WolfeNotes.com

Happy New Year, Folks

 

DEP Deal Makes A Sham of the Public Process & Violates Clean Water Act

Documents show that the Plumsted Municipal Utilities Authority (PMUA) met privately with DEP officials regarding the DEP’s review of the proposed new sewer plant to serve the massive Lennar development, and that DEP agreed to a critical permit condition months before the draft permit was subject to public review.

Private meetings with permittees are not unusual or improper. However, private agreements prior to public review – especially those that violate DEP’s Surface Water Quality Standards – are highly irregular and totally improper.

Worse, DEP took steps to cover their tracks and mask this prior private concession by omitting the “smoking gun” document from the list of documents provided in the draft permit.

Federal and State rules require that DEP identify all documents and correspondence related to how they derived the permit’s technical requirements.

Both actions are highly improper and are grounds for rejection of the permit by EPA or a Court of law for violation of the public process requirements regarding the issuance of Clean Water Act permits.

Specifically, a September 9, 2014 letter from Peter Ylvisaker Executive Director of Plumsted MUA to DEP supervisor overseeing the PMUA NJPDES permit transmitted an “Addendum” to the prior Socio-Economic Analysis.

Importantly, that September 9, 2014 letter references a prior July 22, 2014 DEP meeting, in which DEP made critical and huge concession to allow lower water quality limits for total dissolved solids (TDS):

If these excerpts are difficult to read, let me be specific here.

The PMUA Executive Director explicitly stated that at the July 22, 2014 meeting, DEP agreed that to the PMUA’s request:

“At our July meeting it was agreed the Analysis did provide sufficient justification for the lowering of the non degradation water quality limits for Total Dissolved Solids (TDS)”.

The letter goes on to note that repeat that DEP agreement on TDS at the close of the letter.

I  guess PMUA doesn’t realize that it is very bad form to put improper DEP deals in writing.

THe DEP’s concession on TDS was absolutely critical, because it is very difficult, if not impossible – without extremely costly treatment technology – to meet the effluent limits for phosphorus, which requires biological treatment that is supplemented by addition of other chemicals, without violating the DEP’s surface water quality standard for TDS, which is 500 mg/L (or lower):

No increase in background which would interfere with the designated or existing uses, or 500 mg/L, whichever is more stringent. 

DEP agreed to a TDS limit of twice that, 1,000 mg/L.

Now here’s where it gets even worse, as DEP intentionally excluded this PMUA letter from the documents listed in the draft permit in an obvious effort to cover their tracks.

Recall that the September 9, 2014 PMUA letter transmitted to DEP a May 10, 2014 Addendum to the Socio-Economic Analysis.

Here is how the DEP draft permit  (@ page 12) identified that May 10, 2014 PMUA Addendum, completely omitting the September 9 transmittal letter smoking gun:

8. “Addendum to the Socio-economic Analysis for the Plumsted Township Wastewater Treatment Plant” prepared by Van Cleef Engineering and HDR Hydroqual, dated May 30, 2014.

Note also how the DEP list of “Correspondences” in the draft permit (@ page 12) also omits the September 9, 2014 PMUA letter, but does include a subsequent PMUA October 17, 2014 letter:

 

 “Reality Came Around”

This could be Gov. Christie’s theme song:

To think that only yesterday
I was cheerful, bright and gay
Looking forward to, but who wouldn’t do
The role I was about to play

But as if to knock me down
Reality came around
And without so much as a mere touch
Cut me into little pieces   ~~~ Alone Again (Naturally) (Gilbert O’Sullivan (1972)

Pick your reality: Climate change. Bridgegate. Jeb Bush. Sit Down Shut up.

Most recently, Governor Christie has engaged in another lonely act of sabotage on the climate change issue, this time attacking an already weak Obama EPA proposed rule to reduce emissions of existing power plants, see today’s AP story:

• [Christie] critiques [Obama] U.S. power plant plans, calls rules ‘impossible to implement’

Bill Wolfe, founder of New Jersey Public Employees for Environmental Responsibility, said the DEP’s letter is troubling partly because he believes Obama’s proposed rules are too weak and cede too much control to state governments in the first place.

He also said it’s the latest in a string of actions Christie has taken on environmental issues.

“He doesn’t deny science,” Wolfe said. “He’s willing to acknowledge the problem, but he’s not willing to do anything about it.”

[for the wonks out there, here is the Christie DEP letter to EPA, h/t TJ.]

Christie is completely out of touch with NJ folks, who understand the science and have demanded action.

See: Christie embraces climate denialism, a national story we broke and told here in NJ many months before, see:

• Christie Deep-Sixed Climate Change Prep
• Gov. Christie: Climate Change An “Esoteric” Issue that “People Don’t Give a Damn About”

But Christie just can’t seem to get with his fellow Republican’s program: just deny the science! It’s all a hoax!

Instead, perhaps even worse, Christie admits the science, but just refuses to do anything about it.

Which puts him in a very lonely place. Alone again, naturally.

State Parks Capital and Operating Funds Must Be Fully Restored

Climate Change and Long Neglected Urban Needs Must Be Addressed

With Less Money & Greater Public Needs, Cost Controls and Planning Reforms Are Required

During the December 8, 2014 hearing of the Senate Environment Committee, Chairman Smith asked for public comments on implementation legislation for the new Open Space funds approved by the voters in November. For a flavor of that debate, see Star Ledger story:

• Fight over open space money brews after ballot question passes

.Below are our recommendations – we strongly urge those who agree to write to Chairman Smith and Assembly Chairwoman Spencer by the December 31, 2014 comment deadline: (email addresses: senbsmith@njleg.org; aswspencer@njleg.org)

December 21, 2014

Dear Chairman Smith and Chairwoman Spencer:

In accordance with Chairman Smith’s request during the Senate Environment Committee’s December 8, 2014 hearing on open space implementation legislation, below  please find my recommendations.

At the outset, it is important to note that I make fund allocation and policy recommendations.

The precedent I rely on for the policy recommendations, as I indicated during my testimony, is the implementation legislation for a portion of the original 1996 CBT dedication, the 1997 Watershed Management Act (Act), P.L. 1997, c. 261.

In the Act, the Legislature found: (emphases mine)

First of all, these 1997 legislative findings have huge continuing relevance today in the following regard:

1) the Legislature noted that funding levels at DEP had been cut and “must be increased in future years”.

2) the objective of additional funding was specifically tied to compliance with regulatory requirements.

3) the funds were intended to expand existing DEP efforts.

Second, substantively, the Act boldly created an entirely new policy and watershed based planning program at DEP. The watershed planning process was designed to be transparent, open, and participatory, including specific requirements for public participation.

Third, the Act specified detailed purposes and allowable uses of funds. Those purposes were substantively integrated with regulatory requirements (see Section 5).

Fourth, Section 6 of the Act set fund matching requirements and strict prohibitions on the use of funds for the benefit of regulated entities and regulatory purposes:

(2) A watershed management group may, pursuant to guidance provided or rules or regulations adopted by the department, distribute all or part of the loan or grant to another person who is to perform a watershed management activity for which the loan or grant was provided. If the watershed management group distributes the loan or grant to a person who has a NJPDES permit to discharge pollutants into the waters of the State pursuant to P.L.1977, c.74 (C.58:10A-1 et seq.), the distribution shall be conditioned upon the permittee providing a match of one dollar for every dollar provided by the loan or grant. The match may be made either as a monetary payment or as an in-kind contribution. Any person who has a NJPDES permit and who accepts a loan or grant pursuant to this subsection shall agree not to use any of the loan or grant monies for the purpose of complying with NJPDES permit requirements. 

• Policy and fund allocation recommendations

With these 1997 precedents in mind, I make the following policy recommendations for open space funding implementation legislation:

1. Fully Restore Parks Capital and Operating funds

Of the initial year $71 million, $32 million must be allocated to State Parks. The entire State Parks capital dedication should be restored legislatively.

Additionally, because lease and concession revenues have been dedicated, we understand that State Parks will suffer a loss of an additional $3.8 million in operating funds, with Liberty State Park particularly hard hit. The full $3.8 million potentially diverted must be restored.

This full restoration is consistent with the terms of Ballot Question #2. The full restoration is authorized pursuant to the provisions of SCR84 (SCS). Full restoration is consistent with public statements of the Keep It Green Coalition.

Specifically, when critics warned that State Parks capital funding was effectively being diverted, KIG responded that parks funding “was in there” as an allowable use of open space funds.

Accordingly, there was no legislative intent and no voter awareness or support for reducing State Parks capital or operating funding. See:

• NJ Open Space Voters Did Not Support Slashing Funds For State Parks and Clean Water Programs

2. Fund neglected and new unmet urban needs

Like the 1997 Act, the legislation must respond boldly to new needs, and address long neglected needs, as follows:

Of the $32 million restored State parks money, at least 1/2 should be allocated to the following unmet and neglected urban needs.

a) Urban parks, Community Gardens, Farmers Markets, and Food Desert programs – “Jersey Fresh 2.0″

The Legislation should allocate those urban parks funds on the basis of a formula that looks at needs: i.e. there are indicators, such as open space and parks per capita or per land area, in each NJ town.

This GIS based formula could also include a location and distance component, e.g. children and elderly should not have to travel more than 1/2 mile to access a park or open space.

Similarly, a significant portion of the farmland preservation funds should be linked to programs that benefit urban residents, including farmers markets and community gardens. The USDA and Rutgers have done good work to map “food deserts”, communities that lack access to fresh fruits and vegetables.

Just like the unmet parks and open space needs, these “food desert” communities could be targeted by a GIS based formula built into the implementation legislation.

b)  Urban Forestry 

Climate change will result in a significant increase in 90+ – 100+ degree days during summer heat waves, see:

• Northeast Climate Assessment

Hotter days increase unhealthy ground level ozone that triggers asthma attacks and respiratory distress. Heat waves also cause increases in mortality, particularly in elderly populations. Urban areas suffer extreme “heat island” effects due to all the pavement and buildings that store heat and the lack of natural cooling of shade trees and vegetation.

All of this will greatly increase the current disproportionate burden born by NJ’s poor and minority urban residents.

DEP already has developed data and a methodology to document these disproportionate burdens.

Specifically, DEP mapped 9 indicators of environmental or public health risk or impact, which correlate strongly with race and income: poor and minority urban communities bear far higher risks, a classic case of environmental injustice, see:

• DEP Discovers Discrimination – Dumps Environmental Justice Issue in Christie’s Lap

In addition to urban parks and community gardens, the legislation should include a major new commitment to urban forestry, as one means to offset the impacts of climate change by providing shade trees, parks, and open space.

In addition to a share of the restoration of Parks funds, a portion of the agricultural and open space fund allocations could be directed to those urban program needs.

3. Impose Cost Controls and Planning Reforms

Historically, the NJ Open space program spending averaged something like $200 – $250+ million per year.

Acquisitions were opportunistic, i.e. based on a willing seller, and not required to reflect any larger planning scheme.

Available funds have been reduced to just $71 million, increasing to $117 million in 2016. Actually, available funds are far less when the $32 million in dedicated State Parks money is subtracted from the $71 million.

The existence of huge unmet needs, greatly increased competition between traditional programs, and major new urban priorities that are not funded dictate the need for cost controls and a more efficient and cost effective program.

Such controls include restrictions on purchase of regulated lands, revisions to land appraisal methods, and elimination of funding for private groups and undefined  and controversial “stewardship” activities.

4. Restrict pooling of funds for regulatory compliance oriented projects

The 1997 Act prohibited use of CBT funds for the benefit of regulated entities and regulatory compliance purposes.

The intent was to prevent regulated entities from using public funds for various DEP regulatory compliance obligations, whether DEP permit, TMDL, water quality study, mitigation, enforcement supplemental environmental program (SEP) or Natural Resource Damage restoration or compensation projects.

Open Space funds have a similar potential for abuse.

For example, a private for profit regulated entity could contract with a private non-profit group to acquire land or engage in mitigation. The project that could receive public open space funds via the non-profit involvement could be a requirement established by DEP, EPA or a federal Natural Resource Trustee.

Various regulatory mandates could range from stream buffer restoration/averaging, wetlands mitigation, carbon offsets, carbon sequestration, carbon credits, pollutant trading, NJPDES BACT demonstrations, WQMP requirements, groundwater recharge projects, SEP’s, or NRD projects, among many other possibilities.

To avoid these large potentials for abuse, the bill should flat out ban any co-mingling of public open pace funds with private sector regulated projects or regulated activities – particularly when “leveraged” with private non-profit involvement.

5.  No funds for “stewardship”

The is no legal, regulatory, or policy working definition of “stewardship”. That lack of definition and policy created enormous conflict in the recent debate on a “Forest Stewardship” bill.

Given scarce funds and a “stewardship” program that is not ready for prime time, it is premature ti allocate any funds to that purpose.

6.  No funds for non-profit administrative costs

The SCR84 authorizing Resolution prohibited use of funds by DEP site remediation program staff.

During the public debate on Ballot Question #2, Ed Potosnak from NJLCV, a member of the Keep It Green Coalition, wrote an Op-ed piece that accused DEP of abusing CBT funds by spending them on staff salaries, see:

• OP-ED: VOTE YES ON PUBLIC QUESTION 2 FOR CLEAN WATER, PRESERVING QUALITY OF LIFE

Potosnak doesn’t know what he’s talking about.

According to DEP, the FY’15 DEP budget funded 266 DEP positions with CBT funds, continuing an 18 year pattern authorized by the original 1996 CBT dedication.

Given those 2 facts, compounded by scarce resources, deep cuts to DEP staff, and huge competing public needs, there should be no funds allocated to private groups.

7.  Apportionment of remaining Open Space funds

After restoring the $32 for Parks capital budget and $3.8 million lease/concession operating budget funds, there are just $35.2 million remaining.

We recommend that those funds be apportioned as follows:

• open space                  ~~~   $20 million (with 25%, or $5 million allocated to urban programs outlined above)
• historic preservation     ~~~   $  8 million
• farmland preservation   ~~~   $7.2 million (with 25%, or $1.8 million, allocated to urban farmers markets and food desert programs outlined above)
• blue acres                     ~~~   $ 0 (NJ received $400 million in Sandy recovery Blue Acres funding)
• stewardship                   ~~~   $ 0 (no funding until a program is defined and enacted into law)
• private non-profits          ~~~  $ 0  (given that DEP staff costs in site remediation were prohibited, so should non-profits)

I appreciate your consideration and look forward to working with you in developing legislation to flesh out the above broad policy recommendations.

Sincerely,

[Note: I did not forget about the need to restore Site Remediation, UST, and water resource programs from which funds were diverted by the ballot question.

But those restorations can not be accomplished in implementation legislation and must wait for the annual budget process.]

Excess Sewer Capacity Fuels Development That Destroys Rural Character & Water Quality

Full Costs of $18 Million System and Who Pays Are Not Disclosed

DEP Ban on Cesspools Does Not Prohibit Sale of Property

Gated Retirement Developments Undermine Downtown Merchants & Community Cohesion

At the conclusion of Wednesday’s DEP public hearing on the proposed new sewer plant discharge to Crosswicks Creek, a few of the project’s supporters, none of whom spoke publicly, accused me of scaring people and providing misinformation.

Others claimed that they could not sell their property due to a new DEP ban on cesspools and failing septic systems, and that sewers were necessary to revitalize the downtown.

Apparently in response to issues raised during the DEP public hearing, the Plumsted Municipal Utilities Authority (PMUA) –  who also did not speak or formally present the project to the public at the hearing – posted bullet points on their website to explain or justify the project (see this for the PMUA powerpoint).

So, I thought I’d mention a few things that PMUA ignored and respond briefly to some of the myths, flaws, and unintended consequences of the New Egypt Redevelopment Plan and the PMUA sewer project.

• What they are not telling you or don’t want to discuss

1) Illegal discharges, cesspools, and failing septics

First of all, there are illegal pipes discharging septic and/or grey-water to Crosswicks Creek from homes and businesses. You don’t solve individual enforcement problems with a massive public sewer system – you take enforcement action, hold individual property owners accountable, force upgrade, and shut those discharges down if you have to. This is something that should have been done by the local health officer and DEP years ago.

Second, there is a lot of fear based on misinformation.

Downtown merchants and homeowners with cesspools and/or failing septics seem to think that: a) DEP’s 2012 regulations prohibit the sale of their property; b) it is impossible to manage wastewater on small lots; c) sewers are the only alternative; and d) massive new development is necessary and will pay for the sewer system (i.e. they will get bailed out).

All of this is completely false.

Here is a DEP fact sheet on the new rules, which were adopted in April of 2012.

DEP rules do not block sale of property. Replacement or upgrades to the cesspool or septic system are negotiated by the buyer and seller in the sale price of the property, just like any other condition, i.e. bad roof or antiquated heating unit etc. DEP rules do nothing to change that fact.

DEP had been working on those rules for over a decade, so all local health inspectors and local and County planners KNEW these new requirements were coming and had plenty of time to take steps to comply with them.

There were relatively cheap alternatives to failing cesspools located in densely developed areas on small lots that could not accommodate a septic field (e.g. install a septic tank in front of the cesspool). These alternatives could have been installed prior to April 2012 before the new rules took effect. The DEP rules since 1990 have required that any “correction” to a cesspool include the addition of a septic tank in front of the cesspool, effectively altering the cesspool to a seepage pit system.

Even if it was not possible to install a septic tank in front of the cesspool, the local health officer could allow a cesspool to continue to exist if he found that it was functioning and not adversely impacting public health or the environment.

With reference to smaller lots, the rules provide for a number of design considerations to deal with these situations. For example, the use of an advanced wastewater pretreatment device pursuant to N.J.A.C. 7:9A-8.3 provides opportunity to reduce the disposal field size in both the area required and the thickness in the zone of treatment. If a fully conforming design is not possible, N.J.A.C. 7:9A-3.16(a)1 provides the administrative authority with the ability to approve of nonconforming designs that are protective of human health and the environment.

Last, if all other options were impossible, a property owner with a failing cesspool or septic could install water conservation measures, no flush toilets, and use a holding tank.

Did your local officials tell you any of this?

No – they wanted a sewer system.

Cesspools are a Medieval technology. Construction of them was banned almost 40 years ago, in 1978. Regulations on proper construction of seepage pits have required at least two feet of unsaturated soil beneath those units since 1954. Here is DEP’s view:

These antiquated units provide no pretreatment of wastewater before discharge, allowing raw sewage to directly impact the environment. 

It is no longer reasonable, in a state as densely populated as New Jersey that has extensive natural resources that need to be protected from such discharges, to allow these obsolete units to continue to be utilized. 

Any business or homeowner that has been relying on a cesspool has absolutely no reasonable expectation that someone else will pay the cost of upgrading that system. None at all.

2) growth and community character

The DEP sewer permit is for a discharge to Crosswicks Creek of  600,000 gallons per day.

The homes and businesses in downtown New Egypt generate a small fraction of that 600,000 GPD.

Even with the proposed massive new 400 – 600 unit retirement development, less than 300,000 GPD would be required.

So why is the PMUA seeking a 600,000 GPD discharge permit?

The obvious answer is that this sewer plan is designed to promote massive new development.

Just as obvious is the fact that this plan has little to do with the publicly stated objectives to revitalize downtown New Egypt or improve water quality.

According to the 2010 United States Census, there were 2,512 people, 902 households in New Egypt (Wiki).

The extra 300,000 GPD capacity would provide enough capacity to serve 1,500 new homes – that would more than double the entire population of New Egypt – and that new growth does not include the massive new 400 – 600 unit retirement development!

3) costs, risks, and who pays

At the public hearing, I criticized the draft permit’s “anti degradation analysis” and “socio-economic analysis” for failure to disclose the full capital and operating costs of the sewer plant and distribution system and identify who would pay for them and how much they would pay.

In response, the PMUA posted these “facts” on the cost of the system, which raise far more questions. PMUA wrote:

So, let’s do a little math:

First, note that operating costs are not mentioned here. According to PMUA engineers, operating costs, for the sewage treatment plant alone (not considering all other costs of the system), will be well in excess of $1 million per year, and that’s just for O&M for the sewer plant, not the entire system. That is over $1,000 per household, according to PMUA engineers, and just for the sewer plant, not the entire system.

Second, note that legally mandatory connections fees for all homeowners and businesses in the sewer service area are not included. All property owners will be legally required to connect to the system, and connection costs could be additional thousands of dollars, depending on how far away from the sewer line the building is located.

Third, note that the risk and costs resulting from DEP fines and penalties  are not mentioned. The PMUA’s own engineers have stated that the facility’s treatment technology can not reliably meet the DEP’s proposed permit limits. Any violations of DEP permit effluent limits trigger automatic mandatory penalties – taxpayers will own the system and will have to pay for these, and they could be considerable and occur very frequently. This is a significant risk that the Town will not be able to get any developer to assume.

Fourth, if the full capital cost is $18 million – and I say “if”, because to is not clear exactly what costs that estimate includes, and whether it includes the conveyance system (pipes) – then the PMUA claims are very misleading and the math is flat out wrong.

An $18 million capital cost divided by 400 units in planned new retirement community is $45,000 per unit.

PMUA claims the retirement community will assume all costs and that they are $19,500 per unit.

For 100% of the $18 million capital cost to be assumed by the retirement development at $19,500 per unit would require a total of  923 units!

So either local taxpayers will pick up a huge tab for this sewer plant or else local officials are planning to build more than twice the number of new homes they have stated publicly.

PILOT payments are “in lieu of local property taxes”. Local property taxes should have nothing to do with sewer system costs, which are supposed to be paid by users of the system.

So, PMUA is misleading residents by blending those two very different issues in the same bullet point.

Finally, there is no legally binding agreement or financial document that can support the PMUA claims. They are assumptions, based on very rosy and unrealistic views of the ability of local officials to extract payments in a negotiated developers agreement.

It is my experience that developers always have more accurate information, more sophisticated financial capabilities, better lawyers, and more negotiating leverage than local governments.

Last, you need to consider how local authorities with the ability to raise revenues behave: they will expand their mission, staff up, buy lots of expensive unnecessary equipment, and become a political patronage hiring pit.

As a result, local taxpayers always get screwed by developers and things turn out badly. Don’t say you weren’t warned.

4) environmental impacts

There are a lot of negative environmental impacts that are not being disclosed by the PMUA or local officials.

The alleged positive water quality impacts claimed by the PMUA from elimination of cesspools and failing septic and the new sewer plant have not been supported by facts, and the PMUA’s own documents contradict some of those claims.

Let’s start with what they are not telling you:

Development of 1,900 new housing units for about 3,500 more people (400 retirement units plus 1,500 new units that could be built with the 300,000 GPD excess sewer capacity) would:

1) consume hundreds of acres of land, 2) destroy farms and forests, 3) create significant new storm water runoff, 4) exacerbate flooding and already severe erosion problems, 5) create non-point source pollution of Crosswicks Creek, 6) create traffic congestion, generate air pollution, and increased greenhouse gas emissions, 7) reduce aquifer recharge, 8) require pumping of at least 500,000 GPD from groundwater to provide water supply, 8) the combination of less recharge and more pumping will deplete groundwater and have adverse impacts on local wetlands, stream base flows, and plants, fish and wildlife, 10) the additional new development and land consumption will negatively impact wildlife habitat and populations, and 11) new development will severely alter the rural character and visual landscape.

More secondary development and infrastructure (gas lines? road improvements? sewer and water lines) will be needed to service all the new growth, and they will have environmental impacts too.

It is very likely – if not certain – that the new development will generate more pollution will offset any pollution reductions from failing cesspools and septics and make water quality worse in Crosswicks Creek.

PMUA claims that the sewer plant would “have no impact on stream flora and fauna”.

There is no evidence to support that statement and it is false.

First, see the above set of impacts the sewer plan will have.

Second, the sewer plant will discharge new pollution loads of nutrients (phosphorus and nitrogen), heavy metals (copper, lead, nickel, zink, mercury, et al), dissolved and suspended solids, and organic chemicals, including things like household hazardous chemicals, contraceptive, prescription drugs, and endocrine disrupting compounds from the metabolism of pharmaceuticals.

As I stated at the hearing, most of these pollutants are toxic to plants, fish and aquatic organisms and some of the organic chemicals are causing profound ecological damage, including recent studies that have shown “dual sexed” fish in the Delaware River.

To claim that the discharge of these pollutants to the Crosswick Creek  – in any amount – would have “no impact” is a ludicrous claim that has no basis in science and that claim is found nowhere in the applicants documents or DEP draft permit.

5) The Redevelopment Plan and downtown New Egypt – Lousy Planning and Loss of A Sense of Place

Downtown New Egypt is surviving but not thriving. The Redevelopment Plan won’t change that, it will make matters worse.

There are national and regional economic conditions that have a far larger impact on the economic wellbeing of downtown New Egypt than the lack of sewers. There are more cost effective other things planners, architects,  and merchants can do to promote downtown revitalization that don’t involve sewers.

Local officials are making false promises to residents and downtown merchants that lack of sewers is what explains their economic distress and that sewers and new development are some kind of magic bullet that will resolve these economic problems.

That is misguided policy, poor planning, and contradicted by the town’s own Redevelopment Plan.

First of all, a large gated senior development  located in a farm field almost a mile from downtown, along roads with no sidewalks, will not help create a “vibrant, diverse, pedestrian friendly, downtown”.

Senior communities are parasites on downtown merchants and communities.

They are sterile and isolated places with no stake in the community –

Their residents won’t attend your football or soccer games or Halloween Parade or graduation or civic ceremonies.

They will not shop downtown and support your local merchants – they will go to nearby regional and more upscale outlets. Sure, they tend to have lots of money to spend, but the don’t have kids, they won’t make neighborly friendships, and they won’t get politically engaged in your local issues except to make selfish demands, which they will enforce by voting in high numbers as a block.

They will not support your school system because they pay no school taxes and have no kids and no interest in educating your kids.

Seniors have higher rates of accidents and health events – like heart attacks, strokes and falls –  that require costly emergency services. They tend to demand more security and police protection. They demand that the sidewalks are smooth, the roads get paved and snow plowed immediately – and that fire Departments and other public services are at their special disposal.

They drive everywhere and create lots of traffic and the need for costly new road improvements, traffic lights, turning lanes, signs, etc. They are politically active and can force local government to meet their needs and impose costs on the rest of the community. These are significant costs to the community that no one is talking about.

Senior citizens don’t walk 1/2 mile along roads with no sidewalks to go downtown New Egypt for a quart of milk and to shop.

Senior citizens living in gated, professionally landscaped developments don’t go to the local Agway for lawn maintenance, supplies, and home repair stuff.

In sum, retirement communities are a disaster for the downtown business district and any ability to build community cohesion and what’s called “a sense of place”.

Last, the Redevelopment Plan includes condemnation of existing homes and the use of eminent domain – even if the Plan succeeds, there are gentrification issues that must be considered.

And this is what the people of Plumsted are tying their future to.