Climate Revolution Action Network (CRAN)

Comments on Resilient Environments and Landscapes (REAL) Rule Proposal

f: (732) 543-3005
e: climaterevolutionnj@gmail.com
w: climaterevolutionnj.org
Contact: Benjamin Dziobek

Introduction: Building New Jersey’s Future with Resilience and Responsibility

As young people, we are committed to building a resilient, equitable, and sustainable future for New Jersey. The NJREAL rules represent a critical opportunity to shape the development standards that will define our state in the face of climate change. Given New Jersey’s status as one of the most densely populated states, every new development must meet high standards of climate preparedness, sustainability, and public health protection.

The Climate Revolution Action Network (CRAN) calls on the New Jersey Department of Environmental
Protection to strengthen these rules with a forward-thinking, climate-resilient approach. Below are our key recommendations for immediate action, organized by the sections where changes are needed.

Enhanced Flood Hazard Management

Adopt Higher Sea-Level Projections: Climate models have historically underestimated both the severity and timeline of climate impacts. To protect communities from intensified flood events, the Climate Adjusted Flood Elevation (CAFE) standard should account for a higher emissions scenario rather than assuming global emissions will be significantly reduced from today’s levels. Based on data from Rutgers University, New Jersey is likely to expect 6.3 feet of sea level rise (SLR) by 2100 under a high emissions scenario. All new developments, redevelopment, roadways, and critical infrastructure should be raised to withstand 6.3 feet of SLR. By incorporating these projections into land-use planning, New Jersey can reduce the risk of costly future retrofits, ensure that infrastructure remains resilient over time, and reduce flood insurance premiums for coastal homeowners.
Managed Retreat: The NJDEP should prioritize Blue Acres Home Buyout applications for properties within the Inundation Risk Zone (IRZ). These homes are the most at risk for damage from SLR and coastal storm surge. Allowing continued development and redevelopment within the IRZ is irresponsible to the lives of prospective homebuyers, as well as the local emergency responders who are involved in rescue efforts in the event of a natural disaster. NJDEP personnel should increase community outreach initiatives in IRZ-effected areas to properly inform residents of future flood risk and their eligibility for the Blue Acres program.
Dry Access Requirements: The proposed “dry access” requirements mandate that critical infrastructure, multi-family buildings, or two or more single-family homes have access to at least one roadway elevated above the CAFE. During Hurricane Ida in 2021, the majority of casualties occurred from automobile strandings due to flooded roadways. Dry access requirements will both prevent roadway strandings and provide safe routes for emergency responders to reach these facilities.

Transit-Oriented Development (TOD) and Sustainable Transportation

Expand Walkability Standards: Require that all TOD projects include pedestrian pathways and bike lanes, creating communities where residents can rely less on cars. Walkable designs not only promote healthier lifestyles but also reduce vehicle emissions, aligning with New Jersey’s climate goals by encouraging low-emission forms of transport.
EV Charging Infrastructure: Require more parking spaces in new TOD developments to include EV charging stations. This will support the growing shift toward electric vehicles and contribute to reducing transportation emissions, making EV charging as accessible as traditional fueling options.
Public Transit Incentives: Include provisions for transit-related benefits, such as subsidized passes or shuttle services to the nearest transit hub, encouraging residents to choose public transit over personal vehicles. Enhanced transit access will not only improve mobility but also reduce traffic congestion, creating more sustainable urban spaces that benefit public health and the environment.

Immediate Renewable Energy and Energy Efficiency Integration

Require On-Site Renewable Energy: Mandate that large-scale commercial and residential developments cover at least 15% of their energy needs with on-site renewable sources, such as solar panels or geothermal systems. By incorporating renewables from the start, new developments can significantly cut carbon emissions and align with New Jersey’s targets for renewable energy growth.
Energy-Efficient Building Standards: Require that all new buildings meet energy efficiency standards such as LEED Silver or equivalent, with a focus on using energy-saving materials and sustainable designs. These standards reduce the operational energy needs of buildings, cutting costs for owners and tenants while supporting the state’s broader climate objectives.
Incentives for Net-Zero Projects: Introduce incentives for developments that achieve net-zero energy consumption. This can include tax credits, grant programs, or expedited permitting processes. By encouraging net-zero buildings, New Jersey can foster a culture of sustainable construction and pave the way for future developments that generate as much energy as they consume.

Environmental Justice and Overburdened Communities

Mandatory Environmental Impact Assessments: Require environmental and health impact assessments for developments within one mile of overburdened communities. This ensures that any potential risks to these communities are identified and mitigated from the outset, promoting equitable development that does not disproportionately harm vulnerable populations.
Community Engagement Requirements: Mandate comprehensive community engagement processes, such as public meetings and feedback sessions, for developments in environmental justice (EJ) areas. This inclusion gives local residents a voice in shaping developments that affect their lives, fostering trust and creating more responsive project outcomes.
Prioritize Funding for Climate Resilience in EJ Areas: Allocate targeted funding to support climate resilience projects in overburdened communities. By investing in these areas, New Jersey can help ensure that resilience measures reach those who need them most, reducing vulnerability to climate impacts and promoting environmental equity across the state.

Biodiversity and Ecosystem Conservation

Mandatory Wildlife Corridors and Buffer Zones: Enforce the establishment of wildlife corridors and buffer zones around protected habitats, minimizing disruptions to ecosystems and allowing species to thrive even as development progresses.
Native Plant Landscaping: To meet Stormwater Retention Standards, the NJDEP should require all new developments and redevelopments to use native plants in green stormwater infrastructure projects. Native plants support local biodiversity, reduce runoff, and enhance soil health, contributing to ecosystem stability and making landscapes more resilient to changing climate conditions.

Strengthen Wetlands and Riparian Zone Protections

Close Development Loopholes: Eliminate exemptions that permit development in sensitive wetlands and riparian areas. This helps ensure these natural features continue to function as flood buffers, water filtration systems, and habitats for diverse species.
Increase Buffer Zones: Mandate a minimum buffer of 300 feet for development around riparian zones and prohibit construction activities within these areas. Enhanced buffers protect water quality, maintain biodiversity, and reduce the risk of property damage from flooding.
Impervious Surface Removals: REAL proposes requiring the removal of existing impervious surfaces, where practicable, within 25 feet of wetlands under a special activity transition area waiver for redevelopment of a significantly disturbed area. This 25-foot zone should be increased to 300 feet to restore a natural riparian buffer zone.

Expanded Rationale: Wetlands and riparian zones are essential to flood mitigation, ecosystem health, and water quality. By strengthening protections and buffer requirements, REAL can support these ecosystems’ ability to perform their critical functions in the face of increasing environmental stressors.

Increased Accountability and Enforcement Mechanisms

Penalties for Non-Compliance: Increase financial penalties for projects that fail to meet NJREAL requirements and direct these funds toward local climate resilience initiatives. Strong penalties deter violations, incentivize compliance, and provide resources for critical adaptation projects, benefiting the broader community.

A Call for Immediate and Bold Action

NJ PACT REAL provides a framework for a resilient New Jersey, but to fully protect our future, CRAN urges the NJDEP to adopt these strengthened recommendations. Addressing transit access, renewable energy, environmental justice, public health, and ecosystem conservation, these changes will establish New Jersey as a leader in climate-resilient development. We thank the NJDEP for considering these recommendations and urge action that secures New Jersey’s future in a warming world.

[Your Name]

Member of Climate Revolution Action Network (CRAN)

[Your Address, optional]

Re: Public Comment on NJPACT REAL Regulations

Dear New Jersey Department of Environmental Protection,

As a young New Jersey resident and member of the Climate Revolution Action Network (CRAN), I am writing to express my strong support for the proposed NJREAL rules, which aim to modernize our state’s resilience to climate impacts. With growing climate challenges threatening New Jersey’s communities, it is critical that these rules are implemented to guide future development and safeguard the wellbeing of residents.

The recent events surrounding [specific issue, e.g., Hurricane Helene or another local event] underscore the urgency of these regulations. [Add personal story or observation here that ties the event to your community, your personal experience, or the impact on those you care about.] It is experiences like these that make it clear how vulnerable our infrastructure and communities are without updated, stringent guidelines.

Need for Pathos: Personal Connection

[Add a paragraph here about why this issue personally resonates with you. You might discuss witnessing flood damage, seeing ecosystems deteriorate, or even the emotional impact of knowing that future generations will face even greater risks. Share a personal reflection on what you’ve seen or felt, making sure it relates to the overall goals of the NJREAL rules.]

Closing Emotional Appeal

[Add a final paragraph / sentences with a call for action, expressing your hopes or fears if these regulations are or are not adopted. Emphasize the generational aspect, as young people like yourself will inherit the consequences of today’s choices. You may also touch on why the work of CRAN and similar organizations is crucial in this context.]

In closing, I urge the New Jersey Department of Environmental Protection to adopt these rules with an eye toward not just our current built environment, but also for the future we hope to build. Let us lead the way in establishing development practices that respect our natural resources, protect our communities, and inspire other states to follow our example.

Thank you for considering my comments on this critical issue.

Sincerely,