[brief] A.  **[...]’s Has Been Building and Facilitating the Development of Affordable Housing for Forty Years.**  [...] is economically diverse, and its varied housing stock reflects [...]’s efforts over decades to provide a range of housing opportunities.  (See Da26).  In the early years of Mount Laurel, between 1985 and 1995, [...] authorized the development of supportive housing, single-family affordable housing, and senior rental units.  (Da47).  Its Housing Authority continues to operate over 440 units constructed prior to 1980 and occupied by low- and moderate-income residents.  (Da48).  --- 1  “T1” refers to Transcript of Order to Show Cause, July 5, 2024.  2  “T2” refers to Transcript of Motion for Reconsideration, October 4, 2024.  On March 14, 1994, the [...] (“[...]”) granted the Township Cycle 1 substantive certification, reflecting [...]’s determination that [...]’s Housing Element and Fair Share Plan accorded with the Fair Housing Act and [...]’s regulations.  (Da48).  [...] proactively and voluntarily implemented its then-current plan, facilitating the development of affordable housing through the early 2000s.  (Da48).  [...] also spent millions of dollars entering into Regional Contribution Agreements (“RCAs”), which were permitted by the Fair Housing Act prior to 2005.  (Da49).  On December 20, 2005, [...] first petitioned for Cycle III substantive certification based on the original version of [...]’s third round regulations that were later invalidated.  (Da50).  On December 31, 2008, [...] filed for substantive certification under [...]’s revised Cycle III regulations.  (Da50).  [...] granted [...] full substantive certification for its Cycle III plan and concluded that [...]’s plan created a surplus of 105 affordable housing credits.  (See Da50.)  On October 14, 2009, [...] became one of only 68 municipalities in the State to be granted full Third Round substantive certification.  (Da50).  [...] continued to implement its affordable housing plan for the Third Round and rehabilitated 86 substandard, existing single-family dwellings occupied by low- and moderate-income households.  (Da51; Da52).  In 2015, [...] voluntarily filed a Declaratory Judgment action under [...] as permitted for municipalities who received substantive certification from [...] before its Third Round Rules were invalidated.  [...] hoped to reach an agreement with the [...] (“[...]”), and the parties met on numerous occasions to discuss potential properties for inclusionary development.  (Da53).  When the parties could not reach an agreement, [...] withdrew from this voluntary process in 2019.  (See Da53).  [...] did not withdraw due to any refusal to provide affordable housing, as demonstrated by [...]’s actions in facilitating numerous inclusionary and 100% affordable projects after filing its Declaratory Judgment action.  (Da53-Da56).  Consistent with its past practice, [...] continued to facilitate the construction of affordable housing.  (See Da53-Da56).  [...]’s ongoing efforts and goals are reflected in its March 2023 Master Plan Reexamination Report & Amended Housing Master Plan Element and Open Space, Recreation and Conservation Master Plan Element (the “MPRR”), which outlines its process for determining land most appropriate for construction of low- and moderate-income housing, including the promotion of mixed-use development to encourage sustainability and smart growth.