Dear Middlesex County Commissioners –

The Lower Raritan Watershed Partnership (LRWP) provides the following comments on the Middlesex County Destination 2040: Proposed Open Space and Recreation Plan (OSRP):

• Balance open space purchases using County funds with housing offsets to address affordable housing crisis

The OSRP calls for acquisition of land zoned for residential development to preserve farmland and open space, however it does not contain provisions for the off-setting of these purchases with requirements for participating municipalities to increase their residential zoning density or extent. We are concerned that if adopted as currently configured, the OSRP will lead to additional upward price pressure on remaining residentially-zoned undeveloped land, ultimately translating into even higher housing costs and exacerbating the ongoing housing crisis already documented in Middlesex County’s Destination 2040 Master Plan.

We suggest that to mitigate this unintended consequence of two Destination 2040 objectives working against each other the OSRP should require those municipalities receiving Middlesex County Open Space to densify or expand their residential zoning to completely compensate for the reduction in potential buildable units resulting from farmland and/or open space purchases. These offsets should consist of at least a ratio of one created zoned housing unit for every purchased developable housing unit, but with additional credits extended toward housing set-asides for affordable housing, micro-housing, homes for veterans, and age-restricted units.

• Contextualize recreational connectivity within the larger region

Any County Greenway considerations should include examination of large-scale network connections for recreation, specifically opportunities to link to multiple East Coast greenway networks via the Middlesex Greenway, the Delaware & Raritan Canal, and the Intracoastal Waterway. The larger metropolitan areas of New York City and Washington D.C. are roughly framed by the Appalachian Trail to the North and the potential alignment of the East Coast Greenway to the South. In addition, the Hudson River Valley to the East, the Delaware and Lehigh National Heritage Corridor, and the Chesapeake and Ohio Canal to the west all form a larger regional trail system matrix. The Middlesex Greenway and Delaware & Raritan Canal could serve as major junctions for these larger regional networks. Likewise, supporting Blueway access from the Intracoastal Waterway up the Raritan River inland to Middlesex County could strengthen a weak link in the East Coast Blueway system.

• Contextualize habitat connectivity within the larger region

Any analysis of ecological habitat and habitat needs must start with a larger perspective. No mention is made within the current OSRP of watershed level planning, migratory behavior linked to flyways and swimways, or other larger ecological planning efforts like those developed by the New York-New Jersey Harbor Estuary Program.

Similarly, as the Middlesex County border is so often defined by natural landscape features including watershed ridges and waterways that serve as habitat connectors, opportunities to enhance habitat connectivity must be examined within the additional contexts of neighboring County conservation and preservation efforts.

• Present more detailed analysis of use of Middlesex County Conservation/Preservation areas

The current OSRP provides solid summary and analysis of Middlesex County Parks system usage and amenities. However, the network of hiking trails within County and publically owned conservation and preservation areas is under theorized. Considerable opportunities exist to enhance access to areas like Plainsboro Preserve, Ireland Brook, Heathcoate Meadows etc. for passive recreational activities including hiking, cross-country running, and snowshoeing.

• Consider the role of Open Space Planning in addressing Pollution Reduction, Flooding and Erosion from an impervious cover reduction perspective

The primary cause of pollution, flooding, and erosion problems in Middlesex County is the quantity of impervious surfaces draining directly to local waterways. To repair our waterways, reduce flooding, and stop erosion, stormwater runoff from impervious surfaces has to be better managed. Through the OSRP Middlesex County has an opportunity to strategically prioritize impervious cover reduction in areas at risk through Open Space planning and other interventions. Middlesex County might consider an additional metric related to impervious cover reduction in their open space and recreation planning activities.

Sincerely,

The Lower Raritan Watershed Partnership Board of Directors