Why didn’t residents know about potential warehousing projects sooner?
There are state statutes (laws) in place that dictate the notification requirements for land-use applications. These rules pertain to an official application by a developer to present a proposal to build something on a particular piece of land. This application must be made to the town’s Joint Land Use Board at a Public Hearing. Once a developer files their official application in good order, they must be heard by the township within 45 days. Upon receiving a Hearing Date, the notification requirements call for the developer to send Certified Letters to all property owners within 200 feet of property being developed 10 days prior to the Hearing Date. The statute also requires the Hearing Date to be published in a local newspaper and the application must be noted on the Joint Land Use Board’s Agenda for that date. The township is required to be consistent in its notification process with every application that comes before the Joint Land Use Board, whether it be for a housing application or a major commercial project. There is no autonomy to publicly broadcast information about a project that is being discussed or has the potential to come before the township’s Joint Land Use Board at some point in the future, until a formal application is filed.
Why does the town have areas zoned to allow warehousing and when were they established?
All municipalities have Zoning Maps that identify the zoning of every property in the community. This is how a town dictates where the residential housing, commercial/retail, open & recreational space areas exist in their community. This is especially important for undeveloped areas, so everyone can see “what” potentially can be built in that area if the landowner decides to sell the land. In our case, we have followed a Smart Growth philosophy for many years that includes limiting the amount of housing development, retaining open space, and segregating the most intense commercial uses to areas on the fringes/edges of our township and in close proximity to major roads or interchanges. That is the case for the two areas in town where the zoning allows warehousing: our western border in the Tomlin Station Road area approaching the NJ Turnpike and our eastern border in the Richwood area at the Routes 322 & 55 interchange. These areas were designated as commercial areas allowing for all uses, including warehousing in the 1960’s (Tomlin) and 1990’s (Richwood).
Are these areas in our town suitable for warehouse zoning?
The industry and planning standards related to the ideal locations for warehouse complexes include:
- Within 75 miles (or 90 minutes) from a port
- Close proximity to highway networks, preferably state systems
- Near the borders/edges of the host community
The Tomlin Station and Richwood areas are suitable based on our proximity to the growing South Jersey port system (Salem, Paulsboro, Camden) and the Philadelphia port. Both areas are located close to major highway access, and both are near the geographic borders of our community.
Can any other type of commercial development occur in the locations that are zoned for warehousing?
Yes, all types of commercial uses are permitted in these areas, up to and including warehousing. Other, less intensive uses have been sought in these locations for years, but that has not occurred.
There were changes made in the zoning of the Tomlin Station Road area in the last few years. What was that about?
There were a series of zoning steps taken since 2018 to protect that area from an undesirable “by right” warehouse project being developed there. A “by right” application is one that meets all the zoning requirements of the property the developer is seeking to build on. If they meet all the standards of the zoning, with no variances requested, they can expect to receive an approval from the Joint Land Use Board. As noted above, the Tomlin Station Road area has been zoned to allow warehousing since the 1960’s. If a “by right” warehouse application was to be submitted, it would likely be approved with the zoning standards that traditionally exist in a commercial zone.
To avoid such a “by right” application, the first step we took was to designate the entire area a Redevelopment Area in 2018. This was an attempt to help the Tomlin Station Commerce Center owner market that property for the desired, mid-size commercial use he had been seeking for the prior decade. That was unsuccessful. Recognizing the upswing in the warehousing market in the region, we took additional defensive steps to ensure that we did not end up with the “worst version/by right” warehouses we now see being built on Route 322 approaching the Commodore Barry Bridge. To accomplish this, we had our Planners and Engineers design a Redevelopment Plan that contained more stringent guidelines if a warehousing developer sought to build in that area. These more stringent guidelines required intense buffering, berming and landscape packages, stricter light and sound protocols, building design feature requirements that softened the look of the building, as well as project size limitations that are lower than the traditional zoning would allow.
We went even further to prevent the “worst version” warehouse application with the underlying zoning changes we made in 2020 and 2021. These steps were not intended to eliminate warehousing from these areas zoned for it. The intent was to reduce the possibility of a warehouse project advancing under traditional zoning. The township still needed the commercial tax revenue from this area and warehousing had become the dominant suitor, considering traditional commercial development had not materialized. This left the Redevelopment path as the only option for a warehouse developer seeking to make an application in that area. This would give the town the controls it sought on behalf of its residents, especially those in close proximity to any project.
Does a community’s crime rate increase related to a warehouse project being built there?
Most of the data related to crime rates going up in conjunction with a warehouse being built in a community pertains to urban areas. In the past, warehouse projects were developed by repurposing vacant buildings in or near or urban areas. These tended to be marginalized regions with higher-than-normal crime rates to begin with. There is data showing that crime rates accelerated slightly in these urban areas. The most significant increases, however, occurred if the warehouse eventually became vacant.
More recently, as the warehouse market has expanded into suburban and more rural areas, a significant increase in the crime rate of that community has not been evidenced. Locally, Logan Township has been a warehouse mecca in the region for many years, but it has a much lower crime rate, across the board, than the national average. Without the urban backdrop and the possibility of abandoned buildings, crime is not an issue. The workers in the warehouses in South Jersey are not considered potential perpetrators with an average salary of nearly $60,000.
In a December 2020 video, the mayor stated that Harrison was “not selling out in the commercial ratable chase and building warehouses everywhere.” Why did that change two years later?
As the warehousing market began to emerge in our region, we spent the years prior to December of 2020 avoiding the warehousing surge by saying “no” to developers expressing interest in areas not zoned for it. We have that ability (to say “no”) when a developer expresses an interest in a property where they would need a variance to build a warehouse. During this time, we took the defensive zoning and Redevelopment actions referenced above to protect areas that had long been zoned for warehousing, like the Tomlin Station Road area. We did this to ensure our ability to control what a project would look and operate like should a warehouse developer seek to move forward there. The video statement expressed the factual history at that point. We had chosen NOT to “sell out” by granting variances to allow warehousing to be built where the zoning did not allow it. We had also taken the defensive actions referenced above to curtail warehousing being built under the traditional zoning requirements that would have allowed for development similar to the ugly warehousing projects we see being built west of us on Route 322. Hence the December 2020 statement. By the end of 2022, the warehousing developers that had purchased the properties in the Tomlin Station Road area recognized the Redevelopment measures we had put in place and put forth plans that met the higher standards we had put in place.
What would be considered a positive or beneficial impact of having a warehouse in a community?
Beyond the obvious revenue impact, any business that immediately adds hundreds of good paying jobs to a community has a positive ripple effect on commerce in that community. Workers often spend money in the town where they work by using the professional services there, patronizing their shops and eating in the restaurants. Hundreds of new workers in a town can even spur an expansion of the existing business footprint there. That said, none of that impact was quantified or considered in the Study.
How do they calculate the number of vehicles that will enter and leave a warehouse project?
The process calls for the developer to disclose the size of the proposed building and the number of loading docks included to the NJ Department of Transportation (DOT). Based on that information, the DOT uses the Federal Commerce Guidelines to determine the number of vehicles a project of that size will generate. The developer must use that data in the traffic studies they submit. The developer has no say or control over the number of vehicles their plan must show. They are required to base their studies on the number given to them by the DOT.
Why are they still building warehouses in NJ when many of them are vacant?
That is actually a falsehood. In September of 2022, The Office of Planning Advocacy outlined the demand and strategic geographic position of our region and its role in the supply chain in the Northeast. According to a 2021 report by the CoStar Group, an industry leader in commercial real estate data and information, almost 30 million square feet of space would be built in New Jersey in the next several years. This is based on the need created by the sustained growth and traffic at South Jersey’s ports, including Camden, Paulsboro, and Salem. The reality is that the vacancy rate for warehouses in New Jersey is less than 2%, with demand increasing by 30% in each of the last two years.
Why is there suddenly such a substantial tax increase related to this warehouse decision?
The tax increase related to our decision on warehousing has nothing to do with warehousing directly. The reality is there have been two major areas dedicated to commercial zoning in our town for decades. Neither area has produced the anticipated revenue over the last 10-15 years. They are the Richwood area and the Tomlin Station Commerce Center area.
During this last decade, the Township Committee decided to limit the property tax increases on our residents as we waited for those commercial tax revenues to materialize. We have maintained one of the lowest Tax Rates in Gloucester County this entire time, but the commercial development world has changed in the last decade. Brick ‘n mortar retail development is no longer a realistic consideration, and the warehousing demand is driving the commercial development market in our region now. If we do not allow some of that development in the designated areas in Harrison Township, there is no other option but to bring the local Tax Rate up to the required level to maintain our municipal services to our residents. This changing landscape and a decision to eliminate any warehousing development would leave no option but to pass the burden onto our residents.
In hindsight, the only thing that we could have done differently would have been to increase local property taxes at a higher rate over the last decade, assuming that Richwood and the Tomlin Station Road area were never going to produce the revenue our Master Plan expected from them. That would have resulted in our current Tax Rate being about 33% higher than it is right now, ranking us around 17th in the county versus having the 4th lowest Tax Rate in the county. Our avoidance of that path for all these years is the reason we now face this decision on warehousing with such significant tax implications.
Why did Township Committee make this decision without further input from the public?
The township leadership took the last two months conducting an internal evaluation of our Budget & Tax Rate history, our staffing needs (now and going forward) and the revenue required to meet those needs. Those details and that data are contained in the Study just released. The fiscal impact defined in this Study would cause a major hardship for many residents in our community. Additional input would not change these facts and it was clear to our leadership team that there was no other path forward at this moment. The Township Committee members agreed on this unanimously, as they did that there will be an annual review of the zoning and tax policy going forward.
SPECIFIC QUESTIONS ABOUT THE KINGS LANDING WAREHOUSE PROJECT:
Harrison’s Joint Land Use Board (JLUB) voted against the warehouse project – what is the status of that project since it was already approved in Woolwich?
The developer has the right, and is pursuing legal action, to have the JLUB’s denial overturned.
What is the current revenue from that land compared to revenue the township would get from the Kings Landing warehouse project?
The land is currently farmed and pays the township less than $2,000 a year in taxes. The warehousing project had a PILOT (Payment In Lieu Of Taxes) in place that called for an annual payment of $1.6 million that would accelerate every five years, based on the new assessed value. In addition to the PILOT payment, the warehouse project would be required to pay the Land Tax, which would be approximately $256,000 annually. The township’s portion of that payment would be about $43,000.
How does the PILOT impact the revenue the township will receive from this project versus a traditional tax payment?
The township keeps 95% of the PILOT payment after the County is allotted 5% of that total payment. That equates to $1.52 million (or $1,520,000) per year for 30 years. The township’s portion of a traditional tax payment on that project would be about $300,000 annually. After factoring in the incremental increases every five years (mentioned above), that amounts to about a $50 million increase in revenue to the township over 30 years when comparing the PILOT payment to a traditional tax payment in this case.
Where were the entrances and exits to that project located?
There was one entrance/exit point planned for this project, located at a signalized intersection that would be created on Route 322 about halfway between Tomlin Station Road and the light at the entrance to the NJ Turnpike. There is no access from Tomlin Station Road.
Woolwich already approved this project – what would happen to the project if the Harrison portion is not part of it?
The assumption is that the developer would amend the Woolwich plan to fit more square footage there and move forward with the project with the same or similar entrance/exit location.
There was concern expressed during the Public Hearing about both the Environmental and Traffic Impact Study provided. Who oversees that and can the township require more details or information?
Traffic Studies and related road or infrastructure improvements fall under the jurisdiction of the DOT (Department of Transportation) and the Gloucester County Engineering Department, depending on what road the project’s entrance/exit lies on. In this case, Route 322 is a state road that Gloucester County has jurisdiction over in that area. Therefore, The Gloucester County Engineering Department is the “superseding agency” that has jurisdiction over all the traffic approvals.
All required Environmental Studies fall under the jurisdiction of the DEP (Department of Environmental Protection). As the superseding agency, the NJ DEP has total authority on all environmental and emission/pollution issues. The good news on that front is that NJ is known for having some of the strictest environmental requirements and oversight in the nation. Local municipalities cannot and do not supersede these authorities and therefore cannot request or require standards higher than these agencies have in place.