Good morning, my name is Rob Freudenberg and I am the Vice President for Energy & Environment at Regional Plan Association. Thank you for the opportunity to provide our comments on this important plan.

RPA is America’s oldest urban research and advocacy organization working to improve the health, equity, sustainability and prosperity of the New York-New Jersey-Connecticut metropolitan region. We pursue these goals by conducting independent research, planning, advocacy and vigorous public-engagement efforts. A cornerstone of our work is the development of long-range plans and policies to guide the region’s growth. Since the 1920s, RPA has produced three landmark plans for the region and recently completed a fourth plan, tackling the urgent challenges facing our region, including climate change, fiscal uncertainty and obstacles to opportunity.

In our 2017 4th Regional Plan, we highlighted the importance of the Meadowlands as an environmental treasure worthy of continued protection, restoration and remediation, a network of communities where hundreds of thousands of residents live, a major industrial and commercial employment center and tourist attraction and a critical convergence of transportation, energy and water infrastructure that literally keeps the region moving, powered and thriving.

So it is with great respect that we provide our comments on the Draft 2019 Hackensack Meadowlands District Master Plan Update (Draft 2019 Plan): Respect for those who have worked for decades to make this place the success it is today, and respect for those who continue to work to ensure a strong and resilient future ahead. And these are certainly not mutually exclusive parties.

We stand before you today in unfortunately uncertain times. In decades past, we could have some reasonable assurance that the goings on of everyday life today would be similar to the goings on of everyday life in the future. But because of a very tenuous and toxic political atmosphere and a climate crisis that threatens every aspect of our communities, environment and economy we cannot plan for the future today the way we have planned for the future in the past. We have entered uncharted territory.

After a thorough review of the Draft 2019 Plan, we commend the NJSEA for advancing the planning process after many years of silence. The Draft 2019 Plan is comprehensive and effective in covering all of the relevant elements and the addition of a section on resiliency was necessary and welcome. RPA offers the following comments, largely focused on the threats that climate change presents to the Meadowlands and the need for more proactive planning and policies.

Face the Climate Crisis Today

In 2005, the then New Jersey Meadowlands Commission released the Hackensack Meadowlands Floodplain Management Plan which laid out a comprehensive plan to manage flooding in the District. The Plan mentioned neither the words ​“climate change” nor ​“sea level rise.” Flooding has always been an issue in the District, but that plan included no discussion about how climate change could worsen the impacts already being felt at the time. Today, we know better and while we commend the inclusion of a section of this Draft 2019 Plan focused on the threats posed by climate change including the permanent flooding from sea level rise, we feel that it falls far short of what is needed at this time. The right time to start comprehensively planning for climate impacts has already passed, but the next best time to start is now, and this plan offers the best mechanism to do that. Adaptation is difficult because it literally is changing what we are currently doing. State and local leaders have a critical responsibility to advance these challenging conversations, take action and find a better future than the path we’re currently on.

Integrate Climate Resilience throughout the Plan & Beyond

The Draft 2019 Plan is correct in stating that ​“planning for resiliency cannot be conducted in a vacuum.” The management district of the Meadowlands is a unique model of governance that by nature takes a regional and long-term approach, with shared costs and opportunities. The impacts of climate change, in particular flooding from precipitation, storm surge and sea level rise, present an existential threat to Meadowlands communities, businesses, infrastructure and ecology. Rather than single out resilience and adaptation as a separate section, NJSEA should integrate climate resilience into all of the other sections of the Plan. Future land use, development and housing, environmental, economic and circulation decisions must factor in the threats from climate change and the final Master Plan should address that. Studying the exact approaches to resilience and adaptation can be done in the future, but a Master Plan’s purpose is to set the framework for decision making, and the decisions made today – from where additional development is encouraged to which wetlands are at risk and should be protected – will certainly be influenced by climate change.

Consider the Creation of a Climate Resilience Park

RPA’s 4th Regional Plan advanced the idea of a climate resilience park that expands its boundaries as sea levels rise. The park would also serve to educate about climate change and its impacts. Given the importance of the Meadowlands and the degree of climate impacts it will face, we recommend that this concept be pursued more broadly. With its unique governance structure, strong communities, thriving businesses and protected wetland ecosystems, the Meadowlands has the opportunity to showcase itself as an innovative leader in climate resilience. The final Master Plan should highlight that opportunity and take steps in that direction.

Work with the Port Authority to Phase Out Teterboro Airport

RPA’s 4th Regional Plan also called for the closure of Teterboro Airport, due to its strong vulnerability to permanent flooding from sea level rise. While this is the jurisdiction of the Port Authority of New York and New Jersey, NJSEA should factor in the potential of the airports closure and work closely with the Port Authority to develop a phased approach. RPA also strongly recommends that the Army Corps of Engineers reject permits to fill in wetlands to allow for the expansion of the airport. Not only does the airport have a limited shelf life that would make taxpayer investments into its expansion wasteful, removing critical wetland areas would likely exacerbate flooding in surrounding neighborhoods. The limited benefits of expansion are not worth the costs.

Expand Intermunicipal Tax Sharing to Develop an Adaptation Fund

The intermunicipal tax sharing approach in the Meadowlands District has been an innovative and effective way of balancing out benefits and costs. In order to adapt the District’s communities, businesses, infrastructure and environment to current and future climate impacts, a significant amount of funding will be required, which currently doesn’t exist. The final Master Plan should address this and should consider expanding the current tax sharing structure to raise additional funds to be spent on adaptation. NJSEA should also work closely with the NJ DEP and municipal leaders to determine the criteria for which projects should be funded.

In conclusion, we are thrilled that NJSEA is advancing this update to the Master Plan. Given the crisis of climate change, we think an integrated and more certain approach around climate adaptation is necessary. Climate change threatens the viability of this critical part of our region. Planning that finds the right approach to growth and – in some cases retreat – is necessary and it is critical that this plan lay out that approach. With the right approach, further investment and growth in the Meadowlands can be achieved, while ensuring the continued protection and expansion of important wetland habitat.

Thanks for the opportunity to submit these comments. We look forward to working closely with NJSEA to consider any of the approaches described above.