Staff outlines municipal housing‑plan reviews under Fair Housing Act reforms; Jackson Township plan raises staff concerns

Staff provided an update on Sept. 26 about municipal housing plans and how recent state Fair Housing Act changes and the Affordable Housing Dispute Resolution Program are affecting Pinelands municipalities.

Brad (staff) said the revised state process required towns to adopt a binding resolution and submit housing plans by June 30, with an August 31 challenge window and a December 31 deadline tied to the statutory schedule. He reported that 39 municipalities adopted the initial binding resolution while 14 did not, and that 21 housing plans have been submitted to the commission and have received staff letters (substantial‑issue or incomplete) as appropriate.

Staff said roughly half of submitted plans included municipal adjustments (vacant‑land or durational adjustments) that either defer or reduce the number of housing units the municipality will plan to provide; Brad said the aggregate number of deferred or unmet units across Pinelands municipalities was a little over 1,000 units, representing about 20% of the total fourth‑round prospective need for the Pinelands municipalities. He cautioned that many municipalities are split between Pinelands and non‑Pinelands areas, so not all identified units would be sited inside the Pinelands boundary.

Brad walked through proposed sites and noted the greatest staff concern was Jackson Township’s adopted plan, which includes four sites within the Pinelands area (two in regional growth areas, one in a rural development area and one in a village). Staff said they have not yet received Jackson’s plan materials for internal review and are awaiting engagement with the municipality to resolve outstanding questions.

Staff also described coordination with the Fair Share Housing Center and said the volume of challenges and requests for additional information may strain the program’s short statutory deadlines. Brad emphasized that the commission’s review evaluates consistency with CMP standards and does not substitute for the state program’s legal review of affordability compliance.

Next steps: staff will continue reviewing submitted plans, issue incomplete or substantial‑issue letters where appropriate, work with municipalities on draft implementing ordinances and redevelopment plans (Monroe, Hamilton, Galloway and Hammonton identified as near‑term cases), and engage with Jackson Township on the four Pinelands sites.