Client: Skylands Preservation Alliance
EELC represents the Skylands Preservation Alliance in this matter of a proposed million plus square feet warehouse with daily traffic from 300 employees and numerous tractor trailers, located on the Tobias Farm, across from the Musconetcong River. This project would negatively impact Bloomsbury and Franklin Township with increased traffic, increased emissions, toxic runoff into the river, and the industrialization of farmland.
On Dec. 22, 2020, EELC filed a motion to supplement the record with a letter that was issued Dec. 21 from the National Park Service (“NPS”) to the Environmental Protection Agency (“EPA”) which concerns the very same water feature and property that is at issue in this pending appeal. The relevance of this letter from the NPS to the EPA to the instant matter is unquestionable: it asserts that “The NPS believes the rigorous methods the USEPA uses to identify headwater streams, wetlands and transition areas found in its hydrologic assessment manual were not followed by the NJDEP.”
On Dec. 28, 2020, Yaraghi filed opposition, and On Jan. 6, 2021, the State filed opposition to SPA’s motion to get the letter from NPS into the record. The Motion denied on Jan. 21.
Related Content: Initial Brief