through the Woodland Wastewater Treatment Plant, into Loantaka Brook, adding additional nutrients to this already impaired tributary of the Passaic River.

Potential significant long-term hydrologic alterations of this headwater stream and the adjacent riparian floodplain areas and wetlands.

Possible impact to threatened and endangered species such as wood turtle and Indiana bat.

In response to GSWA’s opposition and a barrage of public comments and requests, the NJ Department of Environmental Protection (NJDEP) has scheduled a virtual public hearing on March 9 to consider amending the Northeast water quality management plan.

Craft your comments:

Submit your written comments to NJDEP no later than March 23 regarding the proposed 96-unit development in Harding (known as KRE Harding Residential or S/K Mt Kemble). The subject line of all submissions must include the following: Program Interest No. 435442, Activity No. AMD200007

  • Include your name, address, and contact information including your email address
  • Subject line for email or letter must include: Program Interest No. 435442, Activity No. AMD200007
  • Opening of the letter should reference that “comments are pertaining to NJDEPs Proposed Amendment to the Northeast Water Quality Management Plan”
  • Comments should focus on environmental issues related to the addition of 9.3 acres to the Sewer Service area map (served by Woodland Wastewater Treatment plant)
    • Ideally comments will focus on two to three of the points referenced by the experts in our informational webinar and summarized in the list below. Watch GSWA’s February 23 informational webinar replay.
    • NJDEP will NOT give weight to comments that are COPIED (or CUT and PASTE.) Please put comments in your own words. You may use our Environmental Issues list (*scroll down to view) as a starting point.
  • View GSWA’s February 23 informational webinar PowerPoint presentation
  • Comments should refer to the proposed change in the Northeast Water Quality Management Plan as needed due to the addition of the development property to the Sewer Service Area
  • Comments should NOT refer to non-environmental issues such as noise, lights, traffic, or low-income housing
  • Please conclude your comments by stating your preferred outcome to the proposed amendment

Submit your comments (via Email or US Mail):

Email to: wqmp.publiccomments@dep.nj.gov

  • Email subject must say: Program Interest No. 435442, Activity No. AMD200007
  • Must be sent by March 23, 2023
  • Share your submission with GSWA (**see below)

US Mail:

  • The top of the letter must note: Program Interest No. 435442, Activity No. AMD200007
  • Must be postmarked by March 23, 2023
  • Share your submission with GSWA (**see below)
  • Address the envelope exactly as shown here:

New Jersey Department of Environmental Protection
Division of Watershed Protection & Restoration
Bureau of NJPDES Stormwater Permitting & Water Quality Management Planning Program
PO Box 420, Mail Code 501-02A
501 East State Street Trenton, New Jersey 08625-0420

**If you would also like to share your submission with GSWA, on your email to NJDEP, please copy: SRubin@GreatSwamp.org (or) if commenting via US mail, send a copy of your letter to: GSWA, P.O. Box 300, New Vernon, NJ 07976, Attn: Sally Rubin

*Environmental Issues as related to the proposed KRE Harding Residential Development

    • Proposed Mt Kemble development would be located in a water deficit area as delineated in the Highlands Regional Master Plan
    • Water supplied to the proposed development will be withdrawn from a sub watershed (HUC14 – Great Brook above Green Village Rd ) categorized as being in water availability deficit
    • Water utilized in the proposed development will be transferred out of the sub watershed (HUC14 – Great Brook above Green Village Rd) to a different sub watershed (HUC14 Loantaka Brook) further exacerbating the water availability deficit
  • Issues concerning the amendment of the current sewer service area map to add the proposed development area
    • This 9.3-acre proposed development is not currently included in sewer service areas
    • The proposed development will extend the sewerage service area– not infill within a current coverage area
  • Issues concerning the replacement of 9.3 acres of woodland area with rooftops, hardscape, pavement, and lawn
    • Overall runoff volume will be increased to downstream properties due to a lack of post-development recharge of stormwater runoff
    • Flow path of post-development stormwater runoff will be altered from sheet flow over the majority of 9.3 acre site and be concentrated at two discharge points
    • Although the development meets the reduced overall runoff volume will be increased impacting sensitive downstream habitats
    • Stormwater runoff will contain increased nutrients and chemicals that will have a negative impact on downstream water quality
  • Issues regarding the direct downstream impacts to critical habitat for threatened and endangered species (T&E)
    • Increases in water volume to the Silver Brook (AKA – Catfish Brook) will cause bank erosion threatening known, critical wood turtle habitat at the GSWA CMA
    • Altered base flow volume will impact Federally funded vernal pool restoration directly downstream
    • Increased nutrients contained in stormwater runoff from the proposed development will negatively impact downstream water quality resulting in the impairment of sensitive macroinvertebrate habitat
  • Changes to the Northeast Water Quality Management plan as needed to expand the Sewer Service Area map will create significant additional effluent discharge volume, through the Woodland Wastewater Treatment Plant, into Loantaka Brook
    • Additional nutrient loading caused by the increase in effluent from Woodland Wastewater Treatment Plant could exacerbate algal blooms in Kitchell Pond, which is part of Loantaka Brook HUC14.  Impacts from algal blooms could include the presence of blue-green algae classified by NJDEP as a harmful algal bloom (HAB)

GSWA hosted an informational Zoom webinar on Feb. 23 where staff and subject matter experts provided an overview of the facts and concerns. Below are the presentations and information shared on this webinar. Click the links below to view:

 

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