    [From the U.S. Government Printing Office, www.gpo.gov]

     IR   Coastal Zone
           Information
             Center

                                                          A-

                                                             Approval
                                                                                              J4
                                                  of the New Jersey   Coastal Zone

                                                        Management Program

                                                  Bay and Ocean Shore Segment

       f

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       '41                                   Y

       14.
                                     'Tu
                    GB
                    459.4
                    A67
                    1978
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                                                                                         1291
                                                           "J"ITER

                                          Findings of Robert W. Knecht

                   too                      Assistant Administrator

                                                     for

                                            Coastal Zone Management

                                National Oceanic and Atmospheric Administration
          V2

                                               Approval of the

                                                 New Jersey

                                        Coastal Zone Management Program

                                          Bay and Ocean Shore Segment

                    I. Introduction

                    As Assistant Administrator for Coastal Zone Management, National oceanic

                    and Atmospheric Administration, (NOAA), I have reviewed'the record of

                    the development of the New Jersey Coastal Management.Program Bay and

                    Ocean Shore Segment (the Program) including the Coastal Management Strategy

                    for New Jersey, dated September 1977, the combined Program/Draft Environ-

                    mental Iupact Statement (DEIS) submitted to the Environmental Protection

                    Agency on April 28, 1978, and the Program/Final Envirorriental. Impact

                    Statement (FEIS) issued August 24, 1978, and all comments thereon.

                    Based on this review, I have concluded that the Program meets all the

                    requirements of the Coastal Zone Management Act of 1972, as amended,

                    (CZMA) and its implementing regulations and should be approved as set

                    forth below.

                    II. Summary of the New Jersey Program Segment

                    New Jersey has chosen to submit a segment of the.State program pursuant

                    to the provisions of Section 306(h) of the CZMA which states that:

                        At the discretion of the State,and with the approval of
                        the Secretary, a management program may be developed and
                        adopted in segments so that immediate attention may be
                        devoted to those areas within the coastal zone which
                        most urgently need management programs: Provided,

                                                                                        2

                        that the State adequately provides for the ultimate coordination
                        of the various segments of the management program into a single
                        unified program and that the unified program will be completed as
                        soon as is reasonably practicable.

                   The Segment is a State developed program to manage significant

                   land and water areas within:

                        the inland boundary.of the coastal area is defined as the juris-

                        diction of the Coastal Area Facility Review Art, or the Upper

                        Wetlands Boundary of the coastal wetlands located landward of the

                        CAFRAboundary; the seaward boundary extends to the limits of the

                        U.S. territorial waters.

                   The program is based on a series of resource management laws passed

                   during the early 1970's (outlined in Section V) that gave the State

                   direct control over land'and water uses of statewide significance.

                   These laws are administered by the Department of Environmental

                   Protection. Chief among these laws is the Coastal Area Facility

                   Review Act (CAFRA), which establishes a comprehensive permit review

                   for all major facilities proposed for location within its jurisdiction.

                   Also included is the.recent New Jersey Department of,Ehergy Act which

                   provides that the siting of energy facility decisions will be jointly

                   made between the Department of Energy and the Department of Environmental

                   Protection. The land and water use decisions which are only of local

                   significance will continue to be managed by the local governments.

                                                                                         3

                    III. History of the New Jersey Segment

                    The New Jersey legislature passed the Coastal Area Facility Review

                    Act in 1973. Prior to this Art the legislature had passed the Wetlands

                    Act in 1970, The Shore Protection and Waterways Maintenance Act and

                    Acts governing the sale, leasing and management of State-held riparian

                    lands to which the State has held title since colonial days. The

                    preparation of the State coastal management program began in 1974

                    upon receipt of Federal funds pursuant to the CZMA. Concurrently,

                    the State began to prepare a.coastal program for the coastal area

                    from Raritan Bay to the Delaware Memorial Bridge as required by

                    -passage of the CAFRA Statute by the State legislature in 1973. In

                    September of 1977, the State distributed a Coastal Management Strategy

                    Flor New Jersey - CAFRA Area (as mandated by the CAFRA Act). This

                    strategy docunent became the basis for the Program/DEIS released May

                    5, 1978. As part of the DEIS process, the State proposed Chapter 4

                    of the Program as administrative rules of the Department of Environ-

                    mental Protection. 'Ihese proposed rules were revised and adopted,

                    effective September 28, 1978. over 1100 ccoments were received on

                    the Program/DEIS and summrized in the Program/FEIS. On August 28,

                    1978, the Program/FEIS was circulated.

                    IV. The Federal Coastal Zone Management Program

                    'The CZMA was passed in recognition of the importance of the coastal

                    zone of the United States and the potentially adverse effects of

                                                                                       4

                  intense pressures upon this national resource. The Act authorizes a

                  program of financial assistance to encourage the States to better

                  manage their coasts and is administered by the Secretary of Commerce,

                  who in turn, delegated this responsibility to NOAA's Office of Coastal

                  Zone Management.

                  The CZMA states at the outset that "there is a national interest in

                  the effective management, beneficial use, protection, and development

                  of the coastal zone." (Section 302(a)) The Congressional findings

                  describe how competition for utilization of coastal resources, brought

                  on by the increased demands of population growth and econcmic develop-

                  ment, has led to degradation of the coastal enviroment, including the

                  .'loss of living marine resources, wildlife, nutrient-rich areas,

                  permanent and adverse changes to ecological systems, decreasing open

                  space for public use, and shoreline erosion." (Section 302(c)) "The

                  key to more effective protection and use of the land and water resources

                  of the coastal zone is to encourage the states to exercise their full

                  authority over the lands and waters in the coastal zone by assisting

                  the states in cooperation with Federal and local governments and other

                  vitally affected interests in developing land and water use programs ... for

                  dealing with coastal land and water use decisions of more than local

                  significance." (Section 302(h))

                  These broadly stated goals of the CZMA recognize that each individual

                  State should develop a program most appropriate to its unique needs

                                                                                        5

                    and situation. rilius, the State level of government has prime

                    responsibility for achieving effective management of the coastal

                    zone. Under Section 305 of the Federal Act, up to four years of

                    grants are available to 34 coastal States (the Great Lakes are

                    included) to finance up to 80 percent of program development costs.

                    The ent ire process is a collaborative one in which both State and

                    Federal interests are accommodated.

                    After developing a management program the State may submit it to the

                    Assistant Administrator for (bastal Zone Management for approval.

                    If the Program is approved, the State is then eligible for annual

                    grants under Section 306 to administer its management program.

                    In considering a segment of a program for Federal approval, the

                    Assistant Administrator reviews it in accordance with the following

                    general requirements:

                         1) That the Management Program is comprehensive. The CZMA

                    emphasizes that important ecological, cultural, historic and aesthetic

                    values are being lost or adversely affected by population growth and

                    economic development in the coastal zone.

                         2) That the policies, standards, objectives and criteria upon

                    which decisions pursuant to the program will be based are articulated

                    clearly and are sufficiently specific to provide (a) a clear understanding

                                                                                        6

                   of the content of the program, especially in identifying who will be

                   affected by the program and how, and (b) a clear sense of direction and

                   predictability for decision makers who must take actions pursuant to

                   or consistent with the Managemei.it Program; and

                        3) That there are sufficient policies of an enforceable nature

                   to insure the implementation of and adherence to the Management Program.

                   OCZM has issued regulations providing additional guidance on State

                   program development and approval pursuant to the CZMA requirements.

                   (15 CFR Part 923,43 F. IL-g. 8378 et seq., March 1, 1978). These

                   regulations, which reflect the CZMA's Federal-State collaborative

                   process and the need to respond to unique State coastal needs, form

                   the basis of my decision to approve the Program.

                        4) If a State intends to adopt its Management Program as a

                   segment, it shall so advise the Assistant Administrator as early as

                   practicable, stating the reasons for segmenting the program and

                   requesting the Assistant Administrator's approval. In addition

                   to meeting the approval requirements of these regulations, each

                   segment of a Management Program must demonstrate that:

                            a) The segment includes a geographic area on both sides

                   of the coastal landwater interface;

                            b) A timetable and budget have been established for the

                   timely completion of the remaining segment(s); and

                                                                                   7

                            c) The State will exercise policy control over each segment

                   of its management program prior to and following its integration

                   into a conplete State Management Program. D2monstration of this

                   control will include (i) ccmpletion of the management boundary

                   determination for the entire coastal zone throughout the State and

                   (ii) consideration of the national interest throughout the State's

                   entire coastal zone in the planning for and siting of facilities.

                   V. What the New Jersey Program Will Achieve

                       Program approval will provide funds to allow the State to:

                            a) Increase the permit review staff for the Riparian

                   Statutes, Wetlands and (bastal Area Facility IL-view Programs by

                   eight new positions,

                            b) Add specificity and predictability to the above permitting

                   programs through administration of the new "Goastal FL-sources Eevelopment

                   Policy" Regulations adopted September 28, 1978, as a result of this

                   programl

                            c) Increase the enforcement staff for the Riparian, Wetlands

                   and CAFRA programs,

                                                                                 8

                           d) Provide technical assistance  to the Water programs, Green

                  Acres Program and Air Programs within DEP through increases to the

                  NJ/CZM staff,

                           e)  Prepare ecological-sensitivity maps required for

                  administration of the "0:)astal resource and Development Policy"

                  Regulations,

                           f) Develop Dune Protection legislation and recommendations

                  to the legislature within the first year of Program approval,

                           g) Assure consistency with the Program of all Federal and

                  State actions in the coastal zone, through review of Federal permits

                  and licenses and State actions that affect the coastal zone,

                           h) Increase Nj/CZM staff to work with N.J. Department of

                  Ehergy on OCS activities, and develop more specific energy facility

                  siting criteria,

                           i) Support and promote beach access to beaches and other

                  water areas and continue the Beach Shuttle service to Island.Beach

                  State Park, and

                                                                                       9

                            j) Fully consider the national interest in the use of the

                   coastal zone.

                   VI. Major Issues and Resolutions

                   The process of program development, which often involves the recon-

                   ciliation of conflicting interests in the coastal zone, inevitably

                   results in controversy. The segment is the product of numerous

                   choices made during the four years of development. Those interested

                   in the segment have raised a nLmber of concerns during the EIS

                   process. These issues are:

                        1) Does the State have adequate legal authorities to meet the

                            requirements of the Federal 0:)astal Zone Management Act?

                        2)  How does New Jersey meet the requirements of Section 306(h)

                            program segmentation?

                        3) How will the segment program manage the cunulative impacts

                            of small projects not regulated under CAFRA?

                                                                             10
                     J

                         4) Has the State adequately considered the national interest

                              in planning for and siting facilities in the State's coastal

                              zone?

                         5)   Is the Memorandum of Understanding between the New Jersey

                              DEP and the New Jersey DOE satisfactory for program approval

                              and legally enforceable?

                     I have considered all comments and have concluded that these objections
                                                               l/
                     do not present a legitimate bar to approval-, With respect to the five

                     major issues:

                         1) The State does have adequate_legal authorities to meet the

                              E2gLArements of the CZMA.

                              Issues Raised by Comwntors   The program does nothave

                              adequate laws to meet the authorities' requirements of the

                              CZMA; the program doesn't incorporate related State laws;

                              and the policies and regulations have not been adopted by

                              DEP.

                     l/ All comments received on the DEIS are summarized and responded

                       to in Appendix M of the FEIS.

                             Carments - New Jersey Petroleum Cbuncil, U.S. Department of

                             Energy, Environmental Protection Agency, Public Service

                             Electric and Gas Co., Jersey Central Power and Light Co.,

                             New Jersey Builders Association.

                             Response

                             The New Jersey Bay and Ocean Shore Segment has been submitted

                             as a direct State control program (Section 306(E)(1)(B)) to

                             meet the requirements of the CZMA. This particular section

                             of the Act allows a State to develop a program based on a

                             "single, comprehensive piece of legislation specific to

                             coastal management and the requirements of this Act, or on

                             the basis of several different, often pre-existing State

                             authorities which are compatible with and applied on the

                             basis of the coastal management policies." (923.42(d)(1))

                             In addition to the CAFRA law, all relevant-laws have been

                             incorporated into the Segment. The policies of the program

                             have been promulgated as regulations for the Cbastal Area

                             Facility Review Act, Wetlands Art, Waterfront Development

                             Permit Program and the Financial Assistance Shore Protection

                             Program, thus assuring that these programs will be operating

                             consistently with the program. In addition, the policies

                                                                                          12

                              applicable to the Spill Control and Compensation Act and

                              the Soil Erosion and Sediment Control Act as well as to the

                              Federal Clean Air Act and Federal Water Pollution Control

                              Act have been drawn directlv fran those acts or their existing

                              requlations or are incorporated bv reference, thus assuring

                              consistency with the program.  Other DEP programs such as

                              the Stream Encroachment Act, Flood Hazard Areas Act, Waterwav

                              Maintenance Program and the Green Acres Program will be

                              consistent with the Program by being subject to receiving

                              permits from the CAFRA, Wetlands and riparian programs

                              and/or by virtue of the committment in the Commisioner's  letter

                              on paqe ii of the FEIS which states that each agency within DEP will

                              act consistently with the policies of the Bay and  Ocean Shore

                              Segment as outlined in Chapter Four. Specificially, Section

                              1.3 of the adopted rules (Chanter Four) states that the

                              -policies of the Program will apply,  to the extent statutorilv

                              permissible, to all coastal management and Planning actions

                              of DEP. Also, Chapter Five has outlined a conflict resolution

                              process for resolving conflicts within DEP on actions affecting

                              tbe coastal zone.

                              Although the FEIS contained the rules in revised draft form, they were

                              adopted September 28, 1978, prior to program approval.

                                                                                        13

                         2) The segment meets the requirements of Section 306(h) - program

                             segmentation.

                             Issues Raised by Conmentors - The State has not established a

                             boundary for the entire State and has not adequately con-

                             sidered the national interest throughout the entire coastal

                             zone.

                             Comments - Public Service Electric and Gas Co., Jersey Central

                             Power and Light Co., New Jersey Natural Gas Co., New Jersey

                             Petroleum Council.

                             Response

                             The State has proposed a management boundary for the entire

                             State (see Chapter Two and Appendix E) based on the following

                             areas:

                                 a) Bay and Ocean Shore Segment

                                    The landward and seaward boundary as defined in Chapter

                                    Two of the FEIS.

                                 b) Hackensack Meadowlands

                                    The area defined by the jurisdiction of the Hackensack

                                    Meadowlands Development Ccmmission.

                                                                                        14

                                c) Delaware River Waterfront fran the Delaware MEmorial

                                   Brid@Le to Trenton

                                   The area from the water's edge inland to the first

                                   road or cultural feature.

                                d) Northern Waterfront from Raritan Bay to the New York

                                   Border

                                   The area frcrn the water's edge inland to the first road

                                   or cultural feature.

                        The Hackensack Meadowlands, Delaware River, and Northern waterfront

                   areas will be ccmbined with the Bay and Ocean Shore to form the entire

                   State program in 1979. The State has established a timetable and

                   budget for completing the remainder of the State program to meet

                   the requirements of 923.61(a)(2), (See Chapter Eight).

                        There seem to be confusion by some of the commentors; over the

                   requirements of 15 CFR 923.61(a)(3) of the Federal Regulations.

                   This section recognizes that, before a program segment can be approved,

                   it must meet approval requirements in the Coastal Zone Management Act

                   and implementing regulations, just as a total program must. It*also

                   provides that the State,must demonstrate that it will exercise policy

                   control over each segment of its management program prior to and

                                                                                           15

                     following its integration into a coffplete State management program.

                     This requirement refers to control to be exercised in the future,

                     after adoption and approval of such additional segments. If total

                     policy control were in effect at the present time, the whole purpose

                     of segmented approval would be obviated. In Section 923.61(2)(3), two

                     elements are specified which, at a minimum, must be considered by

                     states.at the time of segment approval: (a) boundary determination

                     and (b) national interests in major facilities. Although such elements

                     for future segments need not be in effect or in operation at the time

                     of approval of an-earlier segment,  the State must include at such

                     earlier time a general description of its consideration of at least these

                     two elements.

                         New Jersey has ccmpleted the management boundary for the Bay

                     and Ocean Shore Segment and has proposed a management boundary for the

                     remainder of the State's coastal zone. The State does not need to

                     identify the authorities upon which it will rely in this area at

                     this time.

                         New Jersey has also met the requirements defined in Section 923.61

                     (a)(3) of the Federal Regulations for consideration of the national

                     interests in a coastal zone segment. The State considered the national

                     interests throughout the entire coastal zone in preparing the program

                     T

                                                                                         16

                    for the Segment. Such consideration is demonstrated by the policies

                    in Chapter Flour, and is described specifically in Chapter Six.

                    In addition, New Jersey will continue to consider the national in-

                    terests in its preparation of a program for the rest of the coastal

                    zone.

                         3) The Segment need not manage all the cumulative inpacts of

                             small projects not regulated under CAFRA.

                             Issues Raised by Conmentors; - The program doesn't address

                             the cumulative impacts of projects not covered by CAFRA

                             (under 25 units).

                             Convents - Cape May County Planning Board, New Jersey

                             Conservation Floundation, Sierra Club, New Jersey office of

                             Fiscal Affairs, New Jersey Builders Association, Monmouth

                             Clounty Planning Board, Natural Resources Eefense Council,

                             Environmental Protection Agency.

                             Response:

                             In 1973, the New Jersey Legislature established the threshold

                             for coastal developreent permits under CAFRA at 25 or more

                             dwelling units for new housing developments. DEP adopted

                                                                                        17

                             Procedural Rules and IL-gulations under CAFRA at 25 or more

                             dwelling units for new housing developments. In April,

                             1977, DEP adopted Procedural Rules and Regulations under

                             CAFRA which defined the threshold limit for DEP review

                             under CAFRA parking facilities at 300 or more parking spaces

                             for motor vehicles. (N.J. A.C. 7:7D-2.2) This definition

                             of parking facilities is presently under litigation (New

                             Jersey Builders Association vs. DEP.) and any changes to

                             this administrative rule will require a revision to this

                             program reflecting such changes.

                             The interim final Federal Fegulations (15 CFR 923) promul-

                             gated pursuant to the CZMA do not require that a State address

                             the cumulative impact of a series of small scale developments.

                             'Ihe regulations speak instead in terms of issues of concern

                             to the State in its effort to protect and manage coastal

                             resources@. Given the developed nature of much of the shore-

                             line of this proposed segment, I believe that the provision of

                             New Jersey law to review all proposed development in wetlands

                             and riparian lands and to limit review to major projects

                             elsewhere in the Segment is consistent with a reasonable

                             interpretation of program approval requirements.

                                                                                        18

                             Ihis is not to say that the DL=w Jersey program does not

                             consider and, to a large extent, manage cumulative impacts

                             from a number of sources. First, the Re-source Policy on

                             Secondary impacts (Section 5.14 of Chapter Fbur) insures

                             that each decision subject to the (bastal Program will

                             consider the potential impact on futuredevelopment.

                             Furthermore, the Goastal Location Acceptability Method is

                             designed so that each decision will be influenced by

                             existing development in the area.

                             Second, the small developments not directly regulated by

                             the (bastal program are indirectly affected by program

                             decisions. The funding and siting of infrastructure, such

                             as sewers, roads, and shore protection structures, has a

                             major impact on future development. Similarly, the setting

                             of air and water quality standards by DEP influences the

                             pattern of development.

                         4) The State has adequately considered the national interest.

                             Issues Raised by Ccmmentors - The program has not adequately

                             considered the national interest because 1) it gives a preference

                             for oil-fired electric power plants over nuclear and coal-

                             fired plants in the segment, 2) and the process for considering

                             the national interest is not adequately described.

                                                                           19

                           Capments: Public Service Electric and Gas Co., Jersey

                           Central Power and Light Cb., New Jersey Natural Gas Co.,

                           New Jersey Petroleum Gouncil.

                           Response:

                           Some ccnuents concerned the program's adequacy in considering

                           the national interest in energy facility siting as required

                           by Section 306(c)(8) of the C-ZMA. The comments suggest

                           that the program's preference for oil-fired generation over,

                           nuclear and coal-fired generation clearly conflicts with the

                           national goal to encourage nuclear and coal-fired generation

                           to reduce use of oil for generation ofelectric power. The

                           comments criticized the program's failure to adequately

                           consider the national interest in the orderly exploration,

                           development, and transmission of domestic oil and natural

                           gas and importation of LNG. Because of a description in the

                           FEIS one comment expressed concern that all power plants might

                           be excluded from the segment.

                           The coastal program as revised in the Program/FEIS does not

                           express a preference for oil, nautural gas or any other type

                           of electric generation, nor does it exclude LNG or power plants

                           including nuclear facilities. 'Ihe program requires that facilities

                           ccmply with applicable State and Federal regulations, that if a

                                                                                       20

                            facility requires any one of these permits, the process for

                            consideration of the national interest shall be Chapter

                            Four of the Bay and Ocean Shore Management Program. If a

                            permit application for an energy facility is submitted, DEP

                            will forward copies of the applications to DOE which shall

                            submit an energy report for consideration by DEP during its

                            review process. The report shall describe national interests,

                            if any, in the facility. DEP's decision must explain any

                            differences with the report and, if necessary, an Energy

                            Facility Review Board can be convened to resolve such

                            differences. I believe this process is sufficient to meet

                            the requirements for consideration of the national interest

                            under Section 306(c)(8) and the requirements for segmentation

                            under 923.61(3)(ii). Further, under CAFRA, DEP shall issue

                            a permit only if it finds the proposed facility is located

                            or constructed so as to neither endanger human life or

                            property nor otherwise impair the public health, safety and

                            welfare. The clause "public welfare" has been defined in

                            Section 1.1 of Chapter Four, which has been adopted as

                            Administrative Rule, to include a full consideration of

                            national interests.

                                                                                        21

                         5) The MOU between the New Jersey DDE and the New Jerse

                             DEP is satisfactory and enforceable.

                             Issues Raised by Ccmmentors - The MOU between the New Jersey

                             DOE and New Jersey DEP is unclear on how the process will be

                             carried out by both agencies; it is unclear if the procedural

                             regulations of the Energy Facility Review Board will be

                             adopted prior to program approval.

                             Conuents: Public Service Electric and Gas Co., New Jersey

                             Public Advocate, New Jersey Petroleum Cbuncil, Environmental

                             Protection Agency.

                             Response:

                             Section 305(b)(6) of the Federal CZMA requires a State's

                             Management Program to include a description of the organi-

                             zational structure proposed to implement the program.,

                             Comment (c) to 15 CFR 923.45 (organizational structure)

                             says "The main purpose of this requirement is to provide

                             a closer understanding of the entities that have responsibility

                             for administering various aspects of the management program

                             and the interrelationship of these entities." I believe

                             that the memorandum of understanding in Appendix G accomplishes

                             this.

                                                                                       22

                            The memorandum outlines the decision making process to be

                            followed and the policies on which such decisions will be

                            based. Because both agencies are involved, it insures that

                            all the various interests and needs addressed by the Federal

                            Act will be considered in any decision. In short, it clearly

                            outlines the interrelationship of the two agencies.

                            The procedure outlined by the memorandum has as its end product

                            a CAFRA, Wetlands, or riparian permit decision, which not

                            only makes the decision accountable to the coastal management

                            policies, but also subject to appeal by affected persons.

                            Should a decision be referred by N.J. DOE to the Energy

                            Facility Review Board, and keeping in mind that N.J. DOE

                            has ccomitted itself to the coastal management policies as

                            well as the Energy Master Plan as the basis for its report,

                            it then becomes a matter of resolving the different inter-

                            pretations of the coastal policies by the N.J. DEP and the

                            N.J. DOE. Such a procedure is recognized as valid in the

                            Federal Regulations, 15 CFR 923.42 (control techniques).

                            The revised memorandum reflects this in Section F.3.

                            Procedural regulations governing the Energy Facility Review

                            Board will be adopted during the first year of Coastal

                                                                                        23

                             Program inplementation (see revised Memorandum of Under-

                             standing, Appendix G. Because there are no current, active

                             proposals for energy facilities in New Jersey, I do not

                             believe that the short-term absence of such regulations

                             will in any way delay or otherwise affect energy facility

                             siting in New Jerseyi

                                                                                         24

                             VII.   Detailed Findings on the New Jersey Prograrn

                    Having ccmpared the basic structure of the Program with the general

                    requirements of the Program, I now turn to the question of how the Program

                    satisfies the specific requirements Of the Act and regulations.

                    These findings follow the organizational scheme of the Federal Regu-

                    lations (15 CFR Part 923). They begin by reviewing the uses subject

                    to the Program (Subpart B) and the special management areas involved

                    (Subpart C); next describe the general area that encompasses the uses and

                    special areas, i.e., the boundary (Subpart D); then turn to the

                    authorities and organization necessary for management (Subpart E);

                    and finally examine the public process by which the Program was

                    developed (Subpart F).

                    Section 1 - Uses Subject to Managen-ent (15 CFR Part 923, Subpart B)

                    (A)  The Management Program includes "a definition of what shall,

                         constitute 122rmissible land uses and water uses within the

                         coastal zone which have a direct and significant

                         impact on the coastal waters." (Section 305(b)(2); 15 CFR

                         (923.10-923.12.)

                    T                                                                 25

                  Any use involving construction on or alteration of riparian lands and

                  any use* occurring in a coastal wetland are subject to the Management

                  Program. For the remainder of the coastal area, all facilities

                  defined under CAFRA require a permit. I find the definition of uses

                  provided by these three State regulatory programs includes all uses

                  which have direct and significant impact on the coastal water. The

                  uses subject to CAFRA are listed in Section 13:19-3 of the Act

                  and on pages 289-290 of the program.

                  Chapter Ebur, Section 4.0, presents a set of policies for particular

                  uses of coastal resources. It should be not6d that proposed develop,--

                  ment must meet the standards of the location Policies and I;L-source

                  Policies, in addition to the Use Policies, described below:

                       1) Housing: Me Program prohibits housing development in the

                           water's edge (4.2.2) (defined on page 83 of the Program/FEIS)

                           and discourages residential development involving the

                           destruction of existing structures, unless rehabilitation

                           of the existing structures is,impractical and infeasible

                           (4.2.71). The Program encourages cluster housing development

                           (4.2.3), housing that provides a mix of dwelling types

                           for persons of different ages and inccmes (4.2.4), and housing

                           development that encourages public transportation (4.2.7).

                    Except mosquito control or certain agricultural practices.

                                                                                           26

                              Highrise housing developments are permitted subject to

                              certain conditions designed to minimize the traffic and

                              visual iqpact of such projects. (7.2.8).

                          2) -IL-sort-IL-creational: This type of use is given priority over

                              all other uses in the region (4.3.1). Pesidential,

                              individual, and hotel-motel developments encourage recreational

                              uses (4.3.2), (4.3.4), and all private or public resort-

                              recreation development adjacent to coastal waters must

                              provide for public access to the shorefront (4.3.3). Casino

                              development in Atlantic City is encouraged to locate in the

                              city's traditional resort area (4.3.5). *New armsement

                              piers are prohibited, except in area under riparian grants,

                              where they are discouraged (4.3.11).

                          3) Energy:    Energy facilities are subject to joint review by

                              N.J. DEP and the N.J. DOE. The Program encourages OCS

                              exploration and development, "as long as all related

                              onshore activities do not conflict with existing land

                              uses and are conducted in an environmentally sound manner."

                              (4.4.2). Discouraged activities include platform fabrication

                              yards (4.4.6), and gas processing plants (4.7.14). Pipelines

                              frcm the OCS and nuclear power plants are acceptable in

                                                                                      27

                             the Segment subject to certain conditions (4.4.7, 4.4.13).

                             Energy conservation and alternative technologies are

                             encouraged in the coastalzone (4.4.15).

                         4)  Public Facilities: Proposals to construct new or expanded

                             public facilities are acceptable provided the facility would

                             serve a demonstrational need, and alternate technologies,

                             including conservation, are impractical or infeasible (4.5.1).

                             Detailed policies are also provided for public and private

                             transportation facilities, waste disposal sites, and

                             wastewater treatment systems.

                         5)  Industry-Ccumerce: New or expanded coastal dependent

                             industrial or commercial develor-ment is encouraged to locate

                             at or adjacent to existing sites, except new sites may be

                             acceptable provided that the development can demonstrate

                             a high jcbs/area ratio, and the development poses no

                             conflict with resort-recreation uses of the coast. Mining

                             is acceptable only in sites immediately adjacent to current

                             mining operations (4.6.2), and major parking lots are

                             acceptable subject to certain conditions.

                                                                                    28

                       6)  Ports: Port-related development and marine commerce is

                           acceptable only in or adjacent to established port areas.

                       7)  Shore Protection: Structural measures are acceptable only

                           under certain stringent conditions (4.8.5). Dune restoration

                           and beach nourishment projects are encouraged (4.8.2).

                  (B) The policies andprocedures defining the permissibility of

                       uses are sufficienLJX canprehensive to address the national

                       findings and policies of sections 302 and 303 of the CZMA.

                       (Section 306(c)(1); 15 CFR 923.11, 923.12 and 923.3)

                       The policies for those uses subject to the program are admirably

                       comprehensive in addressing the basic concerns and policies of the

                       CZMA. Program policies are divided into Location Policies, use

                       Policies, and Fesource Policies. These three sets of policies con-

                       stitute a comprehensive, three-stage screening process for the

                       review of proposed coastal activities.

                       There are over 100 enforceable, specific policies in the program

                       which deal with such issues ranging frcm, protection of coastal

                       waters, ecological, to historic and aesthetic standards for

                       developments requiring a permit under the program.

                                                                                      29

                    (C) The Program provides for a "method of assuring that local

                         land and water use regulations within the coastal zone do not

                         unreasonably restrict or exclude land and water uses of

                         regional benefit." (Section 306(e)(2);'15 CFR 923.13, 923.43.)

                         In New Jersey, uses of regional benefit include energy gen-

                         erating and distribution facilities operated by public utilities

                         (not refineries and tank farms), water and sewer facilities,

                         solid waste collection and disposal systems, roads and high-

                         ways, parks, housing,for people with low or moderate incomes,

                         facilities necessary for State or national defense, and the

                         use of wetlands and wet beach areas.

                         Local.governments are prevented from unreasonably excluding

                         these uses by one or more of three factors. 11he most significant

                         factor is the State's power to overrule a local decision

                         denying approval to any public utility.

                         This State authority includes the power to supercede local

                         zoning laws,when necessary if the service conveniences the

                         welfare of the public (N.J.S.A. 40:55D-19). %be term public

                         utility includes roads, street railway, traction railway,

                         autobus, canal, express subway, pipeline, gas, electric light,

                                                                                      30

                         heat power, water, oil, sewer, solid waste collection, solid

                         waste disposal, telephone or telegraphic system, or plant or

                         equipment for public use (N.J.S.A. 48:2-13).

                         Second, the State of New Jersey has the power of eminent

                         domain for any facilities necessary for State or national defense

                         (N.J.S.A. 20:1-3.1), airports (N.J.S.A. 20:1-3.1), State

                         highways (N.J.S.A. 27:7-44.6), parks and open space under

                         the Green Acres Program (N.J.S.A. 13:8A-24).

                         The New Jersey Supreme Court has established in Southern

                         Burlington County NAACP v. Township of Mt. Laurel, 67 N.J.

                         151 (1975) that nunicipalities must "presumptively make

                         realistically possible an appropriate variety and choice

                         of housing . . . at least to the extent of the rmnicipality's

                         fair share of the present and prospective regional need. . ."

                         The Department of O=mnity Affairs is developing guidelines

                         to implement this ruling.

                     r
                                                                                     31

                   (D)  The Management Progran does not include "a plannipg process

                        for energy facilities likely to be located in, or which 2@y

                        significanLly affect, the coastal zone, including, but not

                        limited to, a process for anticipating and managing the impacts

                        fran such facilities." (Section 305(b)(8); 15 CFR 923.14)

                        New Jersey will meet this requirement as part of its final

                        submission which integrates this segment with the remainder

                        of the State's coastal program as provided under 923.61(e).

                  Section II    Special Management Areas (15 CFR Part 923, Subpart (c))

                   (A) The management program includes an inventory and designation

                        of areas of particular concern within the coastal zoneD(Sec.

                        305(b)(3); 15 CFR 923.21)

                        This segment proposes two generic geographical areas of particular

                        concern and nine specific geographic areas of particular

                        concern. These include all coastal wetlands, all wet sand

                        beaches, Higbee Beach in Tower Township in Cape May (bunty,

                        Cape May Point Natural Area, Cape May Wetlands Natural Area,

                        Strathmere Natural Area, North Brigantine Natural Area, Great

                        Bay Natural Area,, Island Beach State Park and Swan Point

                        Natural Area.

                                                                                    32

                         These GAPC's were designated on the basis of the regional or

                         State-wide significance of the area and the need for special

                         attention based on the threat to the preservation of the area

                         or obstacles to its development. An inventory has been comr-

                         pleted for each of the designated GAPC's.

                    (B)  The managenient program includes "broad guidelines on

                         priorities of uses in particular areas, includiD2 specifically

                         those uses of lowest priority." (Section 305(b)(5); 15 CFR

                         923.22)

                         The State has established broad guidelines regarding priorities

                         of uses throughout all geographic areas of particular concern.

                         These priorities include:

                         1) Coastal Wetlands. The priority of uses in coastal wetlands

                         is as follows:

                             a) Open space (no development or disturbance).

                             b)  Development which (1) requires water access or is

                                 water-oriented as a central purpose of the basic function

                                 of the activity; (2) has no prudent or feasible alternative

                                 on a non-wetland site; (3) will result in minimum feasible

                                 alteration or inpairment of natural tidal circulation;

                                                                                     33

                            and (4) will result in minimum feasible alteration or

                            impairment of the natural contour of the natural vegetation

                            of the wetlands.

                            c) Other development has lowest priority.

                        2) Wet Sand Beaches. r1he priority of uses in the wet sand

                        beach areas is:

                            a) R--creation.

                            b)  Navigation and commerce.

                            c)  Development with no prudent or feasible location on

                                a non-beach (wet sand) location.

                            d)  All other uses have lowest priority.

                        3)  Higbee Beach

                            The set of uses with priority in the Higbee Beach-Pond

                        Creek Area includes only recreation conpatible with protection

                        of the area's wildlife. All other uses have lowest priority.

                                                                                      34

                   Ebr the following areas: Cape May Point Natural Area (Class II),

                   Cape May Wetlands Natural Area (Class III), Strathmere Natural Area

                   (Class III), North Brigantine Natural Area (Class II), Great Bay

                   Natural Area (Class I), Swan Point Natural Ared (Class II),

                   Manahawkin Natural Area (Class III), the Natural Areas System

                   Regulations establish a priority of uses for each category of

                   natural areas. These include:

                        Class I Natural Areas: a) The Department shall manage such

                   areas for ecological research and study. When conpatible with other

                   uses they may be used for guided nature tours; and b) all of Class I

                   natural areas shall be restricted to entry by permit or with a

                   designated Department employee.

                        Class II Natural Areas: a) The Department shall manage  Class I

                   areas for the specific purpose of interpretation of natural pro-

                   cesses, flora and fauna of this State. Class II areas may be used

                   for ecological research and study; and b) use of Class II areas

                   shall be limited to interpretive purposes or shall be restricted

                   to entry by permit for research purposes.

                       Class III Natural Areas: a) The Department shall manage class

                   III areas for recreational use, interpretive study, wildlife

                   propagation, and succession control; and b)-Use of Class III shall

                   be limited to interpretative purposes, swimming, canoeing, rowboating,-

                                                                                      35

                    hiking, trailside camping, and recreational hunting, fishing and

                    trapping as provided in the natural areas system rules and regulations.

                    For Island Beach State'Park, special priority of uses include:

                         a) Island Beach Research Area and Wildlife Sanctuary: An

                         area of 1,200 acres encompassing the width of Island Beach

                         State Park and running north for 3.3 miles. It demonstrates

                         a sand dune habitat, it is a wildlife sanctuary, and will

                         serve as a research area. Beach area type III, remainder type

                         b) Island Beach Natural Area: An area of 1,000 acres of the

                         State park, encompassing its width and running 3.3. miles

                         south (excepting maintenance area and official residence),

                         it demonstrates dune habitat and is a botanical preserve.

                         Beach area type III, remainder type II.

                    C)   The management program makes provision for procedures whereby

                         specific areas may be designated for the purpose of preserving

                         or restoring them for.their conservation, recreational, ecological

                         or esthetic values. (Section 306(c)(9), 15 CFR 923.23,923.24)

                    The program identifies several existing programs which provide DEP

                    with the authority to designate areas for preservation or restoration.

                                                                                      36

                    The principal means is through the State Green Acres Program. DEP

                    can purchase land or provide local grants for land purchase for

                    park development. Under the Natural Areas System Act, DEP must

                    identify natural areas within DEP-owned and managed lands in need

                    of preservation or protection. The State Wild and Scenic Rivers

                    System Act requires that DEP classify, designate, and administer

                    river areas as wild, scenic, recreational or developed recreational

                    rivers. In addition, the state can apply for funds to purchase

                    wildlife habitat areas under the Endangered Species Act, or may

                    designate areas for preservation or restoration through the New

                    Jersey Register of Historic Places and the National Pegister of

                    Historic Places.

                     D)  The management program does not include a "definition

                         of the term 'beach' and a planning process for the protection

                         of, and access to, public beaches and other coastal areas of

                         environmental, recreational, historical, esthetic, ecological

                         or cultural value.". (Section 305(b)(7); 15 CFR 923.25)

                    New Jersey will meet this requirement as part of its final sub-

                    mission which integrates this segment with the remainder of the

                    State's coastal program as provided under 923.61(e).

                                                                                  37

                  (E), The management program does not include "a planning process

                       for (a) assessing the effects of shoreline erosion (however

                       caused), and (b) studyi!n and evaluating wasto control or

                       lessen the jEpact of such erosion, and to restore areas.

                       adversely affected by such erosion." (Section 305(b)(9);

                       15 CFR 923.26)

                       New Jersey will meet this requirement as part of its final

                       submission which integrates this segment with the remainder

                       of the State's coastal program as provided under 923.61(e).

                  Section III - Boundaries (15 CFR 923, Subpart'D)

                  (A) The management program includes "an identification of the

                       boundaries of the coastal zone subject to the management

                       pro.qam." (Section 305(b)(1); 15 CFR 923.30-923.34).

                  The inland boundary of the Coastal Area of the segment is defined

                  as the jurisdiction of the Coastal Area Facility review Act, or

                  the Upper Wetlands Boundary of coastal wetlands located landward

                  of the CAPRA boundary. (See page 14 of Program/FEIS). The boundary

                  of this segment therefore, runs from Raritan Bay south to Cape May,

                  then along Delaware Bay to the Delaware Memorial Bridge and inland

                  up to 24 miles. The seaward boundary extends to the limits of the

                  U.S. territorial waters. The boundary excludes all land the use

                                                                                    38

                    of which is by law subject solely to the discretion of or which is

                    in trust by the Federal Government, its officers or agents in

                    accordance with 15 CFR 923.33.

                    Section IV - Authorities and Organization (15 CFR,,Part 923,

                    Subpart E)

                    (A) The State is organized to iniplement the Program and

                         has the authorities necessary to do so (Sections.305(b)(4,

                         305(b)(6), 306(c)(6), 306(c)(7), 306(d), 306(e)(1);

                         15 CFR 923.40-42)

                    The Department of Environmental Protection is the 1ead agency

                    and, within it, the Division of Marine Services is principally

                    responsible for implementing the New Jersey Goastal Program, and

                    for continuing coastal planning. Ehergy siting decisions will be

                    made jointly by N.J. DEP and the Department offhergy consistent with

                    the coastal policies as outlined in the MOU between New Jersey

                    DOE and New Jersey DEP.

                    The Department of Environmental Protection was delegated broad

                    authority.to "formulate conprehensive policies for the conservation

                    ofthe natural resources of  the State" in 1970. In addition, the

                    Governor specifically designated DEP as New Jersey's coastal

                    planning agency under the (bastal Zone Management Act. The

                                                                                      39

                    Department's Division of Marine Services administers the major

                    regulatory programs that will be relied on to implement the

                    Program, including permitting under the Coastal Area Facility

                    Review Act (CAFRA), the Wetlands Act, and the riparian statutes

                    as described in Chapter V of the Program.

                    The Location, Use and Resources Policies of the Program have

                    been adopted as regulations under these laws in accordance with

                    the State's Administrative Procedure Act. I have found no indication

                    that these regulations are anything but a valid exercise of the

                    State's regulatory authority under these laws and legally binding

                    on the administering agencies.

                    Under the new Department of Energy Act, N.J. DOE and N.J. DEP have

                    "coextensive jurisdiction" with respect to the siting of energy

                    facilities. The review procedures are described in the Memorandum

                    of Understanding between the two departments set forth inAppendix

                    G and include consideration of the N.J. DOE Energy Report by N.J.

                    DEP and articulation by N.J. DEP of the reasons why its permit

                    decision differs from the report. The Department of Energy may

                    request that the Governor convene the Energy Facility review Board

                    in accordance with the Act. It is composed of the Director of

                    N.J. DOE's Division of Energy Planning and-Conservation, the

                                                                                      40

                   Commissioner of DEP and a third member appointed by the Governor.

                   In such case, the Board will make the final decision on the energy

                   facility permit application in accordance with its regulations of

                   September 28, 1978. Review is limited to the reasonableness of

                   DEP's decision in light of the Energy Report and to comply with

                   the State's Administrative Procedures Act.

                   Therefore, I find that the State is organized to implement the

                   program, that the authorities are adequate to permit implementation

                   and that the relevant agencies are required to act consistently

                   with the Program.

                        B) The requirements of the Federal Water Pollution Control

                        Act, as amended, and the Clean Air Act, as amended, are

                        incorporated in the Management Program as the water pollution

                        control and air pollution control requirements applicable to

                        the Program. (Section 307(f); 15 CFR 923.44)

                   The water and air quality standards established by the Federal

                   Water Pollution Control Act (33 U.S.C. 1251, et seq.) and the Clean

                   Air Act (42 U.S.C. 1857g, et seg.) are part of the Program and are

                   administered by N.J. DEP. (See Page 172 of the Program/FEIS.)

                                                                                      41

                    (C) The Management Progran and arry ch@!Mes thereto have

                         been reviewed and approved by the Governor. The Governor

                         has designated a single agency to administer the grant and

                         inplementthe Program (Section 306(c)(4)(5); 15 CFR 923.46-

                         923.47).

                    The Governor's letter of August 28, 1978, indicates he has reviewed the

                    program, approved the program, and certified that the program contains

                    the necessary authorities and organizational structure for implementation.

                    The Department of Fnvironmental Protection has been designated

                    as the lead State agency.

                    Section V - Coordination, Public Involvement and National Interests

                    (15 CFR Part 923, Subpart F)

                    (A) During the process of Program development, the State

                         has provided the opportunity for full participation by

                         relevant governrmnt agencies having interes ts and

                         responsibilities affecting the coastal zone, all interest

                        .groups and the general public, and held public hearings on

                         the Program (Section 306(c)(1), 306(c)(3); 15 CFR 923.50-

                         923.55, 923.58) .

                                                                               42

                  During the process of Program development, the State provided

                  relevant Federal and State agencies, county governments, local

                  governments, port authorities and interested parties with the

                  opportunity to participate fully as evidenced by the following:

                  - 9be N.J. Office of Coastal Zone Management has held five general

                  meetings to discuss the evolving program with Federal agency

                  representatives, and met with individual Federal representatives

                  on numerous occasions. Agency comments on the Coastal Management

                  Strategy were utilized in preparing the current program document.

                  - In 1977 DEP contracted with twelve coastal counties to provide

                  assistance to N.J. OCZM in developing the energy facility siting

                  element of the New Jersey Coastal Program. This relationship

                  has been continued by passing through funds to mst of the same

                  coastal county planning boards to allow them to contribute their

                  views to the Program.

                  - Since November, 1976, New Jersey OCZM held monthly meetings with an

                  Environmental Advisory Group conposed of leaders of statewide

                  civil and environmental groups.

                                                                                    43

                    The N.J. CCZM has conducted a variety of public meetings, for the

                  purpose of receiving feedback on DEP planning reports. From 1975

                  to 1977, New Jersey OCZM staff attended public meetings in 38

                  municipalities in addition to holding public hearings in 59

                  municipalities on CAFRA permit applications. In addition, a newsletter,

                  The Jersey Coast is distributed to-interested citizens, agencies

                  and interest groups.

                  - N.J. OCZM held a series of workshops on energy involving gas

                  representatives from oil producing coastal states, as well as the

                  oil and gas industry.

                    The State distributed in September 1977 the Coastal Managenent

                  Strategy for public review and cament. Based on comments on this

                  document, a combined DEIS/program document was distributed for

                  public review April 28, 1978. Public hearings on this document

                  were held June 13, 14, and 15 in Bridgeton, Toms River and Trenton,

                  New Jersey. Over 1100 written comments were received on the

                  program/DEIS. @kitten and oral summaries of the comments and re-

                  sponses to these comments are outlined in Appendix M of the FEIS.

                  (B) The views of the Federal agencies principally affected

                       by the Program have been adequately considered.

                       (Section 306(c)(1), 307(b); 15 CFR 923.51).

                                                                                         44

                      Federal agencies were given an early opportunity to participate in

                      the development of the Program. A description of the extensive

                      participation by the Federal agencies is found in Appendix C of

                      the FEIS,.which indicates over 20 opportunities for each agency

                      to exchange comments on the developing program. Comments on the

                      DEIS were received from the following Federal Departments: Agriculture,

                      Gcmerce, Defense,  Energy, Housing and Urban Development, Interior,

                      Transportation, as well as the Army Corps of Engineers, Environmental

                      Protection Agency, Federal Energy Pegulatory Commission and the

                      Nuclear Regulatory Commission. No Federal agency recommended

                      against approval, although each suggested changes that should be

                      made. 11he major issues raised by the Federal agencies focused

                      on the liquified natural gas policies, the nuclear power plant

                      policies, the cumulative impacts of the program, dredging policies,

                      and opportunities for continuing Federal participation. 1Ihese

                      comments as well as the agencies' specific concerns and OCZM's

                      responses to the ccments are treated at some length in Appendix

                      M of the FEIS.

                      I find that the changes in the Program in response to Federal agency

                      comments on the program to be reasonable and adequate.

                      Federal agency comments on the FEIS and OCZM responses thereto are

                      summarized in Attachment A to these findings.

                                                                                      45

                    (C) The Management Progranprovides, for adequate consideration

                         of the national interest involved in planning for, and in the

                         siting of, facilities (including energy facilities in, or

                         which significantly affect, the coastal zone) which are

                         necessary to meet requirements which are other than local in

                         nature. The State has the reans to give consideration to

                         any applicable interstate energy plan or,program. (Section

                         306(c)(8); 15 CFR 923.52)

                    Chapter Six of the Program identifies the facilities in which

                    there may be a national interest in siting in the coastal zone.

                    Identified are the national interest in the benefits to be derived

                    from the siting of national defense facilities, energy production

                    and transmission, recreation facilities, and transportation and

                    ports (pages 182-187); the national interests in air and water

                    quality (pages 187-188); the national interests in wetland protection

                    and preserving endangered flora and fauna, wildlife refuges and

                    reserves and living marine resources (pages 188-189), and the national

                    interest in protecting floodplain and erosion hazard areas, barrier

                    islands, historic sites and districts and areas of unique cultural

                    significance, minerals, prime agricultural lands and forests (pages

                    190-191). This identification was made by consulting Federal

                                                                                       46

                     laws and regulations, policy statements of EKecutive Crders, special

                     reports, studies and comments of Federal and State agencies and

                     public testimony and applicable interstate energy plans.

                     All of the facilities identified above (national defense, energy

                     production and transmission, recreation and transportation) are

                     of sufficient size to require a CAFRA permit if they occur on

                     non-Federally controlled land. Furthermore, these facilities

                     and any other development which would significantly affect the eleven

                     resources described below as in the national interest, (e.g., water,

                     air, etc.) are required to receive a CAFRA permit. Although other

                     Sta te permits would be needed in sane resource areas, i.e., wetlands,

                     the CAFRA permit and an annual review on the coastal resource and

                     development policies would cover all these issues and thus has

                     been identified as the process during implementation of the

                     Coastal Management Program - Bay and 0--ean Shore Segment for assuring

                     the continued consideration of identified nationalinterests.

                     With respect to nuclear electric generating stations, the State

                     recognizes in its revised policy 4.4.13 its limited role in matters

                     of radiological health and safety pursuant to the Atomic Energy

                     Act of 1954, and the Energy Reorganization Art of 1974, as interpreted

                     by court decisions establishing the respective jurisdictions of the

                     )                                                             47

                     Federal Nuclear Regulatory Ccmission and the State (see inter alia

                     Public Interest Research Group vs. State of New Jersey). As a further

                     clarification for purposes of consistency determination-under S307 of the

                     Federal Act, the provision of policy 4.4.13(e) with regard to the

                     storage and disposal of spent nuclear fuel shall apply only to the

                     extent described above, and only to sites significantly affecting the

                     State's coastal zone.

                     With respect to any Federal license or permit the State's review

                     of the application for that license or permit, for Federal consistency

                     purposes, will be limited to the scope of the review of that-application

                     as established under State and Federal law. Fbr example, in the

                     case of the renewal of an operating permit for a functioning nuclear

                     power plant, the review under both ISLaw Jersey State law and for

                     Federal consistency is limited first to the jurisdiction described

                     in the above paragraph, and then to only issues such as operating

                     practices and changed conditions. Ihe review could not reopen an

                     issue such as proper siting of the existing facility.

                     The CAFRA law states that the (bTrmissioner of DEP "shall issue a

                     permit only if he finds that the proposed facility . . . is located

                     or constructed so as to neither endanger hunan life or property

                     nor otherwise inpair the public health, safety and welfare."

                     (N.J.S.A. 13:19-10f) The Commissioner has interpreted "public

                     welfare" to include a full consideration of national interests as

                                                                                      48

                    described in the program. This interpretation is contained in

                    Chapter Flour, which has been adopted as regulations. In addition,

                    the Department of Energy will interpret its mandate       to con-

                    tribute to the proper siting of energy facilities necessary to

                    serve the public interest. . ." (N.J.S.A. 25:27f.2) as sufficient

                    authority to consider the national interest in the siting of coastal

                    energy facilities (see Section I of MOU between DEP and DOE, Appendix

                    G, page 284).

                    (D) The State has "coordinatedits program with local,

                         areawide and interstate plans applicable to areas within

                         the coastal zone existingon January 1 of the year in which

                         the State's Management PE2Qram is submitted to the Secretary,

                         which plans have been developed by a local government, an

                         areawide 2Qency designated pursuant to regulations

                         established under Section 204 of the Demonstration Cities

                         and Metropolitan Development Act of 1966, a regional

                         agency, or an interstate agency.", Section 306(c)(2);

                         15 CFR 923.56)

                    The Program was coordinated with local areawide and interstate plans

                    by means of a variety of mechanism existing on January 1, 1978,

                    the year in which the Program was submitted.

                                                                                      49

                   The Department of Cmurunity Affairs has prepared a State Development

                   Guide Plan pursuant to Section 701 of the Federal Housing and

                   Cbnununity Development Act. r1he housing element of the policy

                   docL=ent provided input for the Coastal Program's housing policies.

                   'Ihe administrative record contains a listing of, coordination with

                   local governments as of January 1, 1978.

                   N.J. OCZM consulted with the following regional and interstate

                   agencies: the Mid-Atlantic Regional Fisheries Management Council,

                   the Wilmington Metropolitan Area Planni ng Coordination Counci 1'.

                   the Tri-State Regional Planning Commission, the Delaware Valley

                   Regional Planning Ommission, and the South Jersey Resource Conservation

                   and Development Council.

                   (E)  The State has established an effective rrechanism for continuing

                        consultation and coordination between the State and with local

                        governments, interstate agencies, regional agencies and area-wide

                        agencies within the coastal zone to assure the full partic@2aticn

                        of such local governments and agencies in carrying out the purposes

                        of the CZMA. (Section 306(c)(2)(B); 15 CFR 923.57)

                                                                                     50

                   The Goastal resource and Eevelopment Policies will provide the basis

                   for N.J. OCZM consultation and coordination with local governments,

                   regional and interstate agencies and agencies from other states

                   with an interest in the coast.

                   The Department of Community Affairs will continue to participate

                   in the review of CAPRA permit applications as will the Department

                   of Labor and Industry.

                   Development proposed in the coastal zone will be subject to all

                   applicable local regulations as well as to State standards on

                   permits. A locally approved proposal cannot be constructed without

                   receipt of relevant State-approved project permits.and receive

                   appropriate local approvals., CAPRA Procedural Rules and regulations

                   require that CAPRA permit applications be offered for review and

                   comment by county and mun icipal planning boards and environmental

                   commissions.

                   Gontracts between the DEP and twelve coastal counties afford the

                   counties the opportunity to ccmment on CAPRA, Wetland and riparian

                   permit applications, and review the consistency of State, county

                   and municipal plans. In the future, certain county and municipal

                   plan s may be adopted as specific elements of the State Goastal

                   Program.

                                                                                      51

                     VIII. The State has develcped and adopted a progran segment which

                     meets approval requirements for segmntation and adequately provides

                     for the ultimate and expeditious coordination of the segments into

                     a single unified program (Section 306(h) and 15 CFR 923.61).

                     The State has proposed a management boundary for the entire State

                     (See Chapter Two of the Program/FEIS)/

                     The State is ccmitted to unify the Bay and Ocean Shore Segment with

                     the remainder of the State program in 1979. The State has established

                     a timetable and budget for completing the remainder of the State

                     program to meet the requirements of 923.61(a)(2). (See page 209 of

                     Program/FEIS)

                     New Jersey has also met the requirements defined in Section

                     923.61(a)(3) of the Federal regulations for consideration of the

                     national interest in a coastal zone segment. The State considered

                     the national interests throughout the entire coastal zone in preparing

                     the program for the Segment. Such consideration is demonstrated

                     by the policies in Chapter Four, and is described specifically in

                     Chapter Six. in addition, New Jersey will continue to consider

                     the national interests in its preparation of a program for the rest

                     of the coastal zone.

                                                                                    52

                   IX. Conclusion

                   Having made the findings set forth above, and having determined

                   that the Bay and Ocean Shore Segment of New Jersey Coastal Zone

                   Management Program meets the requirements of the Coastal Zone

                   Management Act of 1972, as amended, and its implementing regulations,

                   I have approved this Segment on behalf of the Secretary of Commerce,

                   effective

                                                              4L
                 4frttW. Knecht
                   Assistant Administrator
                     for Coastal Zone Management

                    Appendix A

                    Federal Cam-ents Received on the Program/FEIS

                         Several Federal ccmrents were received on the Program/FEIS and are

                    summarized with OCZM. responses below:

                        The National Marine Fisheries Service (NMFS) suggested the

                    "prudent and feasible alternative" standard for Policy 3.2.11.2(a)

                    should be changed to a standard "that the project is in the public

                    interest." This change in the program is unnecessary because the

                    public interest standard is part of the State's Coastal Area Facility

                    Review Act and thus would apply to any activity that may occur in areas

                    covered by Policy 3.2.11.2(a).

                        The Department of Energy (DOE) found the revised program and impact

                    statement substantially responsive to their comments on the DEIS and

                    supports approval of the program. The DOE requests clarification of the

                    intent of the N. J. Department of Energy and the N. J. Department of

                    Environmental Protection to cooperate on the preparation of a Major

                    Energy Facility Study. Both agencies will participate in this study which

                    will be caupleted by the end of 1979. DOE would like a clarification

                    of the phrase "prudent and feasible" that is used in Policy 4.4.13(a).

                    DOE interprets this phrase to, require only a finding that no alternative

                    sitesare identified as superior to the proposedsite. This interpre-

                    tation is incorrect. The "prudent and feasible" phrase includes a wider

                    range of consideration beyond mere alternative site considerations,

                    i.e., fuel source, design criteria, etc. DOE felt that the discussion

                    on page 302 of the Program concerning the N. J. Departrwnt of Environmenta1

                    Protection Commissioner's role in reviewing safety procedures of nuclear

                    power plant applications should be incorporated into Policy 4.4.13(e).

                    The staterent on page 302 of the program is a sumrary of the decision

                    in Public Interest Research   Group v. State of New Jersey 152

                    N. J. Super 191 which is referenced in Policy 4.4.13(e) and is part

                    of the policy statement.

                         The Corps of Engineers supported approval of the program and raised

                    no serious objection to the program.

                                                                       3 6668 14100 9243