Affordable housing or developer giveaway?
Gov. Mikie Sherrill’s housing plan risks turning a housing crisis into a sprawl program.
I grew up believing affordable housing and environmental protection belong in the same sentence.
I was born in Newark and raised on the Newark-Hillside border in federally built workers’ housing. My father was a union factory worker and civil rights activist. My grandparents were labor radicals who held rent parties to help neighbors facing eviction. Housing was not an academic issue. It was about whether working people could keep a roof over their heads.
But I also learned what happens when working people get housing without environmental protection. Our home was down the street from an operating foundry. The pollution was so thick you could write your name in the soot on cars. The local stream was contaminated with industrial pollution. I remember that throwing a match into the water could make it flare.
Then I spent summers at Camp Midvale in Ringwood. It was a different world. You could breathe the air, swim in the streams, and drink the water. The camp brought together trade unionists, civil rights activists, farmworkers and conservationists. People including James Baldwin, Cesar Chavez, Joan Baez and Ossie Davis came through.
That contrast shaped my environmental philosophy: Working people should never have to choose between affordable housing and a healthy environment. I was also a founder of the Coalition for Affordable Housing and the Environment, which sought to advance both goals.
The New Jersey Developers’ great land rush
That is why I am concerned about Gov. Mikie Sherrill’s housing plan. New Jersey desperately needs affordable homes. But the governor’s September 2026 plan risks turning a housing crisis into a land rush for developers.
The plan calls for 350,000 additional homes over the next decade. That is a statewide housing production goal, not 350,000 income-restricted affordable homes. It combines affordable, workforce, and market-rate housing while doubling the target for homes on state-owned land from 20,000 to 40,000. More construction does not automatically mean more affordability.
The problem is that this is government by press release, without a real study or plan that includes public scrutiny or hearings. The question is whether we are building homes working people can afford or creating more luxury development opportunities for private interests in the name of affordability. Is this a land giveaway and a developer’s dream?
From saving a million acres to paving a million acres
New Jersey is already the most developed state in the nation. About 40% of our land is developed. We are more densely populated per square mile than India, China, or Japan. At New Jersey’s population density, you could fit the entire population of the United States into Texas.
The only thing denser may be the politicians in Trenton who don’t get it.
Affordable housing is becoming the developer’s sales pitch
The central problem is that this plan relies heavily on private development incentives. New Jersey’s inclusionary housing system allows increased density to make private affordable housing projects economically viable. Under the four-to-one model at issue here, an affordable unit can be accompanied by four market-rate units.
That means the affordable unit can become the ticket to a much larger, more profitable development. The developer gets additional building capacity and can get around a town’s zoning restrictions, while the public is told this will lead to affordable housing. The concern is even greater when public land is involved.
It is trickle-down economics with a zoning density bonus.
The issue is not whether affordable housing matters. It does. The issue is whether we are using affordable housing to justify excessive density, public subsidies, and environmental damage while allowing developers to capture much of the financial upside.
Workforce housing and “missing middle” housing are not automatically affordable for low-income families. A market-rate apartment does not become affordable because a press release gives it a friendlier name. Only 10% of the housing is actually designated for low-income households, with another 10% for moderate-income households, often at rents close to market rates.
If the state is serious about affordability, it should prioritize permanently affordable homes, nonprofit and public development, and enforceable affordability requirements. Instead of relying so heavily on private developers, why not use public land to build 100% affordable housing for working families, seniors, veterans, and people with disabilities?
Public land should serve the public, not become a private real estate portfolio.
State land: Public property, private deals
The plan to build as many as 40,000 to 42,000 homes on 3,200 acres of state-owned land raises serious questions about transparency and accountability. The proposal seems to have been written by the New Jersey Builders Association.
Who selects the developers? How are land values and lease terms established? What public subsidies are involved? Who negotiates the deals? How are environmental constraints and local concerns addressed?
When the state controls the land, structures the development, and oversees permitting, there is at least the appearance of a conflict that demands independent oversight. The potential for insider deals and pay-to-play arrangements is troubling.
Redevelopment laws can give public entities substantial discretion in assembling projects and selecting development partners. That discretion can be abused. A system that distributes valuable public land and development rights must be designed to prevent insider arrangements and pay-to-play, not leave residents hoping no one abuses the process.
That makes transparent competition, public disclosure and safeguards against political favoritism essential. The public must be able to see who competes, who wins, and why. Yet provisions for public oversight and transparency appear to be missing from the proposal.
Using state land to bypass local zoning and meaningful community review would make matters worse. Local governments should not lose their voice simply because Trenton owns the property. That could lead to more development in areas which are already overdeveloped.
The state cannot be the landowner, dealmaker, development promoter, and permit overseer without extraordinary transparency and independent checks. Otherwise, the public risks providing the land and infrastructure while private developers collect the profits. That is not public-interest housing policy. It is a potential developer giveaway.
Forty thousand units mean a new city
The scale of this proposal demands a serious accounting of its environmental and infrastructure impacts.
Using an estimate of 2.5 people per unit, 40,000 homes could mean 100,000 residents on five square miles. That is the combined population of Hackensack and Perth Amboy at more than double the density. At 75 gallons of wastewater per person per day, that is potentially 7.5 million gallons of sewage daily. At up to 100 gallons of drinking water per person per day, demand could reach 10 million gallons a day.
These are planning estimates, not site-specific engineering findings, and they may underestimate the impacts. They illustrate the magnitude of what must be evaluated before development is approved, including the potential for overdevelopment and sprawl.
Then there are the cars. At roughly 1.5 to two parking spaces per unit, depending on the housing mix and applicable standards, 40,000 homes could require 60,000 to 80,000 parking spaces.
That is a new city’s worth of people, water demand, sewage, and vehicles. Where will the roads, schools, emergency services, electric capacity, and sewage treatment come from? What about stormwater management? Who will pay to expand the infrastructure?
A developer can build a road entrance or connect to a sewer line. That does not fix the traffic bottleneck a mile away or expand a wastewater plant already near capacity. The biggest infrastructure problems are often outside the property line, and the public can end up paying for them.
The state needs independent, site-specific assessments of water, sewer capacity, roads, stormwater, schools, emergency services, and electricity before approvals, not after the bulldozers arrive.
Transit-oriented development is not a free pass
Building near transit can be smart growth. But putting an apartment building near a train station does not make hundreds of cars disappear.
People still need to get to jobs that are nowhere near a station, take children to school, buy groceries, visit doctors, and care for family. A half-mile circle on a planning map does not describe how people actually travel.
The roads still count. The parking still counts. The traffic and air pollution still count. A study of Metropark in Edison found that 90% of commuters still drove.
A train station is not an environmental absolution. The state must examine real travel patterns, parking demand, and road capacity instead of calling every dense project near transit sustainable. Otherwise, transit-oriented development becomes a rationalization for higher density and overdevelopment without necessarily delivering the promised reduction in driving.
Flooding does not stop at the property line
New Jersey is already dealing with destructive flooding. Every forest cleared, wetland filled, and acre paved changes how rain moves through a watershed. The state has a chronic flooding problem tied to overdevelopment and the loss of open space. How will all this new development affect that problem?
A roof sends water toward a drain. A parking lot sends runoff into a pipe. A road sends water toward a stream. When enough land is developed, the water ends up somewhere else, often in another neighborhood or basement.
A detention basin can handle some stormwater, but it cannot stop a flood. The central question is whether downstream properties and the watershed can handle the additional runoff. What is the cumulative impact of a project, both locally and downstream, when combined with all the development upstream?
That is especially important on state-owned sites containing wetlands, steep slopes, streams, forests, or flood-prone land. If roughly 3,200 acres are being considered for 40,000 homes, the gross density would average about 12.5 homes per acre. That works out to 20,000 people per square mile, denser than Jersey City.
But gross density can hide the real story. In reality, the net density could be closer to 20 units per acre. Once wetlands, slopes, buffers, roads, and stormwater facilities are excluded, the developable acreage shrinks and the net density rises.
You cannot make a wetland buildable by changing the label on a map or make a floodplain safe by packing more units onto the remaining land.
Many of the communities the state is looking at for transit villages, including Rahway, Bound Brook and Lincoln Park, already have serious flooding problems. Many are also overdeveloped. What will be the impact of these very high-density proposals?
The state must disclose the actual developable acreage, net density, and environmental constraints for every site. It must evaluate cumulative flooding impacts, not simply whether a developer can meet a minimum stormwater requirement on its own property.
The REAL problem: More flooding
The concern is compounded by the administration’s decision to extend the legacy period for New Jersey’s REAL environmental rules through July 20, 2027, while the Department of Environmental Protection reviews possible changes to them. Those rules address wetlands, stormwater, flood hazards, and coastal protections. The extension allows certain eligible applications to proceed under earlier standards.
The state cannot claim to be building climate-resilient communities while reconsidering the rules meant to protect them and simultaneously pushing to accelerate development. This risks creating a loophole for affordable housing development in flood zones.
We cannot create a two-tier system in which wealthy people get safe homes on high ground while lower-income families are steered toward flood-prone land because it is cheaper, or developers do not care whether people of modest means end up living with flooding.
Environmental justice must mean more than putting lower-income families wherever land is cheap, even if it floods. Many overburdened communities are already overdeveloped. We cannot create one standard of safety for wealthy communities and another for working people.
Affordable housing must not become affordable environmental risk.
Fast-tracking permits and shot clocks
Sherrill’s permitting agenda makes these concerns more urgent. The administration is promoting permitting dashboards and shot clocks to speed approvals. But a faster decision is not necessarily a better decision.
The Department of Environmental Protection is supposed to protect public health and the environment, not simply move projects through the pipeline. Delays should not be addressed by putting environmental review on a stopwatch.
The state has an inherent conflict of interest when it leases the land, funds the development, and then has the DEP fast-track permit approvals. This could severely limit public oversight, scrutiny, and opportunities for residents to comment on projects that affect their communities.
Environmental review is supposed to be the process that determines whether a project is safe, sustainable, and appropriate. The state seems more interested in getting to yes than saying no to bad projects. The focus should be on whether a project complies with environmental rules and how it will affect surrounding communities.
The answer to slow permitting should be more public capacity, not less public scrutiny. The DEP needs more review staff, scientists, engineers, and inspectors. Fast-tracking permits is not reform if it means fast-tracking risk.
Pave and Wave: Developer-controlled cleanups
The problem with many of these sites is that they are contaminated and may not be suitable for residential development. Brownfields can be appropriate for certain types of development, but building housing on them poses serious risks.
The problem is that the DEP seems to believe development is the only way to get these sites remediated. The agency pushes real estate deals and redevelopment instead of requiring a real cleanup. But contaminated land must actually be cleaned up, not covered over and declared a success.
Former industrial properties, rail yards, and maintenance sites may contain contaminated soil or groundwater. A cap is not the same as removing contamination. Caps can eventually fail, and there is also the risk of carcinogenic vapors entering homes. Residents need to know what pollutants are present, how they will be treated or contained, how groundwater will be protected, how vapors will be addressed, and who will monitor the site over time.
Allowing developers to oversee their own cleanups creates an obvious conflict: The party trying to make the project profitable is also managing the work intended to protect the public. That is the fox planning and building the henhouse, guarding it and declaring it safe.
The DEP must take control of these sites, independently determine what cleanup is necessary, verify that it is completed, and enforce long-term monitoring. A developer’s consultant cannot substitute for independent public oversight.
You do not solve environmental injustice or toxic nightmares by putting affordable housing on top of contaminated sites, capping them and calling it redevelopment. Verify that the land is safe, and only then build.
Who gets exempted, and who gets the development pressure?
The state also needs to explain how development on state-owned land affects municipal affordable housing calculations, including vacant-land adjustments and the amount of land considered developable. Could a change in those calculations increase a town’s obligation and trigger more development, including additional market-rate units under inclusionary zoning?
Those questions must be answered publicly, with a clear methodology.
There is also the exemption of 62 municipalities from prospective affordable housing obligations under the applicable urban aid provisions. The state should explain how those exemptions affect the distribution of housing needs and development pressure.
Since many of those communities have state land and transit facilities, will new development there be entirely market-rate housing, with luxury apartments but no affordable units? Many of these communities are already gentrifying. Affordable housing is being torn down, LLCs are buying up apartment buildings, and people of modest means are being pushed out of their neighborhoods.
Housing demand does not disappear because a municipality is exempt from an obligation. If some communities are exempt while others face growing demands, the state must show that it is not shifting development pressure onto communities with available land but limited infrastructure or environmentally sensitive resources, including the Highlands and Pinelands.
Another concern is that communities with vacant-land adjustments, because of environmental constraints, could lose those adjustments. New requirements could increase development pressure and accelerate the destruction of the natural resources the adjustments were supposed to protect.
Affordable housing is a statewide mandate and responsibility. It should not become a system that protects communities that are growing and becoming more upscale while pushing development pressure onto others that are not growing and are environmentally sensitive.
Build homes for people, not portfolios
New Jersey needs housing. But it also needs clean water, safe drinking water, functioning sewers, flood protection, open space and healthy neighborhoods.
The housing crisis must not become an excuse to hand public land to private developers, weaken environmental scrutiny or treat local planning as an obstacle. Public land offers a different opportunity: Build permanently affordable homes through public, nonprofit and community-based models, with strong affordability protections and transparent financial arrangements.
The state should disclose every proposed site, every developer selection process, every lease and subsidy, every affordability commitment and every environmental constraint. It should require independent reviews of infrastructure, traffic, flooding and contaminated-site remediation. It should prioritize sites that can support housing without destroying critical natural resources or burdening existing residents.
My own life taught me that working people need both a place to live and an environment in which they can live safely.
Affordable housing must not become the cover story for a developer giveaway.
Build housing people can afford. Protect the environment they depend on. And stop treating public land as a private opportunity.
Jeff Tittel is an environmental and political activist, the founder of SOAR, and the former director of the New Jersey Sierra Club.


