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
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
Very truly yours,
William G. Dressel, Jr.