August, 20, 2007

Edward P. Carroll

Manager

Garden Park Associates

100 Cardinal Way

Freehold, NJ 07728

RE:  Garden Park Mobile Home Park, Bethany Road,

Dear Mr. Carroll,

This letter is in reference to a request by a resident of your Garden Park Mobile Home community, John Coffey, that the Bayshore Regional Watershed Council investigate the use of NJDEP grant funds to be applied to the on-going flooding issue taking place along Flat Creek and impacting individual mobile homes near the creek.

In 2005, the all-volunteer Bayshore Regional Watershed Council (BRWC), through the Monmouth County Planning Board and the Township of Holmdel, was the recipient of a $55,000 New Jersey Department of Environmental Protection (NJDEP) Action Now Grant that was awarded to study existing conditions of the Flat Creek watershed region upstream from the Ambient Biological Monitoring (AMNET) Station AN0459, located near Middle Road in Hazlet Township.

In order to undertake the study, the BRWC has partnered with the Townships of Holmdel and Hazlet, the Freehold Soil Conservation District, the Monmouth County Planning Board, the Monmouth County Mosquito Extermination Commission, and the Monmouth Coastal Watersheds Partnership.  

The scope of the study is very clear: It is to focus on the ecological health (i.e., water quality) of the Flat Creek watershed region upstream from the Ambient Biological Monitoring (AMNET) Station AN0459, located near Middle Road in Hazlet Township by assessing the benthic macroinvertebrate community at the station. The goal of this grant, as directed by NJDEP, is to improve the benthic macroinvertebrate community at the monitoring station.   

Biological monitoring has been conducted by NJDEP water quality scientists at Station AN0459 in 1994 and 1999.   Based on the biological monitoring results, the benthic macroinvertebrate community and Flat Creek watershed are both classified as severely impaired.   As such, a direct correlation between the value (i.e., community diversity and richness) of the benthic macroinvertebrate community and the water quality of Flat Creek has been established.  

The Flat Creek watershed area primarily receives drainage from a densely urbanized portion of Monmouth County, with population densities routinely exceeding 2,000 people per square mile.   Although the BRWC is concerned with improving the overall quality of the Flat Creek watershed, its main objective of this grant, as directed by NJDEP, is to raise the monitoring station’s New Jersey Impairment Score (NJIS) by three (3) points from zero.   Subsequent goals include having Flat Creek listed as non-impaired.   In order to accomplish these objectives, pollution and litter sources must be identified and corrected, as stated by NJDEP.

The portions of this grant are divided into two:

1) Hire a consultant to develop a qualitatively analysis of the overall drainage area and prevailing land uses in the Flat Creek watershed grant area, and identify known and suspected sources of watershed pollution.  This task has already been accomplished by T&M Engineering at a cost of approximately $10,000.

2) The remaining funds, approximately $45,000, are part of phase two of the grant and is required to be devoted to improving water quality within the grant project area by raising the monitoring station’s macroinvertebrate impairment score by three points at Middle Road. Thus, this dictates that the remaining funds be devoted to doing the most good, for the greater quantity of the project area, for the longest period of time.

Therefore, the BRWC, after much consultation with council members, the NY-NJ BayKeeper, Monmouth University, and the Monmouth County Planning Board have come to the conclusion that the remaining funds should be devoted to improving water quality within the Flat Creek watershed project area by two actions:

1) Installing several stormwater filtration baskets or storm-ceptor type devices within Hazlet Township and, if funds allow and permission can be received, within Holmdel Township as well. These systems are commonly used in highly developed urbanized areas where land use is too restrictive for natural devices, such as for wetland creation. The system can remove sediment, which can build up in waterways to cause flooding, and hydrocarbons from urban runoff. Designed to treat 85-95% of annual runoff, a stormwater filtration system captures stormwater pollution at the source, effectively capturing high percentages of Total Suspended Solids (TSS) and Total Petroleum Hydrocarbons (TPH). It is recognized by both NJDEP and the US EPA as a common Best Management Practice or BMP within urban watershed areas. If installed correctly and maintained on a regular basis, these systems have been known to improve home and habitat for aquatic life and improve water quality. They have been used in many communities from California to Connecticut. 

2) Establishing an environmental education phase that will design and distribute non-point source reduction methods to many of the property owners along Flat Creek within the project area. This phase may include producing a CD-ROM to show homeowners ways to best minimize their impact to the creek’s hydrology and to improve water quality.

The good news is that NJDEP has approved this plan, their objectives and solutions, and has agreed to allow the remaining grant funds to be used for these two actions, and no more than these two actions.

As for dredging a small portion of Flat Creek near Bethany Road, before dredging can be done, permits must be applied for and approved by several federal and state government agencies, such as the Army Corps of Engineers, US Fish & Wildlife, and NJDEP. Approval is granted based upon the method and procedures for removal and the impact that the dredging operation will have on aquatic life and other nearby wildlife. In addition, we would need to develop a method to confine the dredged material, which is expensive in its own right. The total cost of dredging a portion of Flat Creek, including the acquisition of permits, is way beyond the disbursement of our grant funds, and the time and effort of this all-volunteer organization. Thus, grant funds cannot be devoted to this important individual issue via this particular grant.

Let me state, however, that the BRWC has always advocated for the best planning, the best analysis, the best scientific methods and for long-term forecast studies to be used for any new development project. It is obvious that this was hardly ever done within the Flat Creek watershed region. Instead, a major push was given to develop the area as soon as possible without thought to basic environmental processes, such as flooding.

The BRWC will help in any way we can to improve the quality of life for the residents of the mobile home community. If permission is given by the property owner we would like to conduct stream clean ups and to investigate ways on-site that perhaps areas of the property can be devoted to re-vegetation or laid back further inland and away from the creek’s floodplain.

In addition, the BRWC will contact the Monmouth County Mosquito Commission to inform them of the flooding issue near Bethany Road and to encourage them to investigate this matter and to look into conducting a dredging project on their own.

Moreover, the BRWC asks that the property owner consider the following activities that might reduce long-term flood damage:

• Make sure people do not dump or throw anything into Flat Creek on the property, such as lawn clippings, trash, or topsoil.  A plugged channel cannot carry water, and when it rains the water has to go somewhere.  Every piece of trash contributes to flooding.

• The property owner should consider not building on, altering, re-grading, or filling on the property near the creek in the future.  If any nonconforming use or structure is destroyed by any means, including floods, to an extent of 50% or more of its market value at the time of destruction, it should not be reconstructed or rebuilt and the site should be converted back into wetlands.

• Likewise, serious consideration should be given by the property owner to raise the mobile homes above flood levels. At the very least this should be thought-out as a possible way to ease the burden on the residents of the mobile homes, especially those living closet to Flat Creek.

The BRWC is happy to work with the property owner and/or your office to achieve the above stated goals and to help mitigate the water channel from being plugged up by trash and litter. I thank you for your time and look forward to improving the Flat Creek watershed area for all species to enjoy with Garden Park Associates.

Sincerely,

Joseph Reynolds & Bill McFarland

Co-Chairs

Bayshore Regional Watershed Council

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