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President's Message By: Bill Dunn
As the gubernatorial election drowns on, DEP is very busy. They sent a letter to the League of Municipalities and asked that they distribute it to their mayors stating that DEP was requiring updated Wastewater Management Plans (WMPs) in planning areas 3,4 and 5. Bill Dressel shared the letter with Ellen and asked what AEA knew about this. The Commissioner says he is implementing E.O. 109. However the effect will be not allowing growth in the so called growth areas because plans are not updated. Those of you who have tried to update your WMPs know that the clock runs on the reviews until the data is old and more data is required. More and more information is requested by the DEP staff. One authority was asked for a build out analysis which has never been the purview of an authority. Dennis Palmer testified before a legislative oversight committee regarding the lack of responsiveness of DEP in approving WMPs. He brought in two foot of paper and showed the legislators. Each inch represents $100,000 of consultant work and the plan is still not approved. This was at least five years ago and Dennis' plan is a few inches taller and still not approved. His experience has been duplicated across the state. This program has not been working and it is not the fault of the local agencies charged with planning. DEP has changing their minds on important policies that are the backbone of the plans. E.O. 109 was a mystery to everyone. After DEP sent out staff to explain what it meant, the changed theirs and local agencies did not know what to do. All the discussion over the Big Map put a damper on any plan reviews; then came the wholesale C1 designations. An agency can not approve local work if they keep moving the targets they want the locals to hit. This is why it is not our fault that plans are not approved. Environmental chaos can not lead to good planning. On October 17th in the NJ Register DEP will propose notices about expired plans. Hearings will be held on November 17 in Morris County, November 21 in Burlington County and November 30 in Atlantic City. Members should plan to comment on the new planning rules. SWQ comments AEA has prepared comments on the Surface Water Quality rules. Copies have been shared with all members. See all of you in Atlantic City at the Annual Meeting. Thanks again for your kindness, patience and support, look forward to seeing all of you at the Taj. |