The Dollars and Cents of Health & Safety Programs

New Jersey Adopts Updated Guidance on Warehouse Development

New Jersey State Planning Commission’s Office of Planning Advocacy recently issued new guidance encouraging a regional approach to the planning and siting of new warehouses and provides municipalities factors to consider when developing or updating a Master Plan and reviewing applications, land use, and development requirements.

The guidance was developed following months of research, input gathering and listening sessions with stakeholders such as municipal officials, real estate professionals, business organizations and community groups.

New Jersey is a “home rule” state and as such, this guidance amounts to recommendations rather than enforceable mandates.  The Office of Planning Advocacy stated, “As land-use planning and development review occur predominantly at the local level, their approach has been to provide technical assistance and guidance within the context of sound planning and policy that balances competing needs –including protecting important resources and impacted communities, while ensuring economic growth and viability.”

Why Now?

New Jersey, already a highly developed state, is a much-desired state for logistics hubs because of its proximity to seaports, airports and a large population as online shopping continues to require more logistics centers to bring shipments to doorsteps. According to a 2021 report by Costar, more than 100 warehouses totaling 26.5 million square feet of rentable space are due to be built in New Jersey over the next three years alone. These warehouse developments raise objections from residents and environmental groups about the noise, traffic and pollution these projects may generate. There are concerns that large-scale regional warehousing, can if not properly sited and scaled, result in significant negative impacts, from the intensive consumption of undeveloped land to the degradation of habitat, air and water resources, quality of life, public health, safety, infrastructure, and transportation networks.

Updating Master Plans and Land Use and Zoning Regulations

The guidance aims to help local governments update master plans, zoning and development standards; review development applications; and take a regional approach to warehouse projects. The guidance, in part, essentially says that local municipalities should update their zoning and master plans to adopt to a new era of unprecedented warehouse development. Some old municipal regulations broadly permit industrial development in designated parts of town. Currently, most town ordinances don’t distinguish between different types of industrial properties or which would be appropriate for different areas.

Warehouse development comes in many shapes and sizes, each serving a specific role depending on the nature of the operations, and constraints of the supply chains they are supporting.  The guidance suggests zoning should evolve to keep up with the changing variety of uses and trends (including definitions) as the differences could mean dramatically different impacts and outcomes, and whether a project is compatible with a site and beneficial to a community. Land use regulations should not simply lump “general industrial” or “warehouse” together, as different types can be profoundly different, entailing different impacts, which warrant greater specificity as to appropriate siting and design standards where permitted.

From the standpoint of a warehouse distribution center/facility’s size, the guidance suggests the following be used:

  • Major Distribution center – large-scale regional and/or interstate distribution facility having a minimum gross floor area from 500,000 to more than 1.5 million square feet.
  • Large Fulfillment center – a large format regional fulfillment facility having a minimum gross floor area from 150,000 to more than 500,000 square feet. In this category, a medium-sized fulfillment center would average between 250,000 to 350,000 square feet.
  • Last-mile Fulfillment center – a smaller local or area fulfillment center/facility or station that primarily serves local markets (roughly the same function as retail shopping centers) having a minimum gross floor area from 50,000 to more than 150,000 square feet. This category could include micro/small fulfillment centers of 3,000 to more than 25,000 square feet.


Zoning Conflicts and Other Considerations

The guidance suggests municipalities mitigate and avoid conflicts with other uses, sensitive populations and receptors by locating large warehouses away from residential areas/neighborhoods, downtown commercial/retail areas and main streets, schools, daycare centers, places of worship, hospitals, overburdened communities, scenic corridors and historic districts, important public and civic outdoor spaces, and recreational facilities.

The guidance includes details about additional considerations municipalities should take into consideration including:

  • Types of warehouses
  • Municipal considerations
  • Redevelopment and brownfields
  • Public health and overburdened communities
  • Transportation, traffic and road safety
  • Sustainable design
  • Mitigation best practices
  • Community involvement and public engagement
  • Regional approaches
  • Special resource area considerations

What Role do NJ State Agencies Have?

Once the local reviewing board approves a development proposal, a project must still comply with all county and State agency requirements. In many cases, final site plan approvals are conditioned on an applicant meeting all outside agency requirements and obtaining all necessary permit approvals.

Many rules implemented by the New Jersey Department of Environmental Protection, Division of Land Resource Protection (DLRP), and its more-recently created Watershed and Land Management Program (WLM), will have a direct and measurable impact on the layout, design, and feasibility of a project.

Environmental site constraints (e.g., Freshwater Wetlands, Flood Hazard Areas, etc.), location (e.g., within the Coastal Zone Management Area, etc.), and any encroachments into regulated areas may affect the final design of the project. In addition, several environmental land use, regulatory programs, and rules within DEP have been or are in the process of being modernized to respond to environmental justice and climate change concerns by considering risks such as the sea-level rise and chronic flooding. These updates also aim to facilitate climate resilience by supporting green infrastructure and strengthening air pollution rules to help reduce future greenhouse gas emissions, particularly in overburdened communities.

With these changes in mind, warehouse development applicants should be encouraged to request a pre-application conference with the DLRP at the conceptual stage of a project’s site plan process to understand what permit approvals may be necessary, clarify design conflicts, determine regulatory compliance, and determine if any unforeseen regulatory issues might be discovered. The DLRP may also provide recommendations for design changes that would help to minimize disturbance in environmentally sensitive areas and help the project achieve compliance with the regulations.


How Equity Can Help

Municipal and County Government Clients

Our team of professional planners can help municipal and county governments with updating masterplans, conducting zoning analysis, as well as analyzing the environmental impacts of various development scenarios to determine the best locations for the zoning/rezoning for the different types of industrial sites that the guidance suggests.


Owner & Developer Clients

Equity offers multiple solutions under one roof for your warehouse project. We can analyze environmental impacts of a project, assist with zoning variance and other discretionary actions, obtain environmental permits including wetlands, assist you in navigating brownfield cleanups – including funding options to help offset the clean up cost, and manage the remediation process.

About Equity Environmental Engineering

Equity is an award winning environmental consulting firm with offices in New York City and New Jersey. We offer a variety of services including Environmental Engineering; Site Assessments, Investigations and Remediation; Planning, Land-Use & Zoning; Health & Safety; Wetlands; Noise & Acoustic Services; and Traffic Planning.

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