Mine Hill Planning Board Approves Fair Housing Plan. What Happens Now?

 

by Brian T. Lynch, MSW

The Randall Hill Forest is the area off Randall Ave. between Weber Lane and Spring Brook. It is the undeveloped land surrounding the white which is the MUA water tower. 

News: On Tuesday, February 24, 2026, The Mine Hill Planning Board approved the state-required Fair Housing Plan which compels the town to meet our quotes for low-cost housing. “A gun is to our heads,” as Mayor Sam put it before the vote, which is figuratively true. The Planning Board lawyer, engineer, and Mayor Sam did a good job of explaining the law and their rationale behind the plan to the nearly full room of residents in attendance.

In short, the current developer-friendly laws create new affordable housing options that force towns to consider high-density developments in whatever undeveloped land a developer owns, even if the town has a limited amount of undeveloped land or environmentally sensitive lands under zoning restrictions. New construction is necessarily high-density housing because there is no way that low-cost units can be profitably built under current market conditions. Low wage families simply cannot afford the rent required for a builder to recoup construction costs. As a result, developers have to construct eight luxury, high rent apartments for every two low-rent apartments they build.

Also, New Jersey’s Fair Housing law contains strict protocols for determining how many low-cost housing units each town must add to its housing stock over a period of time. The penalty for failing to create a plan to meet these low-cost housing quotas subjects towns to lawsuits by developers that, if upheld, grant the developer what is called the “builders remedy.” This allows builders to develop high-density housing on their property despite local zoning restrictions related to density, and certain other restrictions. 

The practical implication for Mine Hill is that, in order to meet our current housing quota, we must reopen consideration of developing the 84 acre Randall Hill property with its uncapped mines. Less well appreciated is that this land is also an important water source for Spring Brook. Spring Brook, in turn, contributes clean water to reservoirs that serve 1.2 million New Jersey residents downstream.

There is currently funding through the Morris County Municipal Utilities Authority to purchase Randall Hill because of its importance as a water resource. If both the town and the owner are in agreement to the sale, it would then be purchased and deed to the town. This possibility has not been explored by the town. But, as of Tuesday, when the Planning Board voted on our Fair Housing Plan, the option to preserve the land ended for now. Legally, the town cannot pursue other options under the plan, and no public funding can be used to purchase it from the builder. Instead, the law requires the town to rezone the property to allow the owner, Jason Ellison, to build up to 305 housing units. That is the number of units Mr. Ellison believes he can build.

It gets tricky from here because the owner has to submit a site plan that mitigates the dangers associated with uncapped mines. When this was attempted by the prior owner, Mr. Ellison’s father, the cost of mitigating the mines made the project financially unfeasible. It is possible that this might be the outcome again. If that happens, the town could then move forward towards preserving this tract of land. This would exempt it from further development in the future and save what is both an important water resource and a beautiful forest with all its wildlife.

Commentary: Land developers, I believe, are tools of the billionaire class which need safe, long term investment options. For more than a decade there have been more billionaires and fewer long term investment opportunities for them. The consensus among the richest families in America is that land ownership, which yields monthly rental income, is a good way to grow wealth and preserve it for generations to come. That is why most development projects today are for rental units, not single-family homes. In fact, single -family homes are being bought up by large corporations as rental and investment properties. This is causing both home prices and rental rates to rise. We could be looking at a return to feudalism with its land barons, peasants, and tenant farmers.

There is no stopping this trend at present through either state policies or judicial action. Powerful people have framed the need for affordable housing debate as a crusade against towns that exclude the poor by their zoning laws. This is a real phenomenon, but it isn’t the main reason why there is little affordable housing for the poor. The main reason is that this same billionaire class, in an organized collaboration, stopped giving most employees annual raises based on company profits. That began back in the 1970s.

Forty years ago COLAs (cost of living adjustments) were a separate thing to keep wages on par with inflation? For decades now COLAs are almost the only type of raises workers are occasionally given. Profit sharing raises are the exception. Profits today mostly go to CEO’s and wealthy stockholders. This failure to share profits means real wages are stagnant. Most families are losing buying power year over year as the size of the American economy has almost tripled. Today, the number of workers that can't afford to buy a home (or food, medicine, etc.) has grown to crisis levels.

Housing costs are also affected by market conditions that raised construction costs faster than inflation. And yes, many communities in New Jersey do have restrictive zoning schemes that discourage construction of low-cost housing for the poor. There is always been a class prejudice built into many town zoning laws. This has to be rooted out, which the Fair Housing law is designed to do.

This, in summary, is the backdrop we are up against.

But the specific issue of many residents of Mine HILL are up against right now is trying to conserve the Randall Hill forest, an environmentally important property. It this regard, it is our affordable housing quota that matters most, not any specific development project. There is nothing in the law that says low-cost housing must be new construction. Any way that we can grow affordable housing satisfies the law.

So, for the sake of preserving a single ecologically important forest, the six (6) additional low cost apartments we need to fulfill our quote for this round can more easily come from rezoning single-family housing to include duplex housing for owners that have extra space or sufficient land to add an apartment. We don’t have to play the developers game.

Mine Hill, like most towns, have zoning restrictions that prevent homeowners in older homes from converting their extra space into duplex housing. As a result some homeowners in single-family houses are under financial and social pressure to build non-conforming apartments to help pay their mortgage or shelter their adult children who can’t afford to rent in Morris County. These unauthorized units, nevertheless, provide a cache of affordable, albeit underground, housing which may not be counted in our affordable housing quotas.

Research suggests this is a widespread and growing phenomenon, particularly in high-cost areas, with estimates in some specific, dense localities suggesting that as many as 25% to over 50% of certain types of older housing stock may contain unauthorized units. In specific urban neighborhoods with high demand, it is estimated that over 75% of basements may be rented illegally.

Similar but less dramatic trends are observed in older suburban, "inner-ring" neighborhoods where homeowners convert spaces to manage high mortgages or create "missing middle" housing, or duplexes, in areas that technically only allow single-family detached homes. These apartments exist because they offer more affordable housing options, helping to fill the gap between single-family homes and large apartment buildings. Because they are unregulated and unregistered, these apartments often lack proper exits, ventilation, or smoke detection, leading to high health and safety risks for low-wage tenants. It is in everyone’s interest to recognize these non-conforming, but affordable apartments as a significant part of the suburban housing supply.

Given this research, it is possible that Mine Hill may already have a shadow stock of low-income housing to meet our Round Four fair housing quota. Instead of acknowledging these non-conforming housing units or encouraging homeowners who want to add an apartment to their house, we are allowing dangerous conditions for many low-income families living in non-comforming housing units. With the acute need for low-income housing driving homeowners to skirt the law, we should instead embrace these conversions and work with homeowners to bring these units up to safety standards. We should ease zoning restriction when it is prudent to do so and issue special variance to owners of certain “eligible” homes that can be converted to duplex housing. Mine Hill currently has housing funds available for grants to upgrade substandard housing.

______________________________________

Here is an article that explores housing conversion concepts from 2017. It is entitled, “Learning from a Non-Conforming Neighborhood.”

Here is the Amended Fourth Round Housing Element & Fair Share Plan

   

   For more information on Rebirth of the Randall Hill Forest.

          For my article on Randall Hill Development Back in Play

Will Your Town Water Now Be at Higher Risk?

 by Brian T Lynch, MSW

HERE A LIST OF TOWNS DIRECTLY IMPACTED BY THE RANDOLPH TOWNSHIP BOARD OF ADUSTMENT'S DECISION TO ALLOW A CHEMICAL COMPANY TO HOUSE A MANUFACTURING PLANT RIGHT BESIDE THE BLACK RIVER AND THE MUA'S ALAMATONG WELL FIELD WHERE THESE TOWNS GET DRINKING WATER.

What follows is my letter to Darren Carney, Administrator of the Randolph Township Planning and Zoning Board. I thought the information provided would be sufficient to count as new information not provided by the applicants, or the ECOS company representative did not provide a full account of the chemicals it would be shipping for storage and use at their intended manufacturing plant at the Morris Business Campus. My request for a 20 day municipal reconsideration, based on new information and the significant risks by the chemicals to be used that were not stated by ECOS, was denied. Here below it is the letter I sent and the response I received with an attachment. Is this sufficient? Is it comprehensive enough and is it enforcable.  

Dear Mr. Carney,

I am writing to request a reconsideration of the Board’s decision to allow ECOS to build a bottling/manufacturing plant within the Morris Business Campus on Sussex Turnpike. I am a resident of neighboring Mine Hill.  My standing for making this request is that Mine Hill’s public drinking water comes from the Alamatong Well Field located adjacent to this property. My rationale for making this request is that representatives for the ECOS company appear to have misrepresented the safety and environmental risks associated with the manufacture of its laundry detergent during the public hearing held in September of this year.

The following is an evaluation of the claims made to the Randolph Township Board of Adjustment by representatives of the ECOS chemical company regarding the safety of the chemicals they use in manufacturing their most popular laundry detergent. It was claimed that the companies “largest selling product is a laundry detergent” that is “really biodegradable and free from synthetic dye and other harmful substances.” These clams were recently memorialized in the release of the Board’s minutes and used in justifying a zoning variance allowing the company to rent a large warehouse on the Morris Business Campus. As you can see below, the claims made, which had a bearing on the approval by the Board, appear to be materially false.  Here is a screen shot of the relevant minutes:

  

According to the company’s website, the “Flagship Product” is ECOS Hypoallergenic Laundry Detergent (with enzymes). It is consistently identified as their top product, recognized for being plant-powered and effective in all water temperatures. The most popular versions include the Lavender scent and the Free & Clear (scent-free) formula. What follows is a screenshot from their website of the chemical compounds used to make their laundry detergent.

 Hypoallergenic Laundry Detergent with Enzymes – Free & Clear   

Here is a screenshot of the chemical ingredients in ECOS’s top selling product, as referenced in the Board’s minutes. 

These are the chemicals that will be delivered to the facility in large quantities and stored for use in manufacturing laundry detergent. For each of these ingredients, the Safety Data Sheets (SDS) were reviewed and safety warnings related to public health or the environment were copied and pasted (in part) to the table below. The highest NFPA* category is listed on the table along with a URL link to the SDS reviewed. Note that every chemical compound with a NFPA category of #2 or above is specifically prohibited from this warehouse location by an existing zoning ordinance*. None of this information is referenced in the minutes from the public hearing. (Click on image to open it)

 

Seven of thirteen listed ingredients have NFPA numbers of #2 or higher. Three products are specifically hazardous to aquatic environments. The Safety Data Sheet (SDS) for one chemical, Protease, states that it is “acutely toxic (oral) and very toxic to aquatic life. It carries the highest biohazard category of #4. The SDS warning on a fourth chemical states that it will affect PH of water in the environment and harm aquatic organisms if released in quantity. The SDS on six other chemicals warn against release into the environment. These finding, based on the actual laundry detergent ingredients to be manufactured at this location can not be summarized by saying the product is free from “other harmful substances.” 

 

Given these grave findings, and the mischaracterization of the product by a company representative, action should be taken to reopen a more comprehensive analysis of the plan to allow ECOS to locate a plant within this highly fragile environment. 

If my information is materially wrong, please provide me with corrected information. Thank you for your consideration. 

Brian Lynch

37 Randall Avenue

Mine Hill, New Jersey 07803

* NFPA is the National Fire Protection Association, as you know. (see below).

 

RESPONSE

Darren Carney	Tue, Feb 3, 2:48 PM (2 days ago)
to me, Randolph

Mr. Lynch,

 

The Board has concluded the hearing on the application and can not reopen the case.  As a condition of approval, the tenant is required to provide the attached assessment of its operations before occupying the location.  If the information in the assessment is not consistent with the stipulations and representations made during the public hearing, the tenant will be required to obtain an amended approval from the Board.

 

Darren Carney

Planning Administrator

ATTACHMENT 

15-33.5. Special performance standards.

All uses and development applications in the I-2 District shall provide an assessment of the impact on the

groundwater with a particular emphasis concerning the potential affect on existing and proposed public and

private water supply wells. At a minimum, the assessment shall contain the following:

A. Description of proposed use or activity; product produced or stored, and Standard Industrial Code

(S.I.C.), if applicable.

B. A complete list of the types and volumes of all hazardous materials (including fuels) used, stored,

processed, handled or disposed, other than those volumes and types associated with normal

household use.

C. Documentation of floor drain locations, paved area drainage paths, overflow areas, septic fields and

other routes where contaminants under usual and emergency situations have an opportunity to enter

the groundwater of surface waters.

D. Description of the types of wastes generated and method of disposal, including solid wastes, hazardous

wastes, sewage and nonsewage wastewater discharges.

E. Location of all public and private potable water supply wells within the property and within 2,000 feet

of the property line which have the potential for contamination from the subject property.

F. Description of the risks associated with the use, handling and/or disposal of any hazardous wastes.

G. Description of plans to detect and control hazardous material leaks and spills and plans for inspections

and monitoring, emergency notification and emergency containment and clean-up procedures.

H. Description of best available technologies to safely store and handle any hazardous wastes and to

detect releases of any hazardous materials.

I. Assessment of compliance with the best management practices for groundwater quality protection.

(Ord. No. 30-99, § 2, 7-6-99)

The Tipping Point and Our Changing Culture

by Brian T Lynch, MSW

There is a tipping point in the rise to great wealth where a god complex kicks in and the rich begin leaving morality behind. Jesus warned that it is easer for a camel to pass through the eye of a needle than for a rich man to enter into the kingdom of heaven. The Trump administration is proof of this wisdom. Just recall who stood behind him at his inauguration. It was a who’s who the billionaire architects of American’s current culture…. I no sooner wrote these thoughts down when a friend posted an opinion piece in the NY Times that explains all this better and points to the antidote we need to embrace if we hope to save our society.

 

 https://www.nytimes.com/2026/01/30/opinion/david-brooks-leaving-columnist.html?smid=nytcore-ios-share

 

 

 

REBIRTH OF RANDALL HILL FOREST

by Brian T. Lynch, MSW

NATURAL HISTORY:

Even most folks living in Mine Hill haven’t heard of Randall Hill. It is a section of town bordering Wharton that was once a major mining area. It has mostly been forgottenThe mines were abandond 134 years ago and the land has been undisturbed since. In that time, the scars and barren earth have been reclaimed by nature. Shrubs and a thick canopy of trees reclaimed the hill. The piles of slag and dirt that dotted the hillside, and probably washed down hill during rainstorms, became fixed in place by a growing root system.

As vegetation returned to the hill, the flow of rainwater off the property slowed down, captured by the growing layers of leaf matter and tree roots. The sixty-some sinkholes that run along the western slope act like drainage basins collecting rainwater and sending it directly into the ground. No one ever recalls them filling up with water. There are fractures, two fault lines and maybe porous rock formations in the layers below ground that allow water to move laterally through the ground to low lying areas that surround the hill on three sides.. Surface water still flows in a heavy rain. It makes its way down to the lowlands as it filters through the soil and ground cover. Some of this water also resurfaces as freshwater springs and areas where groundwater seeps back up to the surface. You may know these areas as Spring Brook and the Spring Brook wetlands.

Today, Randall Hill is recognized as a Groundwater Recharge Area because it helps replenish our groundwater aquifers. Spring Brook and its wetlands are recognized as class C1 protected wetlands for the quality of its water. The water, which starts as rainfall on the hill, collects in the lowlands and travels from Spring Brook into Jackson Brook within Hedden Park. From there it flows into the Rockaway River destined for the Jersey City and Split Rock Reservoir. These reservoirs provide 45 million gallons of water a day to 1.2 million residents of Central New Jersey.

FROM MINING TO WOODLAND TO FOREST:

The pristine forest lands which once covered the highlands where we live have receded as human development encroached over time. But a narrow band of forest land, known today as a ”greenbelt”, remained connected to Randall Hill as it was denuded of trees in search of iron ore. The type of ore found here is called magnetite. It is more than 60 % pure iron. It is a heavy and black colored mineral. Three or four hundred-thousand tons were removed ibefore the mines closed. But the greenbelt remained at the foot of the hill.

This proved important for the natural recovery of Randall Hill. It allowed what would otherwise be an isolated stand of trees to redevelop into a true forest ecosystem. As the wetlands and woodlands recovered, they provided new areas of food and shelter for aquatic life, birds, and mammals that are being squeezed by their shrinking habitats. Today, they have repopulated the Spring Brook wetlands and what rightfully should be called the Randall Hill Forest.

Living beside this forest I can tell you that we are treated to almost daily examples of the wildlife that occupies the hill and surrounding wetland. A few years ago, for the first time, we spotted a fledgling great horned owl in a tree near the water tower. It was a molting fledgling. A month later, around bedtime, noisy screams in the treetops caused me to grab a flashlight and run out to investigate. It turned out to be “moving day” when mama owl chased her three babies away from the nest. Two of the three found their own homes nearby. Sometimes since then, when we are up late, we can hear their beautiful night songs.

When I first heard the desperate owl sounds, I thought it was the annual racoon moving day. Every year the mommy racoon living on the hill decides enough is enough and starts screaming at her babies to move out. The juveniles scream back, as teenagers are apt to do. The racket they make is truly scarry. Two years ago, I ran out with a flashlight one night to watch the action and saw a baby racoon fall down from its nest to the ground, hitting branches as it fell. I tried searching with the flashlight to see if it was okay when I suddenly caught site of it running on the ground. It was running straight towards me. Before I could move it stopped short eight feet away. We stared at each other for a long moment before it turned and took off in another direction.

The deer on the hill and in the Spring Brook wetlands are numerous and healthy. My yard seems to be a bit of a greenbelt for them every evening. They cut through a few properties on Randall Avenue heading towards the highway, perhaps heading for the wooded wetlands behind Canfield Avenue School. In the morning, we often spot them heading back to the Randall Hill tree line. We have seen as many as twelve of them making this nightly trek at dusk. Sometimes they are followed by coyotes, which we have seen also. When the lawn is snow covered, we nearly always see coyote tracks beside the deer tracts. We had an animal camera in our yard for a few years and have many pictures of the deer, coyotes, and red fox in our yard. We also have skunks, woodchucks, and on one occasion, what appeared to be a bobcat on the move. And, of course, there are bears. Some big, some cubs with their mother. Over the years they started out as visitors from other parts of the primary forest. This past summer, a whole family moved into an area of the Randal Hill Forest. They lived on the south-east corner of the property near the wetlands. The male bear, according to an experienced local hunter who observed them, seems to be in excess of 650 pounds. They were good neighbors and never bothered anyone.

Then there are the birds. The Spring Brook wetland hosted a whole rafter (flock) of wild turkeys this year in Autumn Run. The sky overhead often featured blackbirds, hawks, starlings, and vultures. Just this morning, during our walk, we noticed five or six vultures perched on the chimneys of houses in Autumn Run, taking advantage of the warmth. The hawks are frequently seen soaring above Randall Hill to catch the thermals created when the breeze rises over up and over the hill. The hawks can often be heard in the woods on the hill. This past year, for the first time that I know of, there was at least one nesting pair.

Then, much to my delight, the bats have returned over the summer months. When I was young, living in Jefferson, the bats were a nightly presence entertaining my friends and me with their acrobatic skills while the “old timers” said, “Watch they don’t nest in your hair”. Since the white nose disease problem, they have been largely absent. Three years ago, I spotted them over my home once or twice. This year there were more, and they appeared often. They are a smaller species than I remember from the past. I haven’t been able to identify them yet, but I am sure they are living on Randall Hill.

The point is that after 134 years of being left alone, this 100-acre woods is a forest once again with a full and healthy habitat for wildlife. It has value both as a habitat and water source for Spring Brook. It did it’s time as an industrial site and now deserves our protection. It is a natural feature of Mine Hill that many other towns would love to claim in their community.

Randall Hill Development Back in Play

 MINE HILL NEWS:

Randall Hill Development Back in Play

by Brian T. Lynch, MSW

Jan 18, 2026

On January 8th, owners of homes within 200 feet from a large property off Randall Avenue began receiving legal notices via certified mail. The notices were from GZA Geoenvironmental, Inc. on behalf of the owners of the woods that run along the east side of Randall Avenue from Weber Lane to the bridge at the bottom of the hill on the Wharton line. Local residents know this property as the site of the abandoned Randall Hill mines, or as the site of the water tower on the hill, which serves our town and surrounding areas.

The property owners of these woods are listed on the notice as Randall LLC, Ellwood Associates LLC, and Jason B. Ellison. The notice was triggered by their application to the NJDEP for a “Line Verification” (LOI), which requests DEP staff to mark the wetland boundaries on their property with flags. LOI requests are made when owners have plans to develop the property. Per statute, this notification to property owners near the site “shall” contain a “description of the site and any proposed project” so homeowners can review the plans and submit their comments or additional information. The window for written comments is 15-days, four days from now.

Unfortunately, the notices we received don’t describe the property, the scope of the project, or what is being planned. As a result, some residents sent letters to DEP asking that the request be denied until a proper description of the development plans is provided to them.

With only rumors to go on, there is nothing I can tell you about what is being planned for the property, but a description of the property is a topic about which much can be said.

MINING HISTORY:

At 970 feet above sea level, Randall Hill is only 425 feet below the highest peak in Morris County. But it is best known for its mining history, not its height. Between 1855 and 1882 a rich iron deposit running for over 2,200 feet along the western slope of the hill was actively mined by both the Randall Hill and Jackson Hill mining companies. There are between 50 and 60 abandoned excavations along that line between mine shafts, air shafts, open pit, and exploratory digs. The deepest of at least six of the Randall Hill mine shafts are between three-hundred and seven-hundred feet deep. About 135,000 tons of high-quality iron ore was extracted from the Randall Hill mine, and another 100,000 tons of ore from the Jackson Mine further down the hill.

There are no records of the number of mine shafts at the Jackson Mine. Some of the activity there was open pit mining. The ore vein was about 125 feet below the surface. None of the excavations at these two mines were properly capped, and any lateral excavations from the main vertical shafts are not well documented. The surface areas over these abandoned mines are presumed to be unstable. The source for this information on the mines comes from an extensive, almost two-year investigation of the mines of Mine Hill conducted by Rutgers University. The report is entitled Abandoned Iron Mines of Mine Hill township, New Jersey and Subsistence Risk Assessment.

 The most recent mine collapse, observed by current residents, was discovered on or about January 26, 2020. Most of the upcoming discussion about development on this property will center around the abandoned mines, how best to stabilize the ground areas, and techniques best suited for this task. Prior landowners a few decades ago were unsuccessful in developing this land for high density housing because it wasn’t economically feasible. It remains to be seen what the new owners are planning. If they are planning an extensive development, there are rigorous qualifications required by Mine Hill statutes which readers can review here.

 

ENVIRONMENTAL CONSIDERATIONS:

A compelling case to limit development on this property can also be made on the basis of the habitat and hydrology of Randall Hill and its surrounding wetlands. It has been 134 years since mining activity ended on this land. Since then, regrowth of the forest and wetland areas have created a thriving natural ecosystem. The entire property is a beautiful habitat that delights residents with all the wildlife it supports. It is also an amazing groundwater recharge area that supplies most of the water that maintains the surrounding wetlands. A full explanation of the environmental considerations will follow in a separate post sometime in the next week or two. Until then, it is important for residents in town to be aware that development of this property has resurfaced again.

Randolph Allowing Restricted Chemicals on Land Beside the Black River

by Brian T. Lynch, MSW

There is an environmental question facing the residents of Randolph Township, It should be a matter of concern to everyone who draws their water from the valley where the Black River flows. The question arises because Randolph officials granted permission for a chemical manufacturing company to open its new plant in the township’s most environmentally sensitive location.

The question: Is it wise to manufacture thousands of tons of chemical cleaning products at a facility located 460 yards from Black River and less than a mile from commercial wells where thousands get their drink water?

This glacier valley runs from Kenvil to Hunterdon County and is a main artery for fresh water, open space, and aquatic habitat. Between wells and reservoirs along the way, it serves farmlands and over two million New Jersey residents. In addition to the Lamington River (Black River), billions of gallons of groundwater travels under the valley in an underground river.

A California based chemical company, ECOS, wants to expand its production of environmentally friendly cleaning products. It hopes to lease a 165,000 square foot building with 60 docking bays in the Morris Business Park located at 1578 Sussex Turnpike (Block 5, lot 8). Schindler Elevator is among the tenants in this industrial complex. The complex shares its southern boundary with Morris County’s Alamatong Wellfielde. To the East is a steep, mostly wooded climb up a steep ridge. This area is recognized as a groundwater recharge area. There are pockets of wetlands  surrounding the property including two small Lamington tributaries that carry water to the river. The western edge of the property is on the edge of the river’s flood plain.

The property owner and landlord is the Silverman Group, a national, privately owned and operated private equity and real estate development organization based in Basking Ridge, New Jersey. It oversees Morris Business Park, one of many commercial and industrial properties it owns in 21 states.

Because of its environmentally sensitive location, this Silverman industrial property has strict zoning restriction that lists nine permitted uses. None of the permitted zoning uses expressly allows chemical manufacturing on this site. Additionally, within the wording of Ordinance §15-33.2(A)(4), is language that prohibits the warehousing, or storage, of goods or products that carry any NFPA rating higher than (1). 

What does that mean? It means any chemicals that carries a moderate to high exposure risk to human health or safety is not permitted to be stored on this site. (see sidebar)

The ECOS operation, if permitted, would involve shipping in, storing, and “blending” very large quantities of various chemicals.

Based on my own review of just six of over 120 products made by ECOS, at least 38 different chemicals are needed. Most of these ingredients have language in their respective “Safety Data Sheets” (SDS) that warn against release of the chemical into the environment. Two of the chemical are listed as harmful to aquatic life or the environment if accidentally leaked into storm drains groundwater or water features. [See Appendix A] [Also, see the claim made on behalf of ECOS about their products in an addendum below]

But, do any of these chemicals carry a NFPA warning of moderate health risks of (2) or higher?

 
Yes. It appears that 23 of the 38 chemicals used in the six ECOS cleaning products surveyed have a NFPA rating of (2) or above. This means that without a zoning variance or a waiver of some type, ECOS should not be allowed to manufacture cleaning products within this industrial complex. The Silverman Group filed with the Randolph Township Board of Adjustment (RTBA) for zoning variances and an interpretation of the municipal ordinances that apply to the site.

ZONING VARIANCE STATUS: GRANTED!

The initial RTBA public hearing on the Silverman Group’s request for variances was held on September 11, 2025. It was clarified that this hearing by the RTBA was for an interpretation of the applicable zoning ordinances. The Board determined that the proposed use is not permitted by municipal zoning statutes, so the application was scheduled for a variance hearing to be heard on September 25th.

On September 25th, RTBA held a public hearing, This time, “The application [was] for a use variance for environmentally friendly cleaning products,” according to the minutes. Ms. Jena Arkin, a chemist with ECOS, explained how “the detergent is made from food-grade ingredient.” 

Charles Heydt, PP, was recognized as an expert and testified. He noted that, “the site is particularly suitable for this industrial zone… that the company's closed system operates effectively, making it a good fit for the site… and there will be no discharge of any manufacturing by-products, with no impacts to the stormwater.” The only chemical ingredient discussed by the board was Ethanol. A description by Ms. Arkin as to how this flammable chemical would be handled within the facility was satisfactory to the Board.  

After satisfying the Board on the company’s plans for safe handling of ethanol used in its hand sanitizer, assuring the Board that its safe, “closed systems” of production allows no chemical waste products or wastewater to exit the building, and the RTBA deciding that ECOS is not a warehousing operation that stores chemicals, the use variance was approved. No discussions of any other chemicals were discussed according to the minutes.

During Ms. Arkin testimony, she said the chemical shipments to the plant would be about five deliveries per shift with two shifts per day. That equals ten deliveries per day to a building with 60 docking bays, as is called for in the plans. Each tractor-trailer holds between 10 and 15 tons of cargo. A conservative estimate, based on a five day per week operation and 10 tons per delivery, is that the Randolph Townships Board of Adjustment is waving in 500 tons of unidentified chemicals per week to this environmentally sensitive location for a manufacturing operation that is not specifically allowed under the current zoning. 

The decision of the Board is based on a point in time picture of ECOS manufacturing. No one can predict what changes in products, chemicals, procedures, natural disasters, or ownership changes there may be over the next 50 years. 

Fifty years is a blink of an eye in geologic time. It is even brief in human terms. If you have or know any young adults in college, based on present expected operations, 1.3 million tons of potentially harmful chemicals will be shipped in and out of the ECOS plant in their lifetime. This is more than enough time for a "black swan" event to happen. 

Pictured on the left are the cargo ports on one side of the building where ECOS hopes to house its manufacturing plant. Half of the paved surface slopes towards the building and the drainage grates seen here. Stormwater from the roof also flows into this drainage channel. The water collected here empties into the field and tree line in the background, then into the Black River.

Is this variance consistent with the values and expectations of Randolph residents and their representatives?  If not, consider contacting the Randolph NJ Clear Water Coalition, a recently formed organization and Facebook Page dedicated to the reconsideration of this Board of Adjustment decision. The time to voice your opinion is running short.

                        A SACRED VALLEY – (My opinion)

This is a picture I took of the area near the commercial wells of the Alamatong Wellfield where water is drawn every day for residents of Randolph, Mine Hill, Mt. Arlington, and part of Jefferson, Roxbury, Wharton, Denville, and Parsippany. It is a spot upstream from the Ironia Bridge and Lake Lillian. It is a place of breathtaking beauty and peaceful solace. It is not a place that most people who drink this water will ever experience. That is too bad. It is very hard to appreciate our life-giving water when we cannot see, hear, or touch the places from which it comes. But if you spend any time at this spot, your inner biological senses will tell you that this is a sacred place.

We each have our daily rituals. This time of year mine usually begins by nudging up the thermostat and drawing water from the kitchen sink for morning coffee. It’s a familiar and important routine that start my day. In fact, it is a ritual carried over from my ancestors who started their day by rekindling the fire with wood they split from a tree they cut down, and lowering a wooden bucket into a hand-dug well for water. The difference between their daily rituals and mine is that they touched the earth directly for warmth and water, just as did the native people before them. We no longer have that intimacy. Most of us rarely consider from where our water is drawn.

My water source is this Alamatong Wellfield. I have seen it in person. The idea of what is being planned doesn't sit well with me. It isn't just that tens of thousands of people rely on this  water every day, but the whole web of abundant life within this ancient ecosystem supports us as well. Any feature of nature capable of supporting so much life is worthy of our veneration and respect. This is sacred land. Shipping tons of harmful chemicals to a location within this zone is an unnecessary risk. I hope the residents and officials of Randolph feel the same way.  Planning and Zoning Board members are our appointed stewards of the land, so I am hope that they will reconsiders this decision. 

Appendix

After reviewing all the chemicals that go into make 6 of 120 products manufactured by ECOS, the following table lists all the chemical ingredients with an NFPA rating of (2) or higher. These are all chemicals specifically prohibited from being stored on the Morris Business Park property by a zoning ordinance. The Randolph Township Board of Adjustment’s variance allows these, and other potentially harmful chemicals, to be shipped and stored for use in the proposed ECOS manufacturing plant. The six products reviewed are:

Laundry Detergent Sheets – Free & Clear, Laundry Detergent Sheets – Lavender Vanilla, ECOS Dishwasher Detergent Packs, Foaming Dish Soap – Free & Clear, Pet Stain & Odor Remover, and Bathroom Cleaner – Tea Tree.

And these are the chemicals compounds that a moderate to high health and safety warning. The CAS# is an internation uniform code identifying the specific chemical. You can search the internet using that number. You can also search the Safety Data Sheet for each of them. Most also carry a general warning that the chemical should not be released into the environment.

ADDENDUM: January 31, 2026   Recently posted Board of Adjustment notes of statements made at the hearing by representitives of ECOS about the chemicals used in one of the laundry detergents they make, which seems to be at odds with the finding above that included a laundry detergent: 

The following is a complete list of ingrediants for just one product, "Launder Detergent - Lavender," which can be found on the ECOS company website. 

https://www.ecos.com/laundry/laundry-detergent-sheets-lavender-vanilla/