A Critique, in progress, of the Orange County Comprehensive Plan

Michael R. Edelstein, Ph.D.
President, Orange Environment, Inc.
Professor, Environmental Studies, Ramapo College of New Jersey

On Thursday, November 14th, OEI was able to obtain, for a fee, our first look at the long awaited Orange County Comprehensive Plan. I just saw it today. We had foiled this document more than a year ago, after the Times Herald Record reported release of a draft for discussion by a select group of Old Boy Network groups and were denied a copy for review. On several subsequent occasions, county officials promised copies to us for comment, but with no follow through. Not only were we, as perhaps the group with the most developed record critical of the evolving growth dynamic in the county, kept out of the process, but the public at large and the municipalities who hold home rule control over actual growth decisions were excluded as well.

Now as an Environmental Psychologist formerly on the faculty of the School of Architecture and Environmental Design at SUNY Buffalo and for nearly thirty years involved in teaching sustainable planning concepts at Ramapo College of New Jersey, before I even opened our copy of “the plan,” I knew that there were two fatal flaws that would be hard to overcome.

The first of these flaws involves the fact that over the past thirty years, the planning professions have learned that direct involvement of stakeholders is necessary to successful planning efforts. How can one speak for visions of our county and communities without open and extensive dialogue and input? Not only does the failure to open the plan up from the beginning strike at the validity of its assumptions and conclusions, but here is an extraordinary failure to create an opportunity for widespread vesting of the officials and people of the county in a blueprint that in many ways will have influence out of persuasion rather than force of law. Violating precepts set forth in the early 1970s, this antiquarian planning process proceeded in a “black box,” out of sight and mind. The plan cites alleged public meetings, but other than one meeting to which OEI was invited, neither we nor any of our sister activist organizations were invited or informed of such meetings. To cite participation here is to foment a fraud.

The absurdity of this approach becomes even clearer when one explains the extraordinary lateness of the plan, namely a year and a half of frantic effort by county officials to rescue a draft that was deemed too incompetent to release for comment. A public process would have been an alternative means to capture errors and point toward solutions.

To remedy this egregious error of planning process, Orange County officials should table the plan and undertake a massive effort to educate the public and, using this draft, create a public conversation about the future. Instead, in a second failure of process, County officials have scheduled hearings two weeks after OEI bought our copy of the plan; most others in the public will have even less time to see the plan, which is not available in libraries or public places as yet. As a result of this rush to jam the plan through, there will be no public conversations about the plan before the only anticipated opportunity for comment passes. Not only does this approach constitute planning malpractice, but there is a little matter of the State Environmental Quality Review Act and its process and substance requirements, which the county is also about to violate. The document indicates that the Orange County Legislature is acting as lead agency, and that it determined that only a short Environmental Assessment of the plan was necessary. Yet, the plan has just been produced in written form; any decision by the lead agency must have preceded the document and, thus, could not have taken into consideration its contents. Furthermore, the effect of the avoidance of an environmental impact statement is to remove hardcore analysis from the process. I make the seniors in my Environmental Assessment course at Ramapo College produce a much more comprehensive document than Orange County required of its planners. No public scoping of the assessment was undertaken. And the comment, on page VI-1, to the effect that an Environmental Assessment was adequate to evaluate the plan “rather than a Generic Environmental Impact Statement, a measure more appropriate for specific actions or County departments and agencies or for municipal plans” reveals a fundamental ignorance of impact assessment tools and requirements. In fact, a Generic Environmental Impact Assessment is precisely the tool to use for a plan such as this, not an Environmental Assessment.

Specific actions can then address specific issues under the umbrella of the plan. Anyone who took my undergraduate course would know this! In sum, the first two process flaws of “the plan” are fatal without even considering its content.

As I went about the unsuccessful effort to see the plan over the past year, various involved parties assured me that I would love it once I saw it. Well, here is my response to the plan’s content.

The Introduction makes no mention of the goals of sustainable planning that are emerging as benchmarks for state of the art efforts. Such key source documents as the Regional Plan are not cited. Moreover, in a telling assumption of the plan on page 1-3, we are told that “growth will be embraced as a way to provide additional employment opportunities and enhanced living environments, but that growth should be directed into the built-up areas of the County where it can be supported effectively and efficiently.”

On the surface this sounds okay. The problem is two-fold. First, the plan does nothing to critically examine the assumption that growth is good or to identify our limits to growth and assimilative capacities and, therefore, how much growth capacity is left. In assuming that growth is good, the report ignores numerous studies done nationwide, but also locally, that show that many forms of growth are economically negative. The result of this growth is good rhetoric gives the plan a 1960s orientation that has no reality in this new millennium. Some growth may be inevitable given our larger context, and some forms of growth may be desirable, but most growth is harmful. Secondly, the report directs growth to existing areas of development. This formulation is excellent. However, the 1970s and 1980s Orange County plans had the same recipe, but look at the mess we now have? The new plan cannot mimic old truths without addressing why this formula failed in the past and how it will be enforced in the future. After all, we are looking for a master plan, not a PR piece.

A PR piece is what we seem to have, and it is no better illustrated than by its graphics. While an anemic picture of a farm adorns the cover, a promising picture, consider the meaning of these graphical statements.

The cover page for section two on “Building Blocks for Quality Communities” shows a picture of Woodbury Common. To construe Woodbury Common as such a building block requires a dyslexic logic that defies imagination. Briefly, W.C. has created such extraordinary traffic, pollution, congestion, small business competition, and wetland takings issues that it is antithetical to any notion of quality communities. The recent idea to relocate the train station there almost got transit officials lynched.

The W.C. may be the second largest tourist attraction in the state, but for many locals it is just, well, just what you would find in the W.C.

Section IV, “The Vision for Quality Communities,” is prefaced by a picture taken of the Newburgh-Beacon bridge from a restaurant on the Newburgh waterfront. This graphical malapropism uses an image that is all about gentrification and making the waterfront serve anyone but the adjacent impoverished and underemployed population as a vision for quality communities? Again, this is the antithetical image to what our plan should advocate for.

Well, this draft stops here before the substantive chapters (hopefully they are so) are encountered.

I will continue this in days to come. Comments please. The plan itself is available from Orange

Environment, Inc. by e-mail, free and hopefully can now be read on our web page.


I actually hope that I will so like the rest of this plan that my negativity will dissolve. But our goal is not to just rip the plan, but rather to rescue it. We need a viable comprehensive plan for sustainability with teeth. It appears that we have been given much less than this.

So tune in later to see if, having two strikes against it, the plan manages a hit or strikes out completely.

How to resurrect the plan? OEI will advocate and, if necessary, ourselves hold public sessions to discuss key concepts in the plan on a community-by-community basis with the goal of developing elements to strengthen the plan with maximum public involvement. We will then organize a campaign to amend the plan with the emerging edits from the process. Local activists from each community will work toward amending local plans and codes to fit the edited county plan. The goal will be to take what is good here and make it even better and to replace what is faulty. Our goal is constructive. We want the best County Comprehensive Plan possible.

Mike Edelstein,