April 24, 2003

Ms. Janis E. Hoagland
Attn. DEP Docket No. 03-03-02
NJ Department of Environmental Protection
Office of Legal Affairs
401 East State Street
PO Box 402
Trenton, NJ 08625-0402

Re: Comments on the NJ DEP "BIG" Map

Dear Ms. Hoagland:

On behalf of the New Jersey State League of Municipalities and its 566 member municipalities, I would like to submit the following comments for your consideration.

The League has already been an active participant in the "BIG" map process, and coordinated an on-going dialogue between a group of mayors and the DEP and the DCA Commissioners. For this, the League is appreciative and hopes to continue such a progressive working relationship.

The League, however, is in a unique position. Since we represent all 566 municipalities in the State of New Jersey, we represent constituencies in the red, yellow and green sections of the map. We represent those who view themselves as "winners" under the new map, and those who view themselves as the "losers" under the new map. It is impossible for us, therefore, to fairly relay the views and opinions of all local leaders interested in the new map. We have done our best to work with DEP to disseminate information to local policy makers. Many local officials have already taken the opportunity to comment on the BIG map, and the League has received a number of these comments as well. We will rely on municipalities to articulate their particular concerns in an appropriate fashion.

From our perspective, the League believes it is necessary to comment on the upcoming process of turning the BIG map from concept to public policy. While we believe the DEP has been proactive in its outreach, a number of local governments believe they have not had enough input into the process. This is understandable from their perspectives, and this underscores our comments.

In order to assure the greatest amount of input from local officials, the League believes it would be wise to model the adoption of the "BIG" map on the already successful cross-acceptance process. For approximately 15 years, local governments and State government have partnered in this process. This partnership has resulted in what is commonly known as the State Map, and we view it as a success.

We certainly are sympathetic with efforts to stop sprawl. For far too long, local officials have not possessed the necessary tools to combat unwise development. We appreciate that the McGreevey Administration has made this a centerpiece of its agenda. Since the BIG map is part of that process, we believe this process can be even more valuable than the State Plan if it is modeled on a bottoms-up inclusionary process.

In that regard, we ask the DEP to continue and expand its regional and/or county meetings, so that all local policy makers have the opportunity to contribute directly to this process.

Furthermore, the League believes it is of utmost importance that municipalities are provided with the necessary technical information at the beginning of the process. If the formula and data are transparent from the beginning, it will bode well for the validity of the process.

We realize our suggestions will inevitably delay the process and provide fodder to those who are intractably opposed to the BIG map or any efforts to curb sprawl. But slowing the process will likely result in a better-finished product.

We thank you for the opportunity to comment and look forward to an on-going collaborative effort between the League and the DEP.