BY HEIDI YEH
As New Jersey towns race to lock in plans for their next round of affordable housing obligations, a critical question is coming into sharper focus across the Pinelands: Are municipalities truly planning for the homes people need—or are some using state housing mandates as political cover for oversized sprawling development?
Affordable housing is one of New Jersey’s most urgent challenges. Teachers, service workers, young families, and seniors all need places they can afford. But in the Pinelands, where one of the nation’s most significant environmental protections intersects with local land-use politics, “affordable housing” is increasingly being invoked to justify development patterns that appear to have far more to do with maximizing market-rate construction than meeting actual housing obligations.
Recent reviews by the Pinelands Commission of municipal affordable housing ordinances suggest this tension is more than theoretical. In Jackson Township, officials argued that Pinelands protections forced them to dramatically increase zoning capacity in environmentally sensitive areas to meet Round 4 housing requirements. But a closer look raises doubts.
Only about half of Jackson Township is in the Pinelands, and the other half is not. The town must provide roughly 1,000 affordable units, but it has proposed to place the majority of these units (581) in the Pinelands half of town. This alone would not be a problem—in fact, the Pinelands properties that the town has targeted could accommodate all 1,000 affordable units. The problem is the way that a much larger number of market-rate units has inflated the size of the development. Jackson Township proposed cramming 3,000 total units, which is roughly triple the zoning capacity that the Pinelands Commission would actually allow. This suggests that the real driver may not be affordable housing itself, but the market-rate development attached to it.
This points to a broader misunderstanding embedded in New Jersey’s housing debate: the assumption that affordable housing must primarily come through sprawling inclusionary developments where only about 20 percent of units are affordable. In reality, that 20 percent threshold was designed as a minimum requirement, not a maximum. But too often, municipalities have treated it as a ceiling, structuring ordinances around the lowest possible affordability ratio and, in doing so, dramatically increasing the total
scale of development.
Medford Township offers another revealing example. To meet an obligation of just 171 affordable units, current proposals could generate nearly 1,000 homes with all of the market-rate units added on. The choice is not simply “build big or build nothing.” Municipalities can require higher affordable set-asides, support fully affordable projects, use rehabilitation credits, or deploy public subsidies to meet obligations more directly and with far less environmental disruption.
Other towns have already shown this is possible. Sparta, for instance, has approved developments with affordability rates approaching 45 percent. Fully affordable developments exist across the state. These examples undermine the often-repeated claim that only large, developer-driven, 20-percent set-aside projects are financially viable.
The Pinelands Commission itself may unintentionally reinforce this pattern through its Pinelands Development Credit (PDC) exemption for affordable housing. Affordable units are exempt from purchasing costly PDCs—a potentially major financial advantage, especially when PDC prices can exceed $23,000 per quarter-credit. However, municipalities control how broadly this exemption is applied, and many local ordinances still structure it around the familiar 20 percent model. This disincentivizes builders from incorporating a higher percentage of affordable units in their Pinelands developments. Is this a conscious decision being made by the town or simply bureaucratic inertia?
Then there are municipal affordable housing trust funds—one of the most overlooked tools available. Funded through development fees, these accounts can support rehabilitation, land acquisition, gap financing, and fully affordable housing without requiring sprawling greenfield projects. Monroe Township representatives described at a recent Pinelands Commission meeting how their town is using such a fund to subsidize an age-restricted development that is 100% affordable. This demonstrates how these funds can offer more flexible, environmentally responsible alternatives when used creatively.
The real issue is not whether affordable housing should be built. It absolutely should. The issue is whether towns are choosing the least destructive, most community-centered path—or defaulting to developer- friendly formulas that produce unnecessary sprawl. The state already has the policy tools to build the housing people need while protecting the landscapes that make New Jersey unique.
