Environmental Commission Letter to Planning Board Regarding The Villa Hotel Application July 2014
TO: Mountain Lakes Planning Board
FROM: Mountain Lakes Environmental Commission
DATE: July 15, 2014
RE: Villa Hotel Application
This forwards our comments regarding Application 14-257 from Evergreen Realty Group for a new hotel at the Villa site on Route 46.
We do not feel that we have adequate information to be able to fully comment upon this application. Our primary concerns about new development continue to be in regards to water usage.
Outstanding questions/points in regards to water usage:
- We would like to verify that our wells refill to firm capacity expectations in the absence of well #5. When Council approved the resolution to allow a hotel within the Zone, a firm capacity test was stipulated by Councilman Albergo. We now understand that data exists that may make such a test unnecessary. We have not been able to obtain this data but feel that the Planning Board should request it.
- The forecasted water usage of 75 gpd is low versus standards we have found online. According to the American Hotel and Lodging Association, the average hotel consumers about 209 gallons of water per day per occupied room. (facilitiesnet.com/plumbingrestrooms/article/water-conservation-case-studies). Forecasted usage is also much below Mr. Ryden’s average hotel water usage (1.4 mgm) as stipulated in his memo of 8/19/13. If the developer is achieving this low usage rate by doing offsite laundry, we would recommend approval only upon the stipulation that laundry never be allowed onsite. If it is not legally possible to make this requirement, we believe that allocating 1.4MM gallons out of our current 2MM gallon surplus is too risky given the near certainty of future periodic droughts.
- The forecasted water usage of the restaurant is 10 gpd per seat, however, a Baseline Water Consumption Worksheet located at infohouse.p2ric.org estimates a standard restaurant’s usage at 35 gpd per seat. It is also unclear why a restaurant is forecast to use half the water of a banquet customer. This is not our area of expertise and we would recommend that these numbers be verified.
- The plans call for a 43 x 30 foot spa. Spas use a substantial amount of water and we recommend that water usage estimates be requested for this addition. There is no mention of a pool. We recommend that wording that prohibits pool construction be added to any site plan approval.
- The Borough is allocated 30 million gallons of water per month. Mr. Ryden’s memo of 8/19/13 states that “we have had 30 MG months in the recent past.” We would like to review Borough monthly water usage to understand how often this happens and what the impact of adding hotel demand on top of existing demand will be.
- Drought is not uncommon in New Jersey. Given that the margin for error is fairly small (2 million gpm unallocated), we would recommend that the Borough develop a water conservation plan as well as a back up plan should two Borough wells be down. We would request that both plans be complete before site application approval.
Secondly, we would recommend that the project live within existing setbacks in order to protect the character of Borough aesthetics and neighbors’ rights. Lastly we note that stormwater is currently treated at the existing facility. We would recommend asking for verification of system maintenance and want to make sure that treated water be recharged to the aquifer.
Historical Water Usage/Month Mountain Lakes, NJ
Environmental Commission of Mountain Lakes Statement to Council April 2014
The Environmental Commission has concerns about the possible risk to the water supply with the proposed 130 room development of a hotel at the Villa on Route 46 and the Boulevard. We currently reside in HUC-14 – the highest water deficit area as defined by the Highlands Regional Master Plan. The Plan’s calculations show a regional deficit of up to 7.1 million gallons per day (see attachment 1).
Secondly, although this project might meet on paper the Firm Capacity requirements as delineated by the NJDEP, we believe that our requirement calculation may be based upon untested assumptions about non-core well capacity. A 2009 LWV study indicated that our ‘Firm Capacity’ calculation relies upon the assumption that Well No. 2, located on Laurel Hill, can produce sufficient water to act as a viable back up to well #5. The League study suggests, however, that historically, this bedrock well has produced only ‘one –tenth’ of the firm capacity number used in the calculation.
If ML had sufficient firm capacity it would seem that we could use water from Borough wells during times when well #5 is shut down. In the summer of 2011, however, the Borough chose to purchase water from Parsippany rather than source internally.
If Mountain Lakes decides to allow water intensive development like a hotel, the EC would recommend two courses of action. First: we should test the assumptions within the firm capacity calculation and shut down well #5 to see if sufficient capacity exists to fill the tanks. Secondly, we should develop a borough-wide water conservation plan that could be deployed during a time of drought.
In closing, great care must be taken to ensure the water supply. We would like to see Mountain Lakes living up to our obligations within the Highlands Regional Master Plan to work to decrease water deficits – not contribute to them. We would also like to see an economically healthy business corridor with adequate water to fund a variety of new businesses. We look forward to being an active partner in working with the Council to achieve sustainable growth.