On January 27, 2022, a decision was made by the Superior Court Appellate Division on In the Matter of New Jersey Sports and Exposition Authority Resolution 2020-07, Adopting the Hackensack Meadowlands District Master Plan Update 2020. The New Jersey Sports and Exposition Authority (“NJSEA”) was formed to adopt and implement a master plan for the Hackensack Meadowlands District (“District”). NJSEA was to complete a new master plan by February 15, 2020. Towers Associates, Ltd (“Towers”) owns eleven acres of property in the District which includes a Home Depot store and a proposed hotel.
The NJSEA completed a draft plan by August 5, 2019. Under the Land Use section of the Plan, the NJSEA did not perform its own comprehensive traffic study of the current traffic conditions, rather it relied upon data collected in 2013 by the New Jersey Department of Transportation. (“DOT”). Further, it reclassified an area of the property from the Commercial Corridor Planning Arear to Employment Center Planning Area. After the release of the draft plan, Towers submitted written comments objecting to the Draft Master Plan Update, which centered around the potential increased traffic would bring to the area and the rezoning of a portion of the District. After public comment, NJSEA replied to concerns, however the Committee rejected the Plan. Despite the issues and the Committee’s rejection, the Board of Commissioner’s voted to adopt the Master Plan Update.
Towers appealed the adoption of the Master Plan Update stating that NJSEA failed to complete a regional transportation study and that they rezoned areas of the property, which was arbitrary and capricious. The Court gave deferential review to NJSEA’s adoption of the Master Plan as to whether this decision was arbitrary, capricious, or unreasonable or if it violated legislative policies expressed or implied in the act that governs NJSEA. The Court looked to the statute that governed the role of NJSEA and their obligations to update the plan, which were the Hackensack Meadowlands Reclamation and Development Act (HMRDA) and the Hackensack Meadowlands Agency Consolidation Act (HMACA). The plain language of the statute makes clear that there was no requirement imposed for the inclusion of a transportation study prior to the adoption of the plan. Therefore the Court held that NJSEA’s decision was not arbitrary and capricious.
The Court further held that the NJSEA reclassification of the area of the property to the Employment Center Planning Area was not arbitrary and capricious. The Court found that NJSEA did not rezone the property rather it reclassified based upon what was used in the vicinity. The Court held this was not rezoning, as planning areas do not constitute rezoning, and found that there was substantial evidence to support the NJSEA’s conclusion that the reclassification of the land was for the benefit of the District. Further, the Court found that reclassifying the property did not go against objectives of the plan, rather it benefitted it, as the reclassification of the property stimulates job growth and economic prosperity.
The Superior Court Appellate Division affirmed the Updated Master Plan of NJSEA.