Mr. David Fanz

New Jersey Department of Environmental Protection

Land Use Regulation Program – Monmouth Region

P.O. Box 439

501 East State Street

Trenton , New Jersey 08625-0439

Re: Application for a General Permit No. 10A – Long Crossing

75 Manchester Avenue , Keyport Borough, Monmouth County , N.J.

Block 120 Lots 8 & 9 Block 130 Lots 42, 48–52

MC Project No. 041148A

Dear Mr. Fanz,

Since 2000, the Bayshore Regional Watershed Council (BRWC) has been working to improve the physical environment in the Raritan Bay – Sandy Hook Bay watershed region of Middlesex and Monmouth counties. The BRWC is made up of volunteers, including citizens, scientists, environmental commissioners, and municipal officials. Our goal is the restoration and conservation of bay waters and their tributaries.

Recently, it has come to the attention of BRWC members that there are new development activities within the Borough of Keyport, Monmouth County , New Jersey , that has the high potential to degrade the physical environment in the Bayshore region.

The BRWC understands that there is currently an application for a General permit No. 10A – Long Crossing, in front of NJDEP. Under the Freshwater Wetlands Protection Act rules, N.J.A.C. 7:7a, the applicant, 75 Manchester LLC, is seeking approval for disturbance of a NJ State open water in order to construct a roadway near freshwater wetlands.

This letter is to request that NJDEP turn down this permit application.

The BRWC believes that there are at least seven reasons for the application to be rejected. The grounds for refusal are as follows:

• Point Number 1: The property is next to Chingarora Creek, which is part of Conaskunk Point. This location is over 100 acres and is the largest extant tidal wetland system in the Bayshore region. As such, it is one of the most environmentally sensitive areas in the watershed region.
• Point Number 2: The freshwater creek through this property is part of the Chingarora Creek watershed area that drains out to Raritan Bay . This natural creek environment is maintained for the enjoyment of residents and visitors. A roadway in this location would be a major disturbance of this natural environment.
• Point Number 3: Chingarora Creek is part of the storm water drainage system for numerous streets within the Borough of Keyport. If an additional roadway was permitted, a major culvert would be necessary to handle on-street flooding from 1 and 3-year severe storm events. Thus, further degrading water quality and further degrading wetlands.
• Point Number 4 : The application is requesting to construct a road near the Henry Hudson multi-use rail-to-trail, part of the Monmouth County Park System. This trail provides much needed recreation in an area of the Bayshore that is already over-saturated with development, many of it poorly planned. It would then be impractical and injudicious to locate a high-traffic street abutting to a park that contains children and families. This would destroy the existing natural vegetated buffer and a safe zone between the trail and on-hand development. This roadway would also destroy a section of the linear park and be a reversal of 4/18/2005 Monmouth County plan for buffering the trail.
• Point Number 5: There is every reason to believe that this roadway will lead to future development that will degrade the abutting park and nearby creek. 75 Manchester LLC has submitted to Keyport Borough officials plans for a major housing development for this site and needs a high-traffic roadway through this creek area. Maser Consulting describes the 75 Manchester project on their website as the redevelopment of an existing industrial building site into a multifamily residential complex consisting of approximately 60-units with a mix of flats, duplex, and townhouses over a lower parking deck. It seems apparent that the purpose of this NJ DEP application is really to lay the foundation for the main street for this 60-unit development.
• Point Number 6 : The BRWC believes this roadway is totally not necessary. Since the applicant has full access to his property and building from Maple Place , there is no justification for disturbance of "State open waters" and vital freshwater wetlands in order to construct a retaining wall and driveway.
• Point Number 7 : Finally, the BRWC believes strongly in the absolute need to preserve wetlands and improve stream quality, not degrade it further by unwanted and poorly planned development. In urban areas, such as much of the Bayshore region, wetlands are among the last remnants of natural vegetation in the landscape. Wetlands are thus important elements of the natural capital of urban ecosystems. They often serve or are expected to serve multiple functions within the system: stormwater detention, water storage, treatment of wastewater/water quality improvement, maintenance of wildlife habitat, human recreation, education, and aesthetics. As more land in the surrounding area is converted to development, and population densities and demography change, increasing pressure is placed on those wetlands that remain to serve these multiple functions, some of which are incompatible. The potential for cumulative impacts of stressors on urban wetlands means that these impacts cannot be analyzed in isolation.

The BRWC also believe it is in the best interest of residents and taxpayers of Keyport and the Bayshore region of Monmouth and Middlesex counties, and citizens of the State of New Jersey for a public hearing to be conducted on the need and scope of this project.

It has been the experience of many BRWC members that very often new development projects are undertaken will limited public review or little sensitivity to the future needs of the community. Furthermore, as is often the case, there are no special actions taken to gain local concerns from those residents who usually do not have an active voice in the community, such as the poor, minorities, or newly relocated residents. Development projects repeatedly have the greatest negative impact to these groups of people.

At this time, few people who live in Keyport, including those who reside near the project area, know anything about this proposed project. There is a need for the general public to be educated and play an active role in the process, and to be represented as an interested party.

Under these social environmental circumstances, the BRWC strongly believes that a public hearing is needed to openly make known the purpose of the project.

The natural environment in the Borough of Keyport is a vital element in the economy of the Bayshore region. Commercial and recreational fishing, and shellfish harvesting in the area around Chingarora Creek contributes a substantial amount of money in taxes and generates hundreds of jobs.

The Bayshore Regional Watershed Council would hope that NJDEP would try to preserve and protect the local environment rather than add to our problems.

We appreciate the opportunity to submit these comments. Public review is an integral part of intelligent, fact-based development.

In closing, the need to preserve urban wetlands and the watershed area, the applicant’s failure to fully disclose his intentions for a 60-unit housing development, and the negative impact on the Henry Hudson Trail, all justify an immediate denial of this application.

Please put the Bayshore Regional Watershed Council on the list of parties notified of actions regarding this application.

Sincerely,

Joseph S. Reynolds

Co-chair

Bayshore Regional Watershed Council

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