Objector WeCare Response dated May 4 2026 to Letter of Bryan D Plocker Esq

THE BOARD’S SEVEN REQUESTS TO THE APPLICANT To put a finer point on the ways in which the WEHI development application is incomplete or flawed, at the end of its March 4, 2026, special meeting the Board, through Board Counsel, listed seven items the applicant had to address: 1. A complete tree replacement plan; 2. The location and capacity of a sanitary sewage system that would satisfy the needs of the proposed new development and meet the “feasibility” requirement that is mandated by State law prior to any planning board approval; see Field v. Franklin Township, 190 N.J. Super. 326 (App. Div. 1983); 3. Adjustments to the stormwater management system to re-direct adequate water to the upper wetlands; 4. The need for a water tower to assure sufficient water pressure for regular tenant usage and for firefighting purposes; 5. The extent to which the developer would contribute to the cost of off-site infrastructure needs; 6. The identification of a second point of ingress and egress for regular usage; and 7. The development of an improved plan for emergency access. OBJECTOR’S RESPONSE TO MR. PLOCKER’S MARCH 30, 2026 LETTER 1. Applicant inadequate response as to the sewer capacity and the disregard of the governing law under Field v. Franklin Township. Mr. Plocker’s letter dutifully contains sections claiming to deal with six of the seven items (the issue of contributions to the costs of necessary off-site improvements is not addressed) and adds a long concluding section entitled “Condominium’s Sewer Line”, recognizing the importance of this issue, but offers no evidence of actual feasibility of the proposed sewer line and no evidence that the public sewer system can accept the anticipated waste flow of this project. It is precisely this 3