To the Chairman and Members of the Zoning Board:

RE: ZBA2024-5 St. Mina Coptic Orthodox Church, 134 State Highway 34, Block 17, Lot 12

The applicant seeks Preliminary and Final Site Plan Approval to construct a 63,977sf recreational facility and athletic turf field on this property. This facility is not a permitted use in the R40B (residential and agricultural district) zone and requires the granting of a D(1) variance. The R40-B zone generally allows for 15% impervious coverage whereas this plan calls for 23.6%. This plan is not consistent with Holmdel’s Master Plan and should not be approved.   

This property’s southeastern border is at the headwaters of the Willow Brook, a major tributary of the Swimming River Reservoir which services more than half of Monmouth County residents. Holmdel’s overstressed watershed lands that supply the streams and groundwater serving our reservoir already have far too much impervious coverage. The watershed of the Willow Brook currently has 15.6% impervious coverage. Any watershed with more than 10% is considered impaired. Further degradation should be avoided at all costs. 

In accordance with the mission of Citizens for Informed Land Use (CILU) to protect our water supply and quality of life, we have the following concerns regarding the proposal for this site:

Concern # 1 Turf Fields

There are many studies pointing to the environmental impact of artificial turf fields. We know from the last meeting that you understand these issues, particularly regarding exposure to the watershed from toxins, PFAs (forever chemicals), and microplastics produced by this type of field.  Many of the chemicals in these fields are water soluble or of such fine grain that they will not be caught in the proposed turf field barriers and instead be piped out to the stormwater basins to infiltrate the ground water feeding into the Willow Brook. We need to keep this toxic run-off out of our water supply. 

At the last Zoning Board meeting we also referred to the Mount Sinai Medical Center study which indicated the potential health risks to children playing on artificial turf, such as respiratory issues, bacterial infections, injuries, and possible risk of cancer.

Considering the health and environmental risks, we hope that you will insist on the soccer field remaining in natural cover.

Concern #2 18 Acre Farm Field

The developer is requesting the Zoning Board grant both a use variance and significantly increased impervious coverage for the recreational facility. In an effort to protect the watershed, we strongly recommend, as a condition of approval, that the 18-acre farm field to the west of the church (shown on the developer's site plan as an open field with stream corridor buffer) be permanently restricted as a conservation, agricultural, or drainage easement in the deed.

These 18 acres, which drain directly into the Willow Brook, were included in the calculation of the impervious coverage to equal 23.6%. This was necessary to balance the impervious coverage of the massive 50,131sf footprint of the proposed recreational facility that would be added to the coverage of the existing church and parking lots. 

This may be Holmdel’s only opportunity to protect this land critical to the watershed. The applicant has used only 23.6% of the 28% allowed for a church; they have roughly 65,000 sf of potential impervious coverage left for future use. This acre and a half of potential impervious coverage (approximately equal in size to the recreational facility for which they are now requesting a zoning variance) is critical for our water supply.

As the Board considers approval of the non-permitted use in this zone, we ask you to exercise your prerogative to require a deed restriction for this 18 acre farm field.

Concern # 3 Wastewater Treatment System.

The plan calls for a wastewater treatment plant with six disposal fields that are wedged within the required easement between the proposed recreational facility and the backyard fences of the Tiberon Drive homeowners.  We would like to better understand why an 8,600 gallon per day package plant should be placed so close to the homes of the adjacent neighborhood. Will this placement cause long-term maintenance problems? Will there be noise or saturation issues for Tiberon Drive homeowners?  

Package plants have been used as a fulcrum for unanticipated development. This plan’s wastewater treatment plant poses such a significant intrusion on our watershed that it requires an amendment of the Monmouth County Water Quality Management Plan (WQMP), as per NJDEP regulations. This additional requirement should not be taken lightly. 

Given the massive footprint of the proposed recreational facility, the use of toxic artificial turf, and the project’s potential impact on the water supply and quality of life for Holmdel residents, we hope you will take our concerns into consideration. 

Sincerely,

The CILU Board