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

                  COASTAL MANAGEMENT STRATEGY FOR NEW JERSEY - CAFRA AREA:

                           Public Comments and DEP Responses

                Addendum To: New Jersey Coastal Management Program -
                              Bay and Ocean Shore Segment
                              and Draft Environmental Impact Statement

                                     May 1978

                   New Jersey Department of Environmental Protection
                          Office of Coastal Zone Management
                                   P.O. Box 1889
                             Trenton, New Jersey 08625

                                                             Ub. S. DEPARTMENT Or COMMERCE NOAP
                                                             COASTAL SERVICES CENTER
                                                            ?234 SOULITH HOU3ON AVENUE
                                                            CHARLESTON, SC 29405-2413

    ICS

                                               r-
                                                 r PropOzty of C~;o Lbra ry

    Introduct ion

         This report presents responses by the Department of Environmental Protection
    (DEP) to public comments on the Coastal Management Strategy for New Jersey-CAFRA
    Area.   The Strategy was presented by DEP to the Governor, Legislature, and public
    in-the fall of .1977. The 223 page report was prepared in fulfillment of Section 16
    of the Coastal Area Facility Review Act (CAFRA) and as a draft of New Jersey's
    coastal program to be submitted for approval to the U.S. Department of Commerce
    under the federal Coastal Zone Management Act.

         DEP distributed 3,000 copies of the Strategy and over 6,000 copies of a four
    page summary to interested individuals and groups representing a wide cross-section
    of public officials, private interest groups and interested individuals. Staff of
    DEP's Office of Coastal Zone Management (DEP-OCZM) discussed the report at more
    than  20  informal  meetings  held  throughout  the  coast.   In late November  1977,
    DEP-OCZM convened a series of meetings in eight coastal counties which were
    attended  by over 300 people.   Appendix I of this report provides a summary of
    responses to a questionnaire DEP-OCZM distributed at the eight public meetings.
    Appendix II lists the individuals and groups who commented on the Strategy.

         The major part of this report is a presentation of specific comments on the
    Strategy and DEP responses. The responses, for the most part, explain how DEP used
    the comment in revising the Strategy to prepare the New Jersey Coastal Management
    Program - Bay and Ocean Shorefront Segment and Draft Environmental Impact Statement.
    Because many of the comments refer to specific sections of the Strategy and many of
    the responses refer to the Coastal Program document, this report can best be
    understood and appreciated by reference to these two documents.

         This report lists and responds to 434 specific comments that DEP-OCZM extracted
    from the 80 letters and statements received in response to the Strategy and from
    many of the comments expressed at public meetings.   Many comments which did not
    specifically address part of the Strategy were considered, but have not been
    included  in this report.   In addition, DEP has not included comments expressing
    agreement  or support,  since  these  required  no response  but  "Thank You".   DEP
    reworded some of the comments extracted from longer statements, but tried to
    maintain the original intent and tone of the writer or speaker. A complete set of
    the comments are available for consultation at DEP-OCZM's Trenton Office.

         The left column on the following pages includes the public comment with the
    appropriate page of the Strategy in parenthesis, when possible.  The middle column
    indicates the individual -or g-roup making the comment, and the right column gives
    DEP's response with a reference to the section of the Coastal Management Program -
    Bay and Ocean Shore Segment whenever possible.

         The comments are generally listed in the order of the pages of the Strategy to
    which they refer. The comments are'listed under the following headings:

                                 COMMENT                                           COMMENT
    READING                        NUMBER   READING                                  NUMBER

    Boundary                         1-25     Transportation                         162-165
    Basic Coastal Policies          26-37     Industrial Development                 166-167
    Coastal Policies General        38-49     Mining                                 168-170
    Illustrations and Mapping       50-60     Solid Waste and Resource Recovery        171
    .Energy                         61-131    Agriculture                            172-173
    Housing                        132-156    Shore Protection                       174-181
    Parks and Recreation           157-161    Recreational Boating                   182-186

                                  COMMENT                                           COMMENT
    READING                       NUMBER      HEADING                               NUMBER

    Ports and Commercial Boating 187-188    Air Quality                                221
    Dredging and Dredge Spoil                 Public Access                            222
      Disposal                    189-196    Marine Sanctuaries                     223-224
    Sewerage                      197-205    Areas for Preservation and
    Ocean Dumping                    206        Restoration                            225
    Linear Development             207-211    Geographic Areas of Particular
    Dunes                          212-213      Concern                                226
    Innovative Development           214      Location Policies                     227-263
    Commercial Fisheries             215      Performance Standards                  264-293
    Urban Areas                      216      Management System                      294-407
    Water Transportation             217      Public Participation                   408-417
    Wetlands                       218-220    General                                418-434

    COMMENT                         SOURCE               RESPONSE

    BOUNDARY

     1.  Areas west of Garden       New Jersey Shore    These areas were included in CAFRA
         State Parkway should      Builders Associ-    for sound environmental reasons
         be deleted.  (Page 13)   tion                   and can only be removed by the
                                                       Legislature, not DEP. See Chapter
                                  Manchester Manu-    Two - Inland Boundary Segment. (Pages
                                   facttirers Assoc.    13-16)

                                   Asarco Inc.

     2.  The following are not    U.S. Navy              Except for the access road and
         included in CAFRA and                           railroad to Earle, this comment
         should not be listed as                         is correct.  The appendix on Excluded
         being in the coastal                            Federal Lands - Segment has been
         zone.                                           changed accordingly.  (See pages
         1)  Lakehurst                                   264-265)
         2) Fort Dix
         3) Naval Weapons
             Station Earle
         (Page 13)

     3.  CAFRA boundary is not    Salem County           See Appendix F - pages 252-253
         based on significant      Planning Board        for description of basis for the
         impact.  Cultural                              boundary.  Cultural features are
         features are not                               used as an easily understood method
         rational way of                                 of describing the scientifically
         delineating a boundary                          determined area.
         (Page 13, 17)

    4.  Some streams are not       Salem County         All tidally influenced streams will
         included in the coastal  Planning Board        be included as they are delineated.
         zone boundary. (Page
         17)                       U.S. Fish and
                                  Wildlife Service

    5.  DEP should include         Pureland Indust-    This is essentially the approach used
         Stream Encroachment,      rial Complex          in determining the Segment boundary, and
         Riparian, Wetland, &                            every effort will be made later in 1978
         Flood Insurance juris-                          to define a coastal zone boundary along
         diction to determine                            the Delaware River without creating
        boundary in Gloucester                          additional boundary lines.
         County (Page 17)

    6.  Include all marine         National Marine      This is impossible because the
         coastal areas to the      Fisheries Service   salinity varies from hour to hour.
        maximum salinity                                Instead, the boundary is based upon
         intrusion at low                                tidal influence is more inclusive.
         flow (page 15).

    7.  What criteria were used  U.S. Fish and          See Appendix F, pages 252-253.
         in boundary determina-   Wildlife Service
         tion? (Page 17)

    COMMENT                        SOURCE               RESPONSE

     8.  Mo-re thorough study      Society for          Agreed.  This will occur through DEP-
         for the boundary in the  Environmental and   OCZM staff work and a contract for
         northern waterfront       Economic Develop-   coastal planning with county planning
         area is necessary.        ment (SEED)          board including Hudson and Union, as
         HMDC inclusion should                          well as the HMDC.
         be studied (Page 18)

     9.  Wetlands inland of        National Marine      Agreed.  The boundary has been changed.
         CAFRA should be           Fisheries Service   See Chapter Two - Inland Boundary -
         included (Page 13)                             Segment, pages 13-16.

    10.  No additional areas       New Jersey Asphalt  Such additions are required by Federal
         outside CAFRA should      Pavement Assoc.      law.  See Appendix F - Coastal Zone
         be added to the coastal                        Boundary.
         zone. (page 15, 19)       New Jersey Utility
                                  Contractors Assco.

    11.  The Palisades should      Hoboken Resident    The State has limited present legal
         be included in the                             authority to manage development along
         coastal zone (page 18)                         the Palisades. Inclusion in the
                                                       coastal zone would therefore be
                                                       meaningless. New state legislation
                                                       would be necessary to protect the
                                                       Palisades.

    12.  Correct "Medford Lakes"  Burlington - OCS    Agreed.  See page 260.
         to "Medford" (Page 25)

    13.  Include upstream shore-  DEP, Division of    The coastal zone boundary is based
         lands above Trenton &    Fish, Game &          upon tidal influence and is therefore
         all flood plains to 20'  Shellfisheries        proposed to stop at Trenton.  Water
         contour.  (Page 17)                            in other parts of the state are
                                                       being addressed by the 208 water
                                                       quality planning program adminis-
                                                       tered by the Division of Water
                                                       Resources.

    14.  Are non-CAFRA areas       Charles Erwin        Probably not in the near future,
         going to be legisla-                           unless the legislature so chooses.
         tively defined?  (Page                         See Appendix F - Coastal Zone
         15)                                            Boundary.

    15.  Middlesex, by being       Middlesex County    DEP has a contract with the Middlesex
         excluded from CAFRA,      Planning Board       County Planning Board to determine
         does not get money, but                        what activities should take place in
         gets pressure for uses                         the county's waterfront areas.  Acti-
         excluded in CAFRA                              vities discouraged in the Segment will
         (Page 15)                                      be recommended for location in other
                                                       parts of the coastal zone only if they
                                                       are appropriate.

    COMMENT                        SOURCE               RE SPONSE

    16.  Program must include      Salem County         This has been done.  See Chapter Two -
         areas of direct and       Planning Board       Inland Boundary - Segment, pages 13-16
         significant impact.                            and Appendix F, page 252.
         (Page 17, 18)             Natural Resources
                                  Defense Council

    17.  Does OCZMI have legal     Public Advocate      Not to extend the CAFRA boundary, but
         ability to expand                              DEP can define a coastal zone without
         boundary?  (Page 17,      New Jersey           changing the boundaries of state laws.
         19)                       Chamber of           See Appendix F, page 252-264.
                                  Commerce

    18.  Include Raritan Bay,      Middlesex - 208      This is to be determined later in
         and Estuary, to                                1978 in coordination with the County
         Victory Bridge (Page                           Planning Boards.  See Appendix F,
         17, 19)                                        pages 252-264.

    19.  Re-evaluate northern      New Jersey Conser-  This is to be determined later in
         boundary to determine    vation Foundation   1978 in coordination with the coastal
         what political area                            county planning boards.  See Appendix
         should be included to                          F, pages 252-264.
         g~ain control. (Page
         18)

    20.  Will Camden be included  City of Camden -    The waterfront sections may be
         in the coastal zone?      Economic Devel-      included, although the exact boundary
         (Page 17)                 opement Director    will be determined later in 1978 in
                                                       coordination with the coastal
                                                       planning boards. See Appendix F,
                                                       pages 252-264.

    21.  Have all wetlands along  U.S. Fish &           Yes, all wetlands on tidal streams
         Delaware River been       Wildlife Service    related to Delaware Bay are now
         included?  (Page 17)                           included.  See Chapter Two - Inland
                                                       Boundary - Segment, pages 13-16.

    22.  The borough of West       Eugene Amron         It is now included.  See page 254.
         Long Branch is omitted
         on list of Monmouth
         County municipalities.

         (Page 123)

    23.  Secaucus, which is 80%   Hartz Mountain        It will be included when DEP prepares
         in the HMDC district,    Industries            the program for the rest of the coastal
         is not listed on list                          zone.  It is now listed on page 261.
         of affected munici-
         palities in the Strategy.
         (Page 125)

    COMM~ET                         SOURCE               RESPONSE

    24.  Coastal program should   Jersey City            The intent of the energy policies is to
         not be submitted in       Planning Director   steer facilities to where they can best
         segments because it                            be accommodated.  Submission of the Pro-
         could lead to pushing    Regional Plan         gram in segments will not affect their
         of all energy facili-    Association            location.
         ties to non-CAFRA
         area.

    25.  Re-examine boundaries    Regional Plan          The boundaries will be reexamined
         after inventory is        Association          during 1978 through public comment
         completed.  The Strategy                       on the Segment, the Estuarine Study,
         covers an area that                            and DEP's contracts with counties.
         seems to extend beyond
         the coastal zone, while
         the boundaries in the
         north seem too narrow
         to protect coastal
         environmental values.

    BASIC COASTAL POLICIES

    26.  Basic Coastal Policies   Public Service         This phrase is implied by Basic Coastal
         do not address benefi-   Electric & Gas        Policies I and 2 and specifically
         cial use and develop-    Company               addressed by Location and Use Policies
         ment of coastal zone.                           encouraging appropriate development
         The should be revised                          of coastal sites.  See pages 11-12.
         to include "while per-
         mitting its beneficial
         use and development."
         (Page 25)

    27.  The second basic Coastal Salem County           Agreed, and included in second basic
         Policy should also        Planning Board       Coastal Policy.  See page 11.
         encourage industrial
         development in a con-
         centrated manner (Page
         25)

    28.  The second Basic           Salem County         Agreed.  The rationale for the policy
         Coastal policy should    Planning Board        includes a statement incorporating this
         encourage dispersed                            comment, and the fourth Basic Coastal
         development to reduce    Public Service         Policy further insures its consider-
         safety hazards, as in    Electric & Gas        ation.  See page 11-12.
         nuclear plants and LNG   Company
         facilities.

    29.  The program should        Salem-County          Agreed.  The Resource Policy on "Buffer
         protect an environ-       Planning Board       and Compatibility of Uses"' in Chapter
         mental resource or some                         Three addresses this issue.  See page
         lands which are in need  New Jersey            160.
         of preservation because  Conservation                                                     '
         they are near developed Foundation
         lands. (Page 25)

    COMMENT                         SOURCE               RESPONSE

    30.  The second Basic           New Jersey           The Basic Coastal Policy and the
         Coastal Policy of con-   Chamber of             Clean Air Act Amendments provide
         centration will con-      Commerce              two criteria, rather than a conflict,
         flict with federal                              for locating development.  See
         Clean Air Act Amend-                            the rationale for the Air Quality
        ments which specify                             Resource Policy in Chapter Three
         no development in                               on pages 157-158.
         non-degradation
         (essentially urban)
         areas. (Page 25)

    31.  The statement that         American Littoral   This is now noted in the rationale
         land where development   society                to Use Policy 7.2.2 on page 132
         is discouraged is likely                        and in the rationale to the Buffer
         to decrease in value,                           Resource Policy.  See pages 160-161.
        may be incorrect since
         open space can increase
         the value of adjacent
         land. (Page 25)

    32.  What is the relation-    Society for Envi-   It is essentially consistent.  See
         ship of the concentra-   ronmental and          "Department of Community Affars" in
         tion of development       Economic Develop-   Chapter Four on pages 171-172.
         with DCA State Devel-    ment (SEED)
         opment Guide Plan?
         (Page 25)

    33.  Cluster development        League of Women      This concern is addressed by the
         increases runoff of       Voters               Runoff Resource Policy in Chapter
         toxins and heavy metals                         Three.  See pages 153-154.
         more than suburb-an
         single family develop-
        ment. (Page 25)

    34.  Certain development        JoAnn Katzban        The Program for the rest of the
         prefers urban to shore                          coastal zone will address urban
            l~~~octosopen space                         waterfront issues.
         is protected,      btthe
         people are not pro-
         tected. (Basic Coastal
         Policy 4, Page 25)

    35.  Strategy does not deal   Bill Beren             As summarized by the fourth Basic
        wi~3th pe~ople.  Rethink                        Coastal Policy, the entire set of
         urban policies in                               policies is based upon a desire to
         relation to special                            maintain and improve the quality

         needs of people.                                of life for all people.
    36.  More economic concerns   Bob Litorie            Economic concerns did help form the
         are necessary.  (Page                           policies.  Long term economic gain
         25)                                             depends upon the siting and construc-
                                                       tion of development in an environ-
                                                       mentally sound manner.

    COMM4ENT                        SOURCE               RESPONSE

    37.  Prohibiting and           Marine Trades         The Coastal Program is an effort to
         encouraging alone         Association           provide a statement of what the State
         will not provide coastal                        of New Jersey will do to manage the
         zone envisioned by                             c'oast, and what it believes others
         N.J.'s coastal planners.                        should do.  More precise definitions
         Encouragement must                             of these terms have been included.
         become more positive.                           See Pages 20-21.
         (Page 25)

    COASTAL POLICIES - GENERAL

    38.  Considering the con-      Joint Council of    This is a serious problem.  The Coastal
         centration of people,    Taxpayers             Program cannot address past development
         what is to happen during                       which should not have been built.  DEP
         a hurricane or other                           can only work with the N.J. Department
         disaster requiring                             of Defense to have effective evacuation
         evacuation.                                    procedures, and adopt policies to deny
                                                       or condition future development in
                                                       such areas.

    39.  Use policies should       National Marine       This is now addressed in Resource
         discuss fishing           Fisheries Service   Policies in Chapter Three.  See
         (Virginia's CZM                                pages 151-152.
         program is a good
         model).

    40.  Why is there no policy   Steve Gabriel          There is very limited state legal
         on rebuilding non-con-   Ocean City            authority to manage building or
         forming uses (i.e.                             rebuilding on sand dunes.  The
         rebuilding on a sand                            issue merits further study.
         dune) (Page 34)

    41.  "Shall be discouraged"   Asaro Inc.             Developers wish to know early
         should not appear in                           how DEP views their project and
         print.                                         the use of "discouraged", which
                                                       has been further defined in the
                                                       Segment can give an applicant a
                                                       clear idea of how the project
                                                       can be revised to be approved.

    42.  The Strategy encourages  Steve Gabriel          This will be achieved largely
         the maintenance of        Ocean City           by denying development application
         large contiguous tracts                        which would break up large areas
         of prime agricultural                          of agricultural land.  DEP will
         land (Use Policy 35,                           explore the possibility of using
         page 39).  How will                            TDR (transfer of development
         this be achieved?  Will                        rights).
         OCZM utilize TDR?

      COM4MENT                        SOURCE               RESPONSE

    43. Heavily developed areas  Association               Agreed. See Resource-Policies on
           in New Jersey already    of New Jersey         Water, Air and Buffers on pages
           suffer the highest        Environmental         152, 157, and 160.
    I    ~levels of environmental  Commissions
           degradation and pollu-
           tion. DEP must insure
           that permits granted
           for development in these
           areas do not increase
           air, water, and noise
           pollution.
    *44.  No further growth, even  Association of          This is the general intent of
    *     ~if it is adjacent to      New Jersey           the policies, although develop-
           previously developed      Environmental        ment is in some cases appropriate
           areas, should be          commissions           or necessary.  See policies and
    I    ~allowed on barrier                              rationale on pages 55, 54, 69,
           islands, dunes, wet-                            and 57.
           lands, prime aquifer
           recharge and areas of
           high water table.
    45. Policies should clearly  Association of            Activities are "prohibited" when
           delineate prohibited      New Jersey            appropriate and when legally
           uses and site-types in   Environmental          feasible.  See Chapter Three.
           which no change will      Commissions
           be allowed.
      46.  Use of "encouraged"        Association of       The definition of "encouraged"
           status should be          New Jersey            has been made more specific.
           severely restricted in   Environmental          See page 21.  The term will not
           environmentally sensi-   commissions            not be applied to types of
           .tive areas, and in                             development with which DEP has
    I    ~cases where DEP has        New Jersey           no previous experience.  A sen-
           no previous review        Conservation          tence to this effect was mnad-
           experience the "encour-  Foundation             vertantly omitted from the DEIS,
    I    ~aged" status should                             but will be included in the
           never be used.                                  Final EIS.

    347.  Performance standards    DEP - Division          They now do.  See Location and
    -     ~should include fish       of Fish, Game &      Resource Policies in Chapter Three,
           and shellfish.            Shellfisheries        especially pages 31, 32, 33, 34,
                                                          and 151.

      48.  The Program needs to       Natural Resources   Such a policy is difficult because New
           develop a barrier         Defense Council       Jersey barrier islands are quite
    -I   ~island policy.                                   developed.  The Coastal Programs
                                                          addresses this issue in Location
                                                          Policies for "High Rise Erosion Areas"
                                                          (page 50), "Dunes" (page 54), "Beaches"
                I                                         ~~~~~~~~~~~~~(page 71-72) and "Central Barrier
                                                          Island Corridors" (page 55) in Chapter
                                                          Three.

    COMMENT                        SOURCE               RESPONSE

    49.  Where has infill been    Sierra Club           It is now explicitly defined in the
        defined in the Strategy?                       Glossary on page 312.
         (Use Policy 44, Page 42)
    ILLUSTRATIONS AND MAPPING

    50.  Some additional dia-      Bur'lington OCS      The Location Policy Section of Chapter
        grams would aid in the   Task Force            Three is a thorough redesign of CLAM
        description of the                             intended to accomplish this purpose.
         implementation of CLAM.                        See pages 19-163.

    51.  Illustrations on Pages   American Littoral   Agreed.  These figures have been
         90 and 91 are unclear    Society               redrawn, and others have been added.
         (dredging coastal appear-
        ance, effluent discharge,
         air) (Page 90, 91)
    52.  Figure 7c, with its       DEP - Division       Same cotmment as above.
        reference to building    of Environmental
        moratorium does not       Quality
        reflect any concept
        relevant to air
         quality planning.I

    53.  You cannot develop        Public Advocate      The use of many maps and coastal visitsI
        policies without map-                          helped form the policies.  See the
        ping areas. (Page 34)                          Case Studies beginning on page 316 to
                                                     see the relationship between policies     I
                                                     and mapping. Preparation and repro-
                                                     duction o~f detailed maps for the
                                                     coastal zone will be done in the
                                                     future. See Chapter Seven, especiallyU
                                                     page 198.

    54. Maps 3a through 7 are    League of Women        The maps have been omitted.  Clearer       I
        difficult to read         Voters               maps are available for inspection
        because in some the                            in the DEP-OCZM Trenton office.
         coast is dark while in
        others it is uncolored.
         (Page 112, 122)

    55.  DEP should complete       Association of       This is part of DEP's plan.  SeeI
         the proposed coastal      New Jersey           pages 197-198 in Chapter Seven.
        mapping project within   Environmental
         the next two years.       CommissionsI

    56.  Areas where (a) general  Regional Plan         Same comment as above.
        development should be    AssociationI.
         allowed (b) where only
        certain uses will be
        permitted and where
        design must be approved,
         and (c) areas of supreme

      COMMENT                         SOURCE               RESPONSE

    I     ~ecological, visual or
           recreational value where
           nothing should be built
    I    ~without some overriding
           reason, should be deli-
    ~~1     neated.

      57.  The order of policies    DEP - Green Acres   The order of the policies has been
            is inconsistent with                            rearranged.  The order is not, however,
            the content of the                              intended to indicate relative importance.
           policies. Transporta.-
           tion deserves billing
           over camping, and the
           buffer policy should
            follow vegetation.

    I 58.  There is no basis for    Public Service         This has been deleted.
           allusion to "careless    Electric & Gas
           design of planning of    Company
           major industrial or
           energy facilities.'"
            It should be deleted.
            (Page 92)

      59.  Change page vii-last       American Littoral   The introduction has been largely
            sentence from "encour-   society                rewritten, omitting this phrase.
    I    ~age appropriate"t to
           "discourage inappro-
           priate". (page vii)

      60.  DEFINE:                    Cape May County      A glossary has been included as
           1. Maximum practica-      Planning Board        Appendix M.  The population density
              bility                                       limits regarding LNG facilities
    I    ~2. Single purpose vs.                            have not yet been defined by any
              multi purpose marina                         level of government or industry.
           3. substantial popula-                          See pages 310-315.
     I      ~ ~tion density limits
              with regard to LNG
               siting

      ENERGY

    fl61.  Change "from the center  American Littoral   The wording has been changed to
    *     ~of the Pine Barrens"       Society       i       fundeveloped parts of the Pine
           to "from the Pine                              Barrens ... See "Pipelines and
           Barrens". (Page 28)                             Associated Facilities" subsection
               *1                                        ~ ~~~~~~~~~~~of Energy Policies in Chapter Three
                                                          on pages 141-144.

    COMMENT                         SOURCE               RESPONSE

    62.  Siting flexibility is    Public Service         The Energy Policies in Chapter Three
        needed and must be        Electric & Gas        provide such flexibility.  See pages
        provided by the Strat-   Company                137-147.I
        egy.  It is possible
        to allocate a small
        portion of the coastI

    63.  The document is anti-    Public Service         Disagree.  The energy policies consider3
        energy and anti-growth.  Electric and Gas    both state and national interests.  See
         it is also in conflict   Company               National Interest Section of Chapter
        with the spirit and                             Five (page 176-186) as well as Energy *
         intent of CAFRA.  The                          Policies in Chapter Three (pagesU
        national objective is                           137-147).
         to become energy self-
         sufficient, which isI
        virtually ignored.
         (Page 26)

    64.  Energy related uses       Natural Resource    Agreed. Major energy facilities are
         such as refineries,       Defense Council      directed out of CAFRA.  See pages
         power plants, etc.                              137-147.
         should be specifically
        directed outside the
         CAFRA area.

    65.  NJ is a non-attainment   JoAnn Katzban          Any additional or expansion of existing
         area, and the entire                           refineries will have to comply with
         state is in conflict                           state and air federal offset emission
        with air standards                              controls.  Development in the coastal
         regarding petrochemicals.                      zone, as elsewhere in the state, will
         It is important that                           have to comply with the Clean Air Act. 3
         the Strategy recognize                         See Air Resource Policy, on pagesU
         the cancer problem.                            157-158.

    66.  We are concerned that    State Chamber          The articulation of energy facility
         the Strategy will not    of Commerce           siting policies is a major step toward
         allow the most expedi-                         expediting project review by lessening
         tious handling of energy                       uncertainty.
         facility projects,
         especially off-shore
         development.

    67.  Policies are vague and   Sierra Club            The language of the policies has been
         loop holed.  Having a                          tightened.  See pages 137-147.
         policy that encouragesI
         oil companies to oper-
         ate in a manner that
         respects the environ-
        ment is laughable. All
        must conform to the law.
         Saying pipelines "shall
         avoid" the barrens is
         feeble, they should be
         prohibited from the

         barrens.

      COMMENT                         SOURCE               RESPONSE

    I68.  The legitimacy of an        Public Advocate      Legitimacy, or need, will be considered
           energy facility must                            as well as possible alternatives by DEP
           be considered (unneeded                         and DOE.  See especially pages 138 and
           facilities will not be                          139.
           approved) (Page 26)

    fl69.  There seems to be          U.S. Bureau of       Disagree.  The state as a whole will
    *     ~inadequate accommoda-    Land Management        be doing more than its fair share to
           tion of OCS facilities.                         support exploration and development.
              (ae93)                                      See Energy Use Policies in Chapter
                                                          Three and National Interest section
                                                          in Chapter Five.

      70.  Energy policies need       Cape May County      This is the intent of the "General
    -     ~to reflect the require-  Planning Board         Energy Facility Siting Policy" in
           ment that the best                              Chapter Three on pages 137-138.
           available technology
    I    ~be utilized during
           all phases of planning,
           design, construction
    I    ~and operation of the
           facilities. (Page 26)

      71.  005 facility policies    Atlantic Audubon    Disagree.  The opinions and.. data in
           do not reflect informa-  Society                the two reports were taken into
           tion in the Princeton                           account in the initial drafting, as
           and Rutgers studies.                            well as the redrafting of the energy
                                                          policies.

    I 72.  Oil and gas support-       Atlantic Audubon    DEP encourages the location of such
           ing activities are        Society               facilities in developed urban areas.
           incompatible with                              A facility will be approved, however,
           the Atlantic County                             only if it will not interfere with,
           tourist economy and                            or threaten, the environment which
           should take place in                            supports the tourist industry.
           the Perth Amboy area.
           (Page 26)

      73.  Paragraph on page 93       U.S. Bureau of       This section has been deleted.  OCS
           appears to indicate       Land Management       facilities are considered in detail
           inadequate accomodation                         in the Energy Policies Section of
           of OCS facilities.                              Chapter Three.  See pages 137-147.
           (Page 93)

      74.  N.J. should recognize    American Littoral   This is recognized in the "Conservation
           the national need to      Society               and Alternative Technology" Energy
    -I   ~provide and identify                             Policy in Chapter Three.  See pages
           new energy supplies.                            147 and 162.
           (Page 27)

    COMMENT                         SOURCE               RESPONSE

    75.  Delete "rapid"1 and       American Littoral   "Rapid" exploration is encouraged to
         "respect" in general      Society              provide information on the likely extent
        005 policy.  (page 26)                         of development.  The exploration must
                                                     be designed to  "respect'' the natural     I
                                                     and build environment or it will not
                                                     be approved.

    76.  DEP should evaluate        Public Advocate      DEP's contracts with Rutgers, Princeton,
        costs and benefits to                          and 12 coastal counties to study OCS
        N.J. of oil drilling                           activities, as well as independent
        and production of OCS.                         DEP-OCZM studies and critiques of
         (Page 26)                                      EIS's prepared by the U.S. Bureau
                                                     of Land Management on the OCS
                                                     Lease - Sales No. 40, 42, and 49.I
                                                     have contributed much cost-benefit
                                                     information.

    77.  The policies should       Natural Resources   This is the intent.  See revised lang-
         state that only 00S       Defense Council      uage on Energy Policies in Chapter
         related facilities                             Three on pages 137-147.I
        which need to be
         adjacent to the lease
         sale area will be per-I
        mitted in CAFRA area,
         and all others will be
        directed inland.
         (Page 26)

    78.  DEP wishes to avoid       Public Advocate       Agreed.
         conflict with state's
        major tourist industry.
         (Page 26)

    79.  The Energy Policies       Atlantic Audubon    This is the reason most energy facili-
         should consider con-      society              ties are directed toward developed
         flicts with com-                               areas.
        mercial and recrea-
         tional fishing and
         tourism. (Page 26)

    80.  Expand the OCS policies  Cape May County        To the extent such impacts can be known
         to include considera-    Planning Board        in the exploratory phase, they are
         tion of impacts which                          being considered.
         are a result of devel-
        opment and production
         phases of OCS activi-

                              ties. (Page 26)~~~

      COMMENT                         SOURCE                RESPONSE

    I 81.  The policy stating          U.S. Fish &          The Onshore Support Base policy has
           offshore bases will        Wildlife Service    been revised and the inconsistency
           locate in industrial                            has been eliminated.  See page 140.
    I    ~zones in urban areas
            is in conflict with
    -     ~page 93 stating that
    *     ~an exception may be
           made for areas near
           Atlantic City. (Page
           27, 93)

      82.  The OCS policy should    Natural Resources   This is the intent of the revised Energy
           establish specific         Defense Council       Policies and Location Policies in Chapter
    I    ~siting requirements                               Three.  See pages 19-163, especially
           and state that siting                            137-147.
            in fragile areas will
    I    ~not be permitted.
            (Page 27)

    I 83.  DEP should declare that  Public Advocate         This is stated in the General OCS Energy
           it will not authorize                            Policy in the Use Policy section of
           offshore industries                              Chapter Three.  See page 139.
           where their impacts
           could be severe.
           (Page 27)

    I 84.  Energy policy #4 does    Natural Resources   These factors are now acknowledged in
           not recognize the low    Defense Council         the "Platform Fabrication Yards"
           demand for siting a                              Energy Policy in the Use Policies
           platform construction                            section of Chapter Three.  See page
           yard, nor the large                              141.
           acreage, nor the
           possibility of having
           to locate in rural
           areas. (Page 27)

    I 85.  Policy should specify    National Marine         This is stated explicitly for all uses
           that development of        Fisheries Service   in the Lower Water's Edge subsection of
           wetlands for offshore                            the Location Policy in Chapter Three.
           platform consturc-                               See pages 69-71.
           tion yards should be
           discouraged. (Page
    I     ~~27)

      86.  A cost-benefit eval-       Public Advocate       Secondary Impacts are considered part
           uation should be                                 of a development application.  See
    -I    ~performed on the                                  Resource Policies in Chapter Three
           secondary impacts of                             on pages 159-160.
           population growth and
           air pollution related
           to energy facilities.
           (Page 27)

    COMMENT                         SOURCE               RESPONSEI

    87.  Pipelines - Section e    N.J. Division of    This has been added to Chapter Three
        should include "'pro-     Fish, Game &          for all uses.  See Prime WildlifeI
        ductive and unique         Shellfisheries       Habitat subsection of Location
        wildlife habitat".  No                          Policies.
        mention is made of wild-
         life, especially our
        rare and endangered
         species.  (Page 28)I

    88.  With respect to pipe-    Conservation           That is the intent of this policy.
         lines, we would hope      Society of Long
        policy is not too         Beach IslandI
         lenient. No risk
         should be taken with
         the ocean/estuarine
        environment. (Page
         28)

    89.  Enlarge pipeline exclu-  U.S. Environ-          The pipeline policy is based uponI
         sion area to include      mental Protec-        the "Critical Area" regulated by
        Great Bay area and the   tion Agency            the Division of Water Resources.
        mouth of the Mullica                            This area does not include theI
         River.  The estuarine                           Great Bay and Mullica River area.
         areas should also be                            See pages 141-142.
         in a protected status.
         (Page 28)

    90.  What is the potential    Stephen Gabriel        It is uncertain.  DEP is undertaking
         for degradation if the   Ocean City             a six month Estuarine Study to begin
         pipeline corridor is                            in May 1978, which will study
         nearby undeveloped                              impacts and the thresholds at
         regions?  (Use Policy                           which point these impacts areI
         5, page 28)                                     felt.

    91.  Support use of criti-    Burlington OCS         This is the basis of the policy.
         cal areas as a means      Task Force            See pages 141-142.I
         of deciding pipe-
         lines traversing the
        most sensitive andI
        wildest portion of the
         pinelands.  (Page 28)

    92.  Use of the word "ini-    U.S. Fish &            The policy has been rewritten to say
         tial" in Pipeline         Wildlife Service    that the number of pipelines shall be m
         Policy #5 implies there                         limited to the maximum extent feasible. f
         will be subsequent cor-                         See Pipeline and Associated Facilities -
         ridor which may not be                          Policy (a) in Use Policies in Chapter
         subject to this policy.                         Three.  Until the oil and gas explora-  f.
         (Page 28)                                       tion is well underway, the hydrocarbonU
                                                     resources off New Jersey's coast and
                                                     the necessary number of support
                                                     facilities cannot be known.  (See          I
                                                     pages 141-142)

    I COMM4ENT                         SOURCE               RESPONSE

    I 93.  Exclusion area in Use    Burlington OCS          The map has been revised.  See page
           #5, is not discernable   Task Force              143.
           by map. The map is
           incorrect. (Page 29)

      94.  "Pipeline exclusion        New Jersey            The policy applies specifically to
           areall should probably    Petroleum              pipelines (and ancillary facilities)
           read "Energy Facilities  Council                 which are the only energy facility
           exclusion area." (Page                           to have been seriously proposed or
           29)                                              evaluated for inclusion in the Pine
                                                          Barrens.

      95.  Will DEP recognize         New Jersey            DEP will work with FERC and other
           certificates of            Petroleum             federal agencies, and consider their
    I    ~necessity from FERC.        council               advice in concert with its own judge-
                                                          merits.

      96.  Joint hearings with        New Jersey            This is a good idea which DEP will use
    -     ~federal agencies might   Petroleum               whenever feasible.
           be in order to review    Council
           certificates. (Page
           29)
    97.   Define - "entire             U.S. Fish &          This includes all contemplated ancil-
           new potential pipeline   Wildlife Service    lary facilities and is defined in
           corridor" in Use Policy                          greater detail in Policy 4.7(c) in
           5, Section d.  (Page                             Chapter Three.  See page 142.
           30)
      98.  Excluded areas for         National Resources  Development of pipelines or other
           pipelines should           Defense Council       facilities is discouraged in such areas
    I     ~include undeveloped                              through the location policies noted in
           portions of the barrier                          Chapter Three.
            islands, wetlands,
    I    ~groundwater, protected
           areas, and resources
           valuable for wildlife
    I    ~and recreation.   (Page
           28)

    I 99.  What types of air pol-   Vivian Li               New facilities will have to provide
    *     ~lut ion controls will be                         the best available technology and con-
           permitted?  (Page 28)                            form to federal and state air standards.
                                                           See page 157.

      100. What are selected cases  Sierra Club             Selected cases could include a pipe-
            for exceptions.  Can oil                         line, road, or other linear facility
    -I    ~pipelines be construed                            which conformed with the coastal
           as linear facilities                             policies in all but a small section.
           and have policies                                In this case, four conditions would
    1     ~waived?  (Page 42)                               have to be met.  See page 131.

    COMMENT                        SOURCE               RESPONSE

    101. Delete "to the maxi-      American Littoral   The language has been changed, although
        mum extent feasible"      Society              the uncertain future of oil and gas
         in reference to pipe-                          development in New Jersey make some
         line corridors in Use                          flexibility necessary.  See Use Policy
         Policy 5a.  (Page 28)                          4.7(a) in Chapter Three on page 141-142.

    102. Was the two mile          New Jersey           Yes.  To protect the waterfront from
         "exclusion" line in Use  Petroleum             facilities which need to be located
         Policy 5 inside the ten  Council               near the coast, but are not dependent
         foot contour picked for                        on a waterfront location.  The two
         any particular reason?                         mile line has been deleted from the
         (Page 30)                                      Bay and Ocean Shore Segment.

    103. The words "Encourage"    Public Advocate       The policy has been rewritten and the
         and "Discouraged" in                           terms "encourage" and "discourage"
         Use Policy 8 indicates                         further defined.  See definitions at
         ambivalance and lack of                        the start of the Location Policy on
         coherent policy.  All                          page 20 and Use Policy 7.4.11 in
         tanker traffic should                          Chapter Three on page 145.
         be limited to existing
         industrial sites.
         (Page 31)

    104. New facilities should    National Resources  Agreed.  See revised tanker terminal
         not cause major           Defence Council      (7.4.11) on page 20 and Location Policy
         adverse impacts from                           in Chapter Three.
         dredging and increased
         oil spillage. (Use
         Policy 8, Page 31)

    105. Deepwater port policy    Public Advocate       The policy has been deleted.
         is unclear and meaning-
         less. (Page 31)

    106. It is unrealstic to       Burlington OCS       Same comment as above.
         think that deepwater      Task Force
         ports are unlikely to
         occur.  (Page 32)

    107. The DOE, not CAFRA        State Chamber        Under state law, both DOE and DEP must
         should prevail in the    of Commerce           be included in coastal energy facility
         siting of electric                             siting.  See Department of Energy
         generating plants.        Public Service       Section of Chapter Four on page 171.
         (Page 32)                 Electric & Gas
                                  Company

      COMMENT                         SOURCE               RESPONSE

    I 108. The Strategy eliminates  Public Service         In view of the state's dense popula-
           nuclear and fossil        Electric & Gas        tion and high cancer rate, the siting
           options.  Unfair bur-    Company                of energy facilities are particularly
    I    ~dens of proof for                                serious decisions.  DEP has a legal
           safety are placed on                            obligation to be sure the facilities
           an applicant.  The                              are safe, while working with the
    *     ~Strategy attempts to                            other state and federal agencies.
           pre-empt the authority
           of Public Utilities,
           DOE and the Energy
           Research and Develop-
           ment Administration.
           (Page 32)

      109. Use Policy 11(d) should  Public Service         The Nuclear Regulatory Commission only
           be deleted.  It is        Electric & Gas        considers population at the time a
           superflous since DEP      Company               facility is proposed.  It does not
           controls land develop-                          monitor or control future growth near
          ment in coastal areas,                          an approved facility.  See revised
           and the Nuclear Regula-                         Electric Generating Station policies
           tory Commission considers                       on pages 145-146.
           population increases
           in the safety analysis.
           (Page 32)
    * 110. The federal govern-         Jersey Central      The federal government has not spe-
          ment has radiation          Power and Light    cifically addressed the needs, oppor-
           standards for nuclear      Company              tunities, preferences and conflicts
           plants.  Therefore,                             of the people of New Jersey.  The policy
           policy 11 should                               has been reworded.  See Use Policy
           be deleted since it                             7.4.13 in Chapter Three on pages 145-
           attempts to pre-empt                            146.
           the Nuclear Regulatory
           Commission (Page 32)
    * 111. The Strategy claims        Public Service       The public and DEP have not been con-
    *     ~nuclear plants are        Electric & Gas        vinced that nuclear plants are suffi-
           unsafe, which only        Company               ciently safe that other technologies
           leaves exotic energy                            should not be explored.  The problems
           sources to be                                  raised by disposal of nuclear waste may
           exploited. (Page 32)                            raise as many questions as does the
                                                         lesser developed newer alternative
                                                         sources of energy. See pages 145-147.

     112. Does DEP have a            Jean Jones           No.  The potential danger of nuclear
           policy to cluster                               and LNG facilities make their location
           nuclear plants?                                 an exception to the general policy of
           (Page 32)                                      concentrating development.  See
                                                         rationale to Basic Coastal Policy 2
                                                         on page 11.

    COMMENT                         SOURCE               RESPONSE

    113. Nuclear plant approvals  League of Women        Agreed.  This was inadvertantly left
        should include stand-    Voters                out of Use Policy 7.4.13 in Chapter
        ards for decommis-                             Three on pages 145-146 and will be
        sioning of obsolete                             included in the Final EIS.  DEPI
        plants.  (Page 32)                             already imposed a plan for decom-
                                                   missioning as a condition for
                                                    issuance of a CAFRA permit for the
                                                    Hope Creek Generating Station.
    114. Add to statement that    Public Service         Agreed.  See rationale to Basic
        "It is recognized that   Electric & Gas        Coastal Policy 2 on page 11.
        certain applications      Company
        such as nuclear energy
        facilities and LNGI
        facilities" may require
        a siting policy remote
        from other facilities.I
        (Page 32)
    115. Rewrite Use Policy 11(b) Public Service         This policy has been rewritten.  See
        to say that disposal of  Electric & Gas        Use Policy 7.4.13 in Chapter Three on
        spent fuel will comply   Company               page 145.  DEP will continue to eval-
        with all safety and                             uat.e all relevant information arising
        environmental require-                          from the EIS or public hearing for a       I
        ments of the Nuclear                            project.
        Regulatory Commisson or
        other requirements whichI
        have been established
        after presentation of
        evidence that such
        requirements are
        reasonable.  (Page 32)

    116. Rewrite Use Policy 11(a) Public Service         Same response as above.I
        to state that construc-  Electric & Gas
        tion and operation of    Company
        offshore and land basedI
        plants will comply with
        all safety and environ-
        mental requirements.I

    117. The policy should call   Public Service         The energy policies were all written
        for approval of facili-  Electric & Gas        with the assistance of concurrence
        ties in DOE master plan  Company               of the Department of Energy.  The
        or that are important                          Master Plan has not yet been adopted
        to the welfare and                             but it is noted in Use Policy 7.4.1         I
        economic well being of                         on page 139.  The welfare and economic
        New Jersey.  (Page 32)                         well being of New Jersey is an
                                                    important factor in assessing              I
                                                    facility need for environmental and
                                                    land use review.

      COM4MENT                        SOURCE                RESPONSE

    I 118. The policy on nuclear    Bill Beren,             A statement to this effect has been
           plants should explain    Hoboken Resident        added to the rationale for the
           whether it represents a                          policy.  See Use Policies in Chapter
    I    ~break with past DEP                               Three on page 146.
           Policy (Page 32)

    fl119. Use Policy 12 appears    U.S. Fish &             This statement is inherent in the
    *     ~to direct LNG to unde-   Wildlife Service    Location Policies which apply to all
           veloped, possibly                                uses and in the LNG policy. See Use
           sensitive areas.  Policy                         Policy 7.4.14 in Chapter Three on
    -I    ~should state that LNG                             page 146.
           will be discouraged
           from locating in
    I    ~sensitive areas.
           (Page 33)

    fl120. The Strategy maintains   Public Service          Despite repeated requests, the Federal
    *     ~an assumption that LNG   Electric & Gas          Energy Regulatory Commasion (formerly
           is hazardous.  New         Company               FPC) has offered no evidence to
           Jersey is pre-empting                            counter the assumption of hazard.
           the Federal Power
           Commission's authority.

    I 121. There is no provision    Public Service          Disagree.  Energy company comments
           in the coastal program   Electric & Gas         have been solicited, received and
           for input by energy        Company               considered since DEP's "Call for
           companies.  (Page 33)                            Information" in 1975.  Such parti-
                                                          cipation will continue to be
                                                          encouraged. See the Public Parti-
                                                          cipation section of Chapter Four on
                                                          page 174 as well as Appendix B on
                                                          page 233-239.

    I 122. Will the state coastal   U.S. Department         No, unless they require construction
           program affect non-land  of Transportation   of regulated land or water facilities.
           use activities such as
           tanker operating pro-
           cedure?

    I123. The state should            Geothermal Energy   Geothermal production has not been
           develop a policy con-    Institute               formally proposed in New Jersey.
           cerning geothermal                               DEP needs additional information
           energy production and                            before a policy can be formulated.
           use.
      124. There should be a          Cape May County       See Use Policy 7.4.15, headed "Con-
           separate policy addres-  Planning Board          servation and Alternative Technolo-
           sing energy conserva-                            gies", on page 147 and Resource
           tion rather than having                          Policy on Energy Conservation on
    *1   ~it woven through                                  page 162.
           the report.

    COMMENT                         SOURCE               RESPONSE

    125. Does DEP have the right  Public Service         T6 the extent that energy facilities
         to consider the feasi-   Electric & Gas        will preempt or affect land or water
        bility of energy          Company               in the coastal zone, DEP maintains
         siting.  isn't this                            this right.  See Department of Energy
        DOE's responsibility?                           section of Chapter Four on page 170
                                                     for discussion of cooperation between
                                                     the two agencies.
    126. The use policy on         Public Service        The Segment now contains no policy
         nuclear generating        Electric & Gas       on offshore plants because of the           I
         stations should state    Company               many complex questions still to be
         `(a) that the construc-                        answered and because of the post-
         tion and operation of                          ponement of the only pending
         offshore and land-based                        application for such a facility.
         plants will comply with
         all safety and environ-
        mental requirements ofI
         Nuclear Regulatory Com-
        mission or other require-
        ments which have beenI
         established after pre-
         sentation of evidence
         that such requirements
         are reasonable." (Use
         Policy 11, page 32)

    127. Review of energy facil-  Public Service         The reviews will be coordinated,I
         ity sites by DEP and      Electric & Gas       while still utlizing the expertise
         DOE, resulting in over-  Company                of the two Departments.  See the
         lapping responsibility                         Department of Energy section ofI
         and significant delays,                        Chapter Four on page 170 and the
         could lead to possible                         draft memorandum of understanding
         conflicts of authority.                        between the two Departments on
         (Use Policy 7, page 26)                        pages 277-282.
         State reviews should
         not duplicate existing
         fact finding studies.
    128. Fossil fueled electric   Public Service         DEP recognizes the added burden
         generating stations       Electric & Gas       which may be placed upon energyI
         should be "restricted"   Company               producers and other industries to
         rather than "discour-                          meet applicable air quality stand-
         aaged" in "preservation"                       ards, but does not consider that
         areas.  To "direct"                            a sufficient reason to permit the
         them to built up areas                         facilities where they will damage
         could conflict with                            valuable natural resources.
         provisions of the
         Clean Air Act. (Use
         Policy 10, page 32)

    ICO',TNENT                        SOURCE               RESPONSE

      129. A general siting           Public Service       The policy for LNG facilities
           criteria should not       Electric & Gas        recognizes that they require large
           be established for        Company               buffer areas in case of an acci-
           LNG facilities                                  dent, and that New Jersey has
                                                          been given too little guidance
                                                          by the Federal government to
               -I                                       ~ ~~~~~~~~~~~more specifically define possible
                                                          appropriate sites. See page 146.

    1130. When disputed energy        Stephen Gabriel      Comments from the public are received
           facility siting deci-    Ocean City             during the review of application and
           sions go to the State's  Resident               at the public hearing.  The Energy
           Energy Facility Review                          Facility Review Board can set its
           Board, will local                               own standards for public comment,
           citizens have a chance                          and is provided with no requirements
           to comment?  (Use                               by the Department of Energy Act.

           Policy 1, page 26)
    I 131. The makeup of the          Public Service       This Board was established by the
           Energy Facility Review   Electric & Gas         Legislature in the Department of
           Board should also         Company               Energy Act and is beyond the
           include representatives                         control of DEP.
    * ~from the Departments of
           Labor & Industry, Com-
           munity Affairs and a
           fifth member appointed
           by the Governor.
           (Page 66)

    IHOUSING

    -132. Use Policy 14 condones   American Littoral   This concern gas been addressed by
           poor development prac-   Society                the Location Policies which are designed
           tices by joining new                            to avoid poor development practices
           residential development                         and by the Resource Policy on Buffers
           with existing develop-                          on page 160.
           ment areas. (Page 34)

    *133. Use Policy 14 should       National Resources  Same comment as above.
    fl    ~hve no conditions since  Defense Council
           it encourages cumulative
           impact and should have
           the phrase "or in
           close proximity to"
           deleted. (Page 34)

    I134. The housing policies       National Marine       This has been added as Location Policy
           should clarify wet-       Fisheries Service   6.5.1.2.  See page 69.
    .3     ~lands filling.  (Page
           34)

    COMMENT                        SOURCE               RESPONSE

    135, How do you analyze        U.S. Fish &          The Wetlands Act and riparian statutes
         cumulative impact if      Wildlife Service    provide authority to manage smaller
         development of less                            numbers of units in the particularly
         than 25 units is not                           sensitive areas they address.  in other  f
         regulated.  (Page 34)                          parts of the CAFRA area, this is an-
                                                       omission which could only be rectified
                                                       by the Legislature.

    136. Condominium developers   American Littoral   Basic Coastal Policy Two, which encour-
         should be required to    Society               ages conservation of open space, applies
         conserve open space.                           to all coastal developments.  See page   f
         (Page 34)                   II.

    137. In Use Policy 15,         U.S. Department      This is incorporated in Use Policy
         height should be          of Housing &         7.2.8(e) in Chapter Three.  See page       I
         based on the pre-         Urban Development   134.
         vailing norm. (Page
         34)

    138. High density towers       American Littoral   See Use Policy 7.2.8 in Chapter Three
         do not conserve land      Society              on pages 134-135.
         when viewed cumula-
         tively. (Page 35)

    139. Motel and hi-rise         Conservation         Disagree.  Such projects like all
         standards in Use Policy  Society of Long       development, have to meet Location
         15 and 16 are too per-   Beach Island          and Resource Policies as well as the
         missive.  (Pages 34,                           applicable Use Policies.
         35)

    140. In Use Policy 15, set-   American Littoral   This factor, studied by Rutgers Center
         backs should be based    Society               for Coastal and Environmental Studies
         on potential wave energy                       under contract to DEP, is now included
         as well as roads and                           in the Location Policy for "High Risk
         parks.  (Page 34)                              Erosion Areas".  See pages 50-54.

    141. In Use Policy 16,         U.S. Department      Residential areas are protected from
                    hotels nd motes of Hosing &negative effects of hotels and motels              I
         should only be located   Urban Development   by Use Policy 7.2.8 concerning high
         in non-res ident ial                           rises, Use Policy 7.3.4 setting con-
         areas.  (Page 35)                              dition for hotel and motel construc-       I
                                                       tion, and Resource Policy 8.15
                                                       concerning "Buffers and Compatiblity
                                                       of Uses" in Chapter Three.  SeeI
                                                       pages 134, 136 and 160.

    142. Hotels and motels         American Littoral   This is addressed for all development.I
         induce unacceptable       society              by Resource Policies on Air and Traffic.
         levels of carbon                               See Chapter Three.  See pages 157 and
         monoxide.  (Page 35)                           163.                                       I

       COMMENT                         SOURCE                RESPONSE

    I 143. In Use Policy 18, how    John Forsythe            Clustering of units should enable a
            will concentration and                           developer to preserve valuable parts
            clustering affect                                of a site, such as dunes.
    I    ~dunes?  (Page 36)

       144. How can you apply          American Littoral   This can be accomplished by reducing
            clustering to low          Society               the size of each lot and putting the
    I     ~~density housing.                                remaining area into common open space.
            (Page 36)

    I 145. The Program should          American Littoral   Seasonal homes help promote tourism.
            not promote seasonal       society               One of the possible secondary impacts
            homes. (Use Policy 18,                           of their construction, however, is
            Page 36)                                         that they may be converted into year-
                H                                          ~~~~~~~~~~~~round housing.  This potential will
                                                           be considered in the review of any
                *                                          ~~~~~~~~~~~~~application to build seasonal homes.

      146. There is no legal base   New Jersey Shore    "'Encouraged" is not the same as
            for encouraging deve-    Builders Assoc.         "required" and is perfectly legal
    I    ~ ~lopments to meet fair                           terminology.  This policy has been
            share housing standards.                         rewritten.  See Use Policy 7.2.4 on
            (Use Policy 20, Page 36)                         page 133 in Chapter Three.  The
                                                           determination of "fair share" is the
                U                                          ~~~~~~~~~~~~~responsibility of the Department of
                *                                          ~~~~~~~~~~~~~Community Affairs.

    1147. Use Policy 20 should         Public Advocate      Same comment as above.
            develop a formula to
            insure fair share
    I    ~housing.  All large
            resident ial deve lop-
           ments should include
    I    ~low income units.
            (Use Policy 20, Page 36)

      148. Campgrounds are in         DEP - Green Acres   The problem has been addressed.
    W     ~conflict with trans-                             See page 93 for campground policy.
            portation.  (use                                 Campgrounds also have to meet all
            Policy 21, Page 36)                              Use and Resource Policy.

      149. Terminology should         U.S. Department       Upon discussion, this comment was
           be changed from non        of Agriculture        withdrawn by USDA.
    I    ~prime agricultural
            land to non prime and
           non unique farmland.
    -3     ~(Use Policy 21, Page 36)

      150. Use Policy 21 should       Atlantic Audubon    This is part of the assessment of
    '1    ~include access to trans- Society                  "Development Potential".  See Location
           portation as a siting                            Policy in Chapter Three, especially
           criterion.  (Page 36)                            pages 89-94.

    COMMENT                        SOURCE               RESPONSE                                   I

    151. Use Policy 21 should      DEP - Division       Although this policy is no longer
         include valuable and      of Fish, Came &      included, wildlife habitats are addressee
         unique wildlife habi-    Shellfisheries        by Policy 6.4.8 of the Special Lands
         tats.  (Page 36)                               Area Location Policy in Chapter Three.
                                                      See page 62.

    152. Use Policy 22 should -   American Littoral   Agreed.  See Use Poicy 7.2.1 in Chapter
         prohibit lagoon devel-   Society               Three on page 132.
         opment.  (Page 37)

    153. There are many loca-      New Jersey Shore    Disagree.  Lagoon development requires
         tions where lagoon        Builders Assoc.      unnecessary damage to sensitive natural
         construction is sound.                         features for development which could be
         (Use Policy 21, Page 37)                       located in many other places.

    154. Barrier free design       DEP - Green Acres   This policy has been changed to require
         should exist at all                            barrier free design in all public
         levels of development. areas.  The added cost of such design    I
         (Use Policy 23, Page 37)                       is the reason it is required in dwelling
                                                      units in only larger projects. (See
                                                      page 133.

    155. The Use Policies should  Natural Resources   Agreed.  See Resource Policy on "Public
         provide full access to   Defense Council       Access to the Shorefront" on page 158
         the public. (Use Policy                        in Chapter Three.
         23, Page 37)

    156. Need to include water    American Littoral   This has been adressed by Use Policy
         dependent use sentence.  Society               7.3.1 giving priority for waterfront
         (Page 37)                                      sites to recreation.  See page 135.

    PARKS AND RECREATION

    157. What type of buildings   American Littoral   Buildings which enhance the recreational
         are implied for recre-   Society               experience and are consistent with the
         ational areas?  (Use                           other Coastal Policies.
         Policy 24, Page 37)

    158. Clarify developers        American Littoral   Developers proposing to build on water-
         responsibility to         Society              front sites must show that they have
         demonstrate use is                             examined and proved infeasible, recre-
         not practicable.  (Use                         ational use of the site.
         Policy 25, Page 37)

    159. Use Policy 25 should      Natural Resources   This is clarified by the "Resort/Recre-
         include specific policy  Defense Council       ational Use Policies" in Chapter Three.
         about what will be                             See Policy 7.3.1 on page 135.
         prohibited. (Page 37)

    160. Use Policy 25 should      DEP - Division of   Such structures which meet the condi-
         not exclude structures   Fish, Game &          tions in Use Policy 7.3 in Chapter
         for recreational          Shellfisheries       Three are permitted.  See pages 135-
         fishing. (Page 37)                             137 and also Use Policy 7.5.5
                                                       on page 147.

                                                                                                I

     COMMENT                         SOURCE               RESPONSE

    I 161. In Use Policy 27 change  American Littoral   The intent of this policy is to indicate
    W     "~contain" to f compa-     Society              that industrial development proposed in
           tible".  (Page 37)                              a site acceptable according to the
                                                         Location Policies should include within
                                                         it areas for recreation. The wording
                                                         of the policy has been changed. See
                                                         Use Policy 7.3.2 in Chapter Three on

                                                         page 135.

      TRANSPORTATION

      162. Will highway projects    Public Advocate        Yes.  See revised Public Facility Use
           not serving existing                            Policies in Chapter Three on pages
           areas be discouraged?                           147-148.
           (Page 38)

    * 163. Use Policy 29 for roads  American Littoral   The Public Facility Use policies are
    *     ~does not respond to        society              designed so that the need for a facility
           incremental growth.                             and its impacts are considered.  See
           (Page 38)                                       also "Secondary Impacts" Resource
                                                         Policy in Chapter Three on page 159.

      164. Reword Use Policy 29       U.S. Department of  Disagree.  DEP wants to be sure that
           to encourage road pro-   Housing & Urban        the construction of a road does not
           jects to serve develop-  Development            cause an unintentional "developing
           ing areas adjacent to                           area"
           settled areas. (Page
           38)
    - 165. New highways are not       American Littoral   Use Policy 7.5.4 in Chapter Three has been
           synonymous with           Society               added prohibiting transportation facilities
           access.  (Use Policy                           which block access.  See page 147.
           29, page 38)

    I INDUSTRIAL DEVELOPMENT

    * 166. Use Policy 31 includes   Public Advocate        The policy has been revised and tightened
    *     ~~an escape clause in                            in language.  See Use Policy 2.6.1 in
           "industries of benefit".                        Chapter Three.
           (Page 38)

      167. Effect of the Strategy   Manchester Manu-    Disagree.  For example, to date, DEP
           will be to haft ~indu~s-   facturers Assoc.    has approved every industrial and
           trial and commercial                            and commercial development proposed
           develoment in Ocean       Asarco Inc.          in Ocean County under CAFRA.

      MINING

    - 168. Use Policy 32 should       Public Advocate      Acceptable reclamation plans, although
           require security for                            not with security deposit, is a condition
           reclamation or upgrad-                          for approval of mining projects.  See Use
           ing to preexisting con-                         Policy 7.6.2 in Chapter Three on page
           dition. (Page 38)                               148.

    COMMENT                         SOURCE               RESPONSE

    169. Do not insinuate           New Jersey Shore    Agreed.  Use Policy 7.6.2 sets accept-
         that no new mines         Builders Assoc.       able conditions for the location of
         should open because                             mines.  See page 148.
         sand and gravel are
         needed for industry
         and roads.  (Use Policy
         32, Page 38)

    170. Fish and Shellfisheries  DEP - Division of   This is addressed for all uses in the
         distribution should be   Fish, Game &           "Special Water Areas" subsection of
         included in subaqueous   Shellfisheries         Chapter Three.  See pages 31-38.
         mining. (Use Policy 32,
         Page 38)

    SOLID WASTE AND RESOURCE RECOVERY

    171. Use Policy 33 should       Sierra Club          This will happen as the district
         conform to District                             plans are developed.  See Use Policy
         Management Plans (Chapter                       7.5.6 on page 147 and the "Other
         325) to all applicable                          Programs in DEP" section of Chapter
         standards.  (Page 39)                           Four on pages 167-170.

    AGRI CULTURE

    172. Use Policy 35 should       Cape May             The definition of prime farmland has
         include not only active  Planning Board         been changed accordingly.  See Location *
         areas, but also fallow                          Policy 6.4.11 on page 6.5.
         and vacant land for
         future agricultural
         use. (Page 39)

    173. Use Policy 35 will         New Jersey Shore    Agreed.  The policy is intended to
         pull farmland off         Builders Assoc.       lead to the maintenance of more
         the open market.                                farmland.  See page 65.
         (Page 39)

    SHORE PROTECTION                                                                                 I

    174. Is DEP attempting to       Speaker at           The beaches are for tourists and state
         to preserve beaches       Public Meeting        residents.  They must also be preserved !
         for tourism?  (Use                              because of their storm protection function.
         Policy 36, page 40)

    175. No guidance as to          Public Advocate      The Shore Protection Use Policies in
         whether structural/ Chapter Three now explicitly state a
         nonstructural shore                             preference for nonstructural solutions.
         protection solutions                            See Use Policy 7.8.1 on page 149.
         are favored by DEP.
         (Use Policy 36, Page 40)

                                                                                                I~

    COMMENT                        SOURCE               RESPONSE

    176. There is no require-      Public Advocate      Use Policy 7.8.3(f) in Chapter Three
         ment that public-                              makes the enhancement and protection
         funds be limited to                            of public access a requirement for
         beaches that comply                            approval of a shore protection
         with the spirit of                             See page 150.
         public access. (Use
         Policy 36, Page 40)

    177. Use nonstructural         Cape May County      Agreed.  See Use Policy 7.8.1 on
         solutions with            Planning Board       page 149.
         structural as last
         resort.  (Use Policy      Public Advocate
         36, page 40)
                                  American Littoral
                                  Society

    178. Preference to methods    National Marine       Use Policy 7.8.3(g) in Chapter
         which minimize adverse   Fisheries Service   Three incorporates this sugges-
         impact on living marine                        tion.  See page 150.
         resources. (Use Policy
         36, Page 40)

    179. Nonstructural should      U.S. Department      This is now included in the Shore Pro-
         include stabilization    of Agriculture        tection Use Policy 7.8 in Chapter
         of dunes with beach                            Three.  See page 149.
         grass, sand fences and
         pedestrian control.
         (Use Policy 36, Page 40)

    180. How will Rutger's         DEP - Division       It was used in the formulation of Location
         study on Coastal Geo-    of Marine Services  Policies for "High Risk Erosion Areas",
         morphology be incor-                           "Dunes", and the "Shore Protection" Use
         porated into the                               Policies in Chapter Three.  See pages
         Strategy? (Page 40)                            50, 54, and 149.

    181. Stronger policy con-      Marine Trades        Economic factors are considered.  See
         cerning adverse eco-      Association          the conditions in Use Policy 7.8.3
         nomic, as well as                              in which new shore protection struc-
         environmental, effects                         tures would be acceptable, especially
         of shore protection                            (b) and (c) on page 149.
         projects must be devel-
         oped.  (Page 40)

    RECREATIONAL BOATING

    182. Pollution and fuel        League of Women      The policies for recreational boating have
         conservation should be   Voters                been rewritten.  Facilities for sail and
         written into policies. oar boating are given preference over
         (Page 40)                 Atlantic Audubon    facilities for motor boats because of
                                  Society              concern for both water and noise pollu-
                                                      tion, and conservation of fuel. Also,
                                  DEP - Bureau of      all marinas are required to have pump
                                  Air Pollution        out stations.  See Use Policy 7.3.6 (c)
                                  Control              and 7.3.7 on page 137.

    COMMHENT                       SOURCE                RESPONSE

    183. What happens when         American Littoral   They will not be approved.  Construc- I
        marina expansions are    Society                tion of new or expanded marinas must
         not economically fea-                          meet the Location Policies as well
         ible?  (Page 40)                               as Use Policies 7.3.6 - 7.3.10 inI
                                                      Chapter Three.

    184. Recreation boating        DEP - Division        Agreed.  Use Policy 7.3.7 has been
         should be directed        of Environmental    added to Chapter Three.  See pageI
         towards sail and oar      Quality               137.
         since hydrocarbon
         emissions from motor                                                                      I
        boats cause pollution.
         (Page 40)

    185. Has DEP relaxed           Yacht Club            The Coastal Program provides a state-
        marina building status?  Owner                 ment of policy for siting marinas which
         (Page 40)                                      will help clarify where marinas can
                                                      and cannot be built. See Use Policy
                                                      3.6 in Chapter Three.

    186. A policy encouraging      Marine Trades         Questions of inequitable taxation and I
         expansion of existing    Association           growth capital are outside the juris-
        marinas is essential,                          diction of DEP.  The formulation of a
        but environmental                              common set of policies in the Segment
         restraints, such as                             should make the permit procedure
         a complicated permit                           simpler.  DEP believes in encouraging      -
         procedure, inequitable                         public marinas to expand recreational    f
         taxation, and lack of                          benefits for all N.J.'s residents.-
         growth capital presently                       See Policies 7.3.6 - 7.3.10 on pages
         restrain that development                      136-137.
         which is being encouraged.I
         Growth of private marinas
         should be encouraged over
         public marinas.  (UseI
         Policy 38, page 40)

    PORTS AND CONMERCIAL BOATING

    187. Does Use Policy 40        American Littoral   Yes.  See Use Policy 7.3.6(b) on page
         require improved          society              137 and Resource Policy 8.12 on page
         access to marinas?                             158 in Chapter Three.I
         (Page 40)

    188. How long in time does    American Littoral   The phrase has been omitted.  See
         "foreseeable" mean in    society               Use Policy 7.7.1 in Chapter Three
         the Statement, "Non                            on page 149.
        water dependant develop-
        ment in port areas shall
         be permitted to the
         extent forseeable ...

         (Use Policy 40, Page 41)

    I COMMENT                         SOURCE               RESPONSE

      DREDGING AND DREDGE SPOIL DISPOSAL

    * 189. Demonstrate viability    National Marine        This is the intent of the dredging
    *     ~before encouraging.       Fisheries Service   policy.  See Location Policies 6.3.8.5
           dredging projects.                              and 6.3.8.6 in Chapter Three on
            (Page 41)                                      page 47.

      190. Good quality spoils        League of Women      More information is needed on this
           can be used to restore   Voters                 idea.
    I     ~wetlands.  (Page 41)

      191. Descriptions of benthic  DEP - Division         This has been included in the "Water
           habitat should be         of Fish, Game &       Areas" Location Policies in Chapter
            included.  (Page 41)      Shellfisheries       Three.  See pages 24-50.
    * 192. Dredging of shallow        DEP - Division       This is the intent of the dredging
    *     ~areas and changing        of Fish, Game &       policies, particularly Location Policy
           euthropic character-      Shellfisheries        6.3.8.6(d) in Chapter Three.  See
            istics should be                               page 47.
           discouraged. (Page 41)

      193. CLAM is not explained    DEP - Division         The dredging policy has been totally
            in Use Policy 42.         of Fish, Game &      reorganized and reworded.  See page
            (Page 41)                 Shellfisheries       47.
    * 194. Land disposal should       American Littoral   This issue will be addressed on a
    *     ~not be encouraged for    society                case by case basis depending on
           highway grading; pilings                        applicable construction standards.
           should be used. (Page
           41)
      195. Without development of   Marine Trades          Dredging is conditionally acceptable
           dredge spoils areas,      Association           or encouraged in certain areas.  See
    I    ~New Jersey's dredging                            Water Acceptability Table on page
           needs will remain unfilled                      45, and policies on page 47.
           and the state's waterways
           will continue to deteri-
           orate. (Page 41)

    1196. A concerted effort must  Marine Trades           The Location Policy of New Dredging
           be made to locate and    Association            is intended to encourage private as
           develop spoils areas                            well as public investigation of such
           physically and econom-                          alternatives.  See page 47.
           ically accessible to the
           public and private sector.
           Investigation of alterna-
    I     ~~tive dredging methods
           must be pursued. (page 41)

    COMMENT                        SOURCE               RESPONSE

    SEWERAGE

    197. Drainage to discharge    Sierra Club           This is required by law and is implicit
         of sewerage should                             particularly in the "Other Programs in
         conform to all appli-                          DEP" section of Chapter Four.  See
         cable effluent and                             pages 167-170.
         water standards, rules
         and regulations and
         permit applications.
         (Use Policy 47, Page 42)

    198. Facilities with excess   Public Advocate       This has been addressed by the
         capacity and intercep-                         "Secondary Impacts" Resource Policy
         tor lines should be                            in Chapter Three.  See pages 159-
         prohibited across low                          160.
         density areas. They
         cause new development
         and secondary impacts.
         Only facilities needed
         for polluted areas
         should be authorized.
         (Page 42)

    199. Why is the aquifer/ National Resources  This issue is now addressed in the
         water supply issue        Defense Council      Resource Policies in Chapter Three
         not addressed in Use                           on Surface Use and Groundwater Use.
         Policy 45 and 46.                              See page 152.
         (Page 42)

    200. Use Policy #46 should    DEP - Division        This policy has been reworded, using
         change "once" to "if".   of Fish, Game &       the words "provided that" instead of
         (Page 42)                 Shellfisheries       ""once or "if".  See Use Policy 7.5.11
                                                       in Chapter Three on page 148.

    201. Use Policy 45 is con-    New Jersey Shore    Disagree, If on-site systems can be
         trary to DEP's policy    Builders Assoc.       built in conformance with all Coastal
         of regional sewer                              Policies they may enable development
         systems. (Page 42)                             without causing environmental harm.
                                                       See Use Policy 7.5.10 on page 148.

    202. Who defines "inade-       Stephen Gabriel      Sewage discharge is regulated by
         quately" in "inade-       Ocean City           the Division of Water Resources.
         quately-treated"          Resident
         sewage? (Use Policy
         47, page 42). Who
         will monitor the
         discharges?

    203. Will water quality        American Littoral   Yes, sometimes.  The Division of Water
         testing be required       Society              Resources sets standards for Water
         during dredging as                             Quality Certificates which may be
         seems to be implied                            applicable.  The Dredging Policy
         in Use Policy 42?                              has been rewritten.  See page 47.
         (Page 41)

      COMMENT                         SOURCE               RESPONSE

    I 204. Are package waste          American Littoral   They are conditionally acceptable.
           water treatment           Society               See Use Policy 7.5.10 in Chapter
           systems included under                          Three on page 148.
    I    ~the term "~waste water
           treatment facilities"
           in Use Policy 44?
           (Page 42)

      205. Referring to inade-        American Littoral   This question is addressed by Use
           quately treated           Society               Policy 7.5.10 which sets stringent
    -I    ~sewerage and its dis-                            standards for a number of factors
           posal:  (1) how will                            in terms of ground and surface
           the proper set back                            waters.  See page 148.
    I    ~distance be determined;
           (2) will it be deter-
           mined before building,
           and (3) is it based
           on soils? (Use Policy
           47, Page 42)

    I OCEAN DUMPING

    * 206. Change "should not"        American Littoral   The policy has been rewritten to
    *     ~~to "will not" in Use      Society       i      tprohibit"' ocean dumping.  See
           Policy 48. (Page 42)                            Location Policy 6.3.8.8 in Chapter
                                                          Three on page 48.

      LINEAR DEVELOPMENT

    I 207. Delete use policy 49.    Sierra Club            This "Linear Facility" policy has
           It is contrary to all                          been rewritten.  Such a policy is
           that CLAM represents.                          necessary because such facilities
                                                          are more difficult to site appro-

                                                          priately than most. See page 131.
    I 208. Please change "these       U.S. Department      The policy now requires that linear
           measures include the      of Agriculture        facilities not harm unique or irre-
           use of special runoff                           placeable areas and be the available
           and erosion control"                            alternative with least impact on
           etc.  (Page 43)                                 sensitive areas.  See page 131.

      209. Revise - "sensitive        New Jersey           Same comment as above.
           areas should not be       Conservation
    I    ~~sacrificed." in Use        Foundation
           Policy 49. Proposals
           should be given needs
           analysis. (Page 42)

      210. No waiver should be       American Littoral   Same comment as above.
           allowed especially        society
           for sewers, pipes, or
           roads. (Use Policy
           49, Page 42)

    COMMENT                         SOURCE                RESPONSE

    211. The document should        U.S. Fish &           The program includes such policies.
         indicate that non         Wildlife Service
         coastal dependant uses
        will be discouraged.
         (Page 26)

    SAND DUNES

    212. Building on destroyed    Steve Gabriel           This is included, to the extent
         sand dunes should be                            statutorily permissible, in the
         prohibited.                                     Location Policy on "Dunes" in
                                                      Chapter Three. See page 55.

    213. A disaster policy is       DEP - Green Acres' Major disasters are not specifically           I
         needed especially for                           addressed.  The policies on Dunes
         dunes.                                           (page 55) and Shore Protection
                                                      (page 149) are designed to addressI
                                                      normal annual storm threats.

    INNOVATIVE DEVELOPMENT

    214. More innovative devel-   DEP - Department    Such activities are included for energy
         opment should be           of Water Resources  and solid waste.  See Use Policies
         encouraged such as         Staff                 7.4.15 and 7.5.6 'and Resource Policies U
         solar, renewable                                8.16 and 8.17 on pages 147, 161 and
         energy, seperate                                162.
         potable-non potableI
         water systems, and
         independent sewerage
         (Clivus Multrom com-I
         posting toilet).

    COMMERCIAL FISHERIES

    215. More attention should    National Marine         This has been incorporated into the
         be paid to wise manage-  Fisheries Service   Location Policies for water areas in
         ment and utilization                             Chapter Three.  See pages 31, 32,I
         of commercial fisheries                         33, 34 and 37.
         and associated living
         marine resources.I
    URBAN AREAS                                           I   samjrga   fteCatlPorm

    216. Revitalization of urban Nancy Gahn i               samjrga  fteCatlPorm
         areas should be a policy.                       embodied in the Basic Coastal Policy of
                                                      concentrating the pattern of development,f
                                                      the Location Policies, and the Resource
                                                      Policy on "Neighborhoods and Special
                                                      Communities" on page 162 in Chapter
                                                      Three.

    COMMENT                        SOURCE               RESPONSE

    WATER TRANSPORTATION

    217. Water transportation      Geothermal           This has been noted in Use Policy 7.5.3
         systems should be         Energy Institute    in Chapter Three on page 147.
         discussed. (Page 38)

    WETLANDS

    218. What areas are being      DEP - Division       This statement, referring to offshore
         referred to "limited      of Fish, Game &      support bases, has been omitted.  The
         areas near Atlantic       Shellfisheries       policy for such facilities encourages
         City".  This establishes                       their location outside the Segment and
         bad variance precedent.                        therefore away from Atlantic City.  See
         This statement should                          Use Policy 7.4.3 in Chapter Three on
         be eliminated.  (Page                          page 140.
         93)

    219. DEP should preserve       Leo Sterenberg       Agreed.  The policy for use of wetlands
         wetlands in Atlantic                           is consistent throughout the Segment.
         City.                                          See Location Policy 6.5.1.2 in Chapter
                                                       Three on page 69.

    220. Are casinos going to      DEP - Division       Casinos will not be permitted on
         be permitted in the       of Fish, Game &      wetlands.  See Use Policy 7.3.5 on
         wetlands?  Be specific   Shellfisheries        page 136 in Chapter Three for Casino
         as to where casinos                            Location Policy.
         will go. (Use Policy
         17, Page 35)

    AIR QUALITY

    221. Atlantic City and other  DEP - Division        Agreed.  See Resource Policy 8.19 on
         urban areas are non-      of Environmental    Traffic in Chapter Three on page 163.
         attainment areas with    Quality
         respect to NAAQS for
         carbon monoxide.  Traf-
         fic congestion must be
         reduced.

    PUBLIC ACCESS

    222. Change "providing"        American Littoral   This concept of public access has been
         to "will increase"        Society              integrated into a Resource Policy
         in Use Policy 17.                              applicable to all development.  See
         (Page 35)                                      Resource Policy 8.12 in Chapter Three
                                                       on page 158.

    MARINE SANCTUARIES

    223. Great Bay Mullica         Ocean County         Agreed.  DEP-OCZM has intentionally
         Inlet areas should be    Planning Director   recommended to NOAA that all coastal
         a NJ Marine Sanctuary.                         inlets, specifically including the
                                                       Great Bay Mullica estuary be con-
                                                       sidered for designation as a
                                                       Marine Sanctuary.

    COMMENT                         SOURCE               RESPONSE

    224. Need a category "Marine  Ocean County           Eight "Special Water Areas" have been
         Recreation Areas."        Planning Director   included in the Location Policies in
                                                      Chapter Three.

    AREAS FOR PRESERVATION AND RESTORATION.

    225. Document lacks policies  National Marine        This is now included in Chapter Six
         and criteria for desig-  Fisheries Service   on page 196.
         nating areas for restor-
         ation and preservation.                                                                    E
         (Page 145)

    GEOGRAPHIC AREAS OF PARTICULAR CONCERN

    226. The Strategy does not    National Resources  This is now included in Chapter
         specify GAPC designa-    Defense Council       Six on pages 194-195.
         tion or strategies forI
         additional designations.

    LOCATION POLICIES

    227. Climax in "low distur-   Burlington OCS         Six variables are to be evaluated to
         bance" definition may    Task Force            determine the environmental sensitivity
         not be the only useful                         of a site.  See Section 6.6 of Location
         criteria.  (Page 147)                          Policy in Chapter Three on pages 81-89.

    228. Building should not be   Ruth Fisher            Agreed.  See Location Policies for Lower
         permitted at the water's                       and Upper Water's Edge in Chapter Three.
         edge.

    229. There should be no        Ruth Fisher           Agreed.  See Location Policies for
         permitting in virgin                           "Specimen Trees", "Prime Forest Areas"
         areas.                                         and "Prime Wildlife Areas" in Chapter
                                                      Three on pages 60, 61 and 62.
    230. Specially valued water   DEP - Division         These are included.  See "Special
         areas should include      of Fish, Game &      Land Areas" and "Special Water Areas"    I
         wildlife habitats i.e.   Shellfisheries         sections of Location Policy in Chapter
         canvasback (LSP) and                           Three.
         scaup staging areasI
         (Raritan). (Page 152-
         153)

    231. Where are "sensitive"    American Littoral   This is now defined more precisely in
         lands?  (Page 135)        Society              the Location Policy in Chapter Three.

    232. Will Great Bay Estuary   DEP - Division         The activities in this area are con-
         be a Sanctuary with       of Fish, Game &      trolled, but not restricted.
         restricted hunting,       Shellfisheries
         trapping or fishing?
         (Page 217)

    I COMMENT                         SOURCE               RESPONSE

      233. Some areas are recog-    U.S. Department        This is the reason development in certain
           nized as valuable areas  of Energy              areas is discouraged or prohibited.
            for preservation. The
            Strategy should designate
            those areas from the
            start. (Page 145)

      234. Please cite examples      DEP - Division        The term "preservation" is defined in
           of preservation, and      of Fish, Game &       the Glossary on page 313.  Examples
           give definition.           Shellfisheries       of different types of sites are pro-
            (Page 146)                                     vided in the "Using the Location
                                                          Policies" beginning on page 316.

    I 235. Bogs, aquifer'out-         Save Our River       Boas and Flood Hazard areas are now
            crops, and flood hazard  Environment            listed as Special Land Areas in Chapter
            areas should be included (SORE)                 Three.  Coastal plain geological for-
    I    ~ ~as preservation areas.                         mations are hydrologically corrected.
            (Page 138)                                      It is therefore difficult to single
                                                          out aquifer outcrop for preservation.
                                                          Instead, the Segment identifies
                                                          areas with high soil permeability
                                                          and low depth to seasonal high
                                                          water tables development sensitivity
                                                          factors.
    * 236. CLAM seems oriented to   American Littoral   The Coastal Program is intended to pro-
           development.  Can a       society               vide applicants and non-applicants alike
           non-applicant get a                             knowledge of where development proposals
            fix on land not suit-    Sierra Club           are likely to be approved or rejected.
    I    ~able for development.
            (Page 127)

    I 237. The meaning of distur-   Burlington OSC         Disturbance is the extent to which
           bance levels is not       Task Force            development has harmed or destroyed
           clear here.  (Page 137)                         natural vegetation.  This section has
                                                          been thoroughly revised. See Section
                                                          6.6 of Location Policies in Chapter
                                                          Three beginning on pages 81.

    1 238. Definitions of preser-   DEP - Division         See Glossary beginning on page 310.
    -     ~vation and conservation  of Marine Services
           may not be clear.
    I~~(ag 7
         23.Sensitivity mapping       National Resource   Agreed.  This will be a future
            should be done for the   Defense Council        activity of DEP.  See Chapter Seven
           entire coast.  (Page                            beginning on page 197.

    I~~17,17

    COMMENT                         SOURCE               RESPONSE

    240. CLAM is reactive.         National Resources  The Coastal Program can, and will,
        Therefore it cannot       Defense Council      provide strong advance indicationsI
         initiate designations                          of the suitability of a site for
         of preservation and                            development, without prejudging an
         restoration.                                   application.I

    241. The Program has not       Cape May County       DEP has identified "growth areas"
         determined capacity to   Planning Board        on the basis of their ability to
         absorb various densities                       accept development.  See pages 96-
         and quantities of                              99.
         development.                                                                               I
    242. The Strategy should        Salem County         Industrial development can be economi-
         encourage industrial      Planning Board       cally and energy inefficient, as well
         development not only                            as harmful to the environment if itI
         in existing developed                          is not sited in appropriate areas.
         areas but throughout                           Industry in undeveloped areas could,
         the State.                                     for example, threaten the touristI
                                                      industry.

    243. Is CLAM applicable to    New Jersey             A specific Linear Location Policy is
         linear facilities?        Petroleum            included in Chapter Three.  See page
         (Page 42)                 council              131.

    244. No method or criteria    New Jersey             The Coast-al Program is intended to
         are supplied for indus-  Petroleum             provide such criteria.
         try to determine con-    Council
         sistency with stateI

    245. Does CLAM delineate       Public Advocate       Yes.  The Coastal Policies, including
         residential, commer-                           CLAM, provide a predictable method
         cial, and industrial                            for making siting decisions.
         locations? (Page 127)

    246. More weight should be    DEP - Green            The Coastal Program balances sensi-
         given to sensitivity as  Acres Staff           tivity and potential.  Each has pre-
         opposed to potential,                          cedence in certain situations.I
         lest the developers
         take a mile on the
         inch.I
    247. There is a lot of room   Speaker at             The location policies have been
         to lower sensitivity in  Public Meeting        tightened and rewritten to minimize
        making a decision.  This                        the possibility of variances.  See
         is where variance can                          Chapter Three.
        occur. (Page 142, 143)

    248. The trade off in sensi-  Speaker at             The Coastal Program has done this. It
         tivity and potential      Public Meeting       can be performed on a site by site
        must be set.  Get on                            basis.  Carrying this out for the
        with it.  (Pages 142,                           Segment will be a future costly and
         143)                                           time consuming step.

      COMMfENT                        SOURCE               RESPONSE

      249. When will the Cape May   American Littoral   The Pilot will be printed and distri-
           Pilot Study be fin-       Society               buted for comment in May or June.
     I    ~ished?

      250. If you use the proposed  American Littoral   Yes.  Carrying capacity is one factor
           process, can you get      Society              used in setting sensitivity levels and
             afeeling for carrying                         is reflected in final determination
           capacity.  (Page 205)                           of acceptability for development.

    I251. All development in         Monmouth County       This is consistent with the Coastal
           Monmouth County east      Environmental         Policies for development managed by
           of public roads is        Commission            the Program.  See Lower and Upper
     I    ~opposed.                                        Water's Edge section of Location
                                                          Policy in Chapter Three, and Chapter
                                                          Four.

    1252. Trade off principles        Natural Resources   Disagree.  The Policies, particularly
           ignore existing envi-    Defense Council        the Air and Water Resource Policies in
           ronmental problems in                           Chapter Three require consideration of
           developed areas.                               existing environmental problems.  See

    I253. The basis of all CAFRA   New Jersey              Both state and federal law require the
           decisions should be       Conservation          balancing of economic and environmental
           environmental.  Where    Foundation             considerations.  The Coastal Program
           critical natural re-                            does, however, protect critical natural
           sources are threatened,                         resources.
           no trade offs should
    *     ~be considered.

      254. The Strategy should        National Marine      This concept is embodied in Lower and
           indicatie t'hat non-      Fisheries Service   Upper Water's Edge Location Policies
           coastal water depen-                            in Chapter Three.
           dent uses are destruc-
           tive to coastal
           living resource.
           Inland alternative
           should be included.

    I255. No consideration of        New Jersey Shore    Disagree.  This consideration helped
           "legitimate economic      Builders Assoc.       shape the Coastal Policies.
           aspirations of inhabi-
           ants of coastal zone"
           is included.

    -3256. Wording should be          American Littoral   The Segment document is an effort to
           stronger.  There are      Society              move in this direction.
           too many qualifiers.

    COMMENT                         SOURCE               RESPONSE

    257. CLAM is not applicable   Hartz Mountain         The Policies in this doucment will be
         to urban waterfront.      Industries           evaluated by DEP, the County Planning
         (Page 18)                                      Boards and the public to determineI
                                                     adjustments and major revisions
                                                     necessary for the rest of the
                                                     coastal zone. They are not
                                                     now proposed for the urban water-
                                                     front areas outside the Segment.

    258. Cape May is changing       Citizens Assoc.      Agreed.I
         quickly.  Rural and       to Protect Our
         recreation both con-      Environment
         tribute to the qualityI
         of life.

    259. The inventory and data   Public Advocate        Noted.I
         validation program are
         important to settle
         disputes.

    260. We are disappointed       New Jersey Shore    DEP-OCZM is now preparing a scope of
         that "potential" study   Builders Assoc.        services for a contract for this study.*
         has not been completed.

    261. Specific constraint and  League of Women        In the Segment, DEP has totally reorga-*
         potential should be       Voters               nized and rewritten the Coastal Policies*
         stated more succinctly.                        to be more clear and succinct.  See-
         (Page 127)                                     Chapter Three.

    262. Existing CLAM explana-   Atlantic County        The explanation has been completelyI
         tion hinders complete    Executive             rewritten.  See Location Policies in
         understanding.  (Page                          Chapter Three.
         127)

    263. CLAM should include a    National Resources  See the Secondary Impact Resource
         mechanism to evaluate    Defense Council        Policy on pages 159-160.I

         many developed areas.
         (Page 44)

    PERFORMANCE STANDARDS

    264. Does the encourage-       U.S. Department       Federal land is not in the coastal zone.
         ment of shorefront        of Transportation   Access will be a criteria for determin-
         access apply to federal                        ing consistency of federal actions with*
         property?  How will it                         the Program.  See Federal Consistency       *
         be implemented?  (Per-                         section of Chapter Five beginning on
         formance Standard 1,                           page 186 and "Public Access" Resource
         Page 49)                                       Policy on page 158.

    CONMMENT                        SOURCE               RESPONSE

    265. Reference should be       DEP - Green Acres   This is noted in Location Policy 6.4.5
         be made to the historic                         in Chapter Three on page 60.
         identification plan, or
         the existing inventory.
         (Performance Standard 3,
         Page 50)

    266. The prescription for       Burlington OCS       This reference has been omitted.
         late successional         Task Force
         forest trees might not
         be the optimum type of
         vegetation on parts of
         barrier islands or in
         the Pine Barrens.  (Per-
         formance Standard 4,
         Page 51)

    267. Rare vegetation and        Burlington OCS       The Resource Policy on "Vegetation"
         fauna can be nurtured                          addresses this issue.  See pages
         in improved environ-                            155-156.
         ments under public/
         private ownership.
         (Performance Standard
         4, Page 51)

    268. Planting of new vege-    American Littoral   Resource Policy 8.8.1 in Chapter Three
         tation by coastal         Society               suggests planting of "appropriate
         developers should be                            native coastal species."  A developer
         limited to indigenous                           is left the option to experiment,
         vegetation.  (Perform-                          having been warned that "non-suitable
         ance Standard 4, Page                           species plantings will do poorly or
         51)                                            die".  See pages 155-156.

    269. Performance Standard       DEP - Division       This has been broken into "Prime Wild-
         5 should be titled        of Fish, Game &       life Habitats"  under Special Land
         "Fish, shellfish          Shellfisheries       Areas on page 62 and several sections
         and wildlife manage-                           of Special Water Areas in Chapter
        ment."  Also hunting,                           Three.  See pages 31-39.
         trapping, fishing &
         shellfish should be
         added. (Page 51)

    270. Performance Policy 6      U.S. Department       This has been included in Resource
         should state that         of Agricutlure        Policy 8.7 in Chapter Three on
         coastal development                             page 154.
         will restrict soil loss
         during construction
         as required under the
         "Soil Erosion and
         Sediment Control Act,
         Chapter 251, PL 1975".
         (Page 51)

    COMMENT                        SOURCE               RESPONSE

    271. Public access should      American Littoral   Agreed.  The Location Policies on
        not be improved for       society              beaches (page 55, 71) in concert with
        areas with fragile                             the Resource Policy or Public Access
        resources that are                             (page 158) address this concern.
        already being threat-
        ened. (Performance
        Standard 1, Page 49)

    272. Only 10% of a site        American Littoral   The percentage varies depending upon
        for vegetation seems      Society              the intensity of development appro-       I
        to be a low require-                           priate for the site.  See Figure 19
        ment.  (Performance                            in Chapter Three on page 119.
        Standard 4, Page 51)

    273. How and by whom           American Littoral   This will be considered by DEP on
        will "anticipated         Society              the basis of all available infor-
        demand" be determined                          mation and informed judgement.
        with regard to water                           See page 152.I
        use. (Performance
        Standard 8, Page 52)

    274. Once through cooling      American Littoral   This is addressed by Location Policy
        should not be permitted  Society               6.3.8.17 regarding Effluent Release.
         in an estuary, because                         See page 49.
        most larvae development
        and physiological
        systems of acquatic
        life are highly depen-
        dent on proper temper-
        ature. (Performance
        Standard 10, Page 53)
    275. The use of micro          American Littoral   in the long run, it will be a lower costm
        climate analysis and      Society              for the tenant and should therefore
        latest planning prin-                          improve the builder's bargaining posi-
        ciples will rarely                             tion.  The sentence, in any case, has
        be a lower cost to                             been removed.  See Resource Policy 8.17 f
        builder as stated.                             in Chapter Three on page 162.U
        (Performance Standard
        12, Page 54)3

    276. Attempts to generate      American Littoral   See discussion of "growth" and "limited
        two growth subcenters    society               growth" areas in Chapter Three on page m
        rather than non-nodal                          96-99.
        dispersed growth should
        be made. (Performance
        Standard 14, Page 55)

    277. Soil erosion stand-       N.J. Department      They are now consistent with Chapter
        ards are too restic-      of Agriculture       251, P.L. 1975.  See Resource Policy
        tive - more so than                            8.7 in Chapter Three on page 154.
        Chapter 251.  (Perform-  U.S. Soil Con-
        ance Standard 6, Page    servation Service
        51)I

      COMMENT                         SOURCE                RESPONSE

    I 278. Change Performance         U.S. Department       The runoff policy has been totally
            Standard 6 to              of Agriculture        rewritten.  See Resource Policy 8.6
            seial precautions                               in Chapter Three on page 153.
    I    ~shall be taken to avoid
            contamination of sur-
            face and groundwater."
    1     ~ ~(Page 51)
      279. Mainland coastal           Sierra Club           That is the thrust of the Policy
           development should not                           noted above.
    1     ~ ~increase the amount of
            runoff. Detention areas
            should be maintained by
    I    ~the municipality. (Per-
            formance Standard 7,
    *     ~Page 52)

      280. The Pine Barrens           Joint Council         Noted.  Most of the Pine Barrens
           must be protected to       of Taxpayers          is not in the Bay and Ocean Shore
            insure future water                              Segment.
            supply. Ocean County
            should consider future
           resources before allow-
    I    ~ing further development.
            (Performance Standard 8,
           Page 52)

      281. What is  "unacceptable    Sierra Club            This policy has been rewritten.
            ... disturbance"?                               See page 152.
           Who deter-mines criteria?
           How is cumulative
            impact to be handled?
            (Performance Standard 8,
           Page 52)
    * 282. The Raritan River from. Middlesex 208            This will be addressed in the program
    fl    ~Victory Bridge to          Agency                for the rest of Coastal Zone to be
           Fieldville Dam and                               completed in late 1978.
           South River to Duher-nal
           Dam should have poli-
           cies determined by
           their water quality.
            (Page 52)

      283. In Performance Standard  Sierra Club             This idea is incorporated by Resource
           9, after effluent,                               Policy 8.3 in Chapter Three which states
           insert "and water                                that all coastal development must con-
           quality".  (Page 53)                             form with all applicable water quality
               *1~~~~~~~~~~~~~~sadrs

    COMMENT                        SOURCE               RESPONSE

    284. Conflict between Per-    Public Service        The conflicts are not apparent.  See
         formance Standard 9       Electric & Gas       effluent policy in Chapter Three on
         and applicable effluent  Company               page 49.
         standards (section 307
         of P.L. 92-500) is pre-  Marine Trades
         senting a problem.  The  Association
         policy also preempts
         P.L. 94-469 Toxic
         Substance Control Act.
         (Page 53)

    285. How will toxic sub-       New Jersey           They have been defined by DEP's
         stances be defined?       Petroleum            Division of Environmental Quality
         (Performance Standard    Council               and the Glossary on page 315.
         9, Page 53)

    286. Performance Standard      Public Service       See Water Acceptability Table on
         10 is vague.  (Page       Electric & Gas       page 45 and policies on following
         53)                       Company              pages for greater detail.

    287. Buffers should be         DEP - Division       This is one possible application of
         required on areas         of Fish, Game &      Resource Policy 8.15 on page 160.
         adjacent to state         Shellfisheries
         wildlife management
         areas where hunting
         is permitted to
         eliminate breach
         under Title 23 (pro-
         hibits hunting within
         450 feet of dwelling).
         (Peformance Standard
         11, Page 54)

    288. The Strategy must         New Jersey           The Program does now discuss the impli-
         address air regulations  Petroleum             cation, but inclusion of the regulations
         specifially and discuss  Council               is not considered necessary.  See
         their implications.                            Resource Policy 8.10 in Chapter Three
         It is not enough to                            on page 157.
         incorporate by refer-
         ence.  (Performance
         Standard 13, Page 55)

    289. CO and photochemical      DEP - Bureau of      The Basic Coastal Policy is that devel-
         chemical oxidants,        Air Pollution        opment, meeting other requirements,
         non-attainment areas      Control              should be built in a concentrated
         may conflict with                              pattern.  A proposal unable to meet
         Basic Coastal Policy      Pandullo Quirk       air standards cannot be built.  This
         2.  (Performance          Associates           issue is addressed in the Conflict
         Standard 13, Page 55)                          Resolution - Appeals section of
                                                       Chapter Four. See pages 174-175.

      COMMENT                         SOURCE               RESPONSE

      290. Add - "in this CAFRA       American Littoral   This policy has been rewritten.  See
           strategy" to Performance Society                Resource Policy 8.14 in Chapter Three
           Standard 15, Page 56)                           on page 159.
    -*291. Add - All CAFRA            Sierra Club           This has been added to the rewritten
    *     ~applications shall                              policy noted above.
           include secondary impact
           information and analysis
           of secondary impact.
           (Performance Standard
           15 Page 56)

    I 292. Endangered/threatened    National Marine        They are addressed in various sections
           species and marine        Fisheries Service   of Chapter Three.  See pages 31, 32,
           mammals conservation                            33, 34, 37, and 62.
    I    ~and preservation of
           endangered species
           should be discussed.
    *     ~(Performance Standard
           30)

    3 293. Noise standards are        U.S. Environmental  Noise is addressed in th~e Resource
    *     ~omitted in deter-          Protection Agency   Policy on "Buffers and Compatibility
           mining acceptable                               of Uses" in Chapter Three on page
           development. (Per-        U.S. Department       160.
            formance Standard 14)    of Transportation
    I MANAGEMENT SYSTEM

      294. CAFRA should develop       Public Advocate      Such a system already exists through
           policing mechanism                              the Riparian Lands inspectors, Marine
            (fines, revoke per-                             Police, Coast Watch Program of the
    I    ~mits, etc.)  (Page                               American Littoral Society and the
           57)                                             enforcement of the Attorney General.
                                                          Approval of the Coastal Management
                I                                        ~ ~~~~~~~~~~~~Program will make New Jersey eligible
                                                          for additional funding for enforcement
                                                          activities. Such activities are not
                                                          fundable in the planning stage.

      295. The Strategy has an        Public Advocate      Some administrative discretion is
            array of policies, but                          inevitable, but the Segment document
    I    ~~DEP still has discre-                           substantially tightens the policies.
            tion to grant permit.                           Their adoption as rules and regulations,
                                                          described in Chapter Three and Four,

                                                          will further limit discretion.

    COMMENT                         SOURCE               RESPONSE

    296. The Strategy is defi-    New Jersey             Disagree.  Chapter Four describes the
        cient_ in t~hat it fails   Petroleum           Management System DEP will use to
         to demonstrate that the  Council               carry out the program.  This system
        OCZM has the requisite                         does comply with the "Direct StateI
         authority to exercise                          Approach" to decision making under
         the degree of control                          the federal Coastal Zone Management
        required by federal law                        Act.
         to administer an effec-
         tive coastal zone manage-
        ment program.
    297. Must develop new          Jersey City           Local governments are asked to review
         system for sharing        Planning Director   permit applications.  The 1978 DEP
         review of permit                               contract with coastal counties,I
        decisions with local                            including 'Hudson, specifically requires
        governments.                                    that these county governments review
                                                     coastal permit applications, andI
                                                     also submit recommendations for
                                                     administrative or legal changes in
                                                     the State-county-municipal decision       I
                                                     making process.

    298. Use procedure for         Public Advocate       DEP already uses appropriate admini-
         issuing "orders to                             strative and judicial orders to
         show cause"*  (Page                            enforce coastal regulations.
         61)

    299. CAFRA could never deny   New Jersey Shore    Disagree.  DEP must be able to find
         a permit on the basis    Builders Assoc.       that a proposal would "prevent air
         of air quality.  (Page                         emissions ... in excess of..
         55)                                            capacities of the ... site and
                                                     within the surrounding region.
                                                     (CAFRA Section l0b). See page
                                                     296.
    300. The fact that CAFRA       American Littoral   Agreed, but the Wetlands Act and
         cannot regulate           Society              riparian statues do give DEP author-
         coastal development                            ity to manage the siting of smaller
        with less than 25         Monmouth County       projects in those particularly
        housing units is a        Environmental         sensitive areas.I
        weakness.  (Page 64)      Commission

                                 U.S. Fish &
                                 Wildlife Service

                                 National Resources
                                 Defense Council

                                 Cape May Board

                                 of Health

     COMMENT                         SOURCE               RESPONSE

    I301 . DEP should not dele- Public Advocate            DEP has asked for local review and
          gate CAFRA permit                               comment, but has retained decision
          authority to counties    Society for Envi-   making authority.  Legislative action
    I    ~and municipalities.        ronmental and        would be necessary to delegate the
           (Page 69)                 Economic Develop-   the decision making.
           *                        ~~~~~~~~ment (SEED)

     302. The Strategy as           Monmnouth County      To responsibly assess the "permnis-
          reflected by CAFRA's      Environmental         siveness" of the Coastal Program,
           record of four denials   commission             one should evaluate the decisions
           and many approvals is                           themselves, rather than the
           too permissive. (Page                           eighteen denials to date under
    1     ~159)                                           CAFRA.

     303. The National Marine        National Marine      DEP does involve appropriate
          Fisheries Service         Fisheries Service   federal agencies at pre-applica-
    I    ~should be involved in                           tion conferences, when appropriate.
          preapplicaiton con-
           ferences.

    I304. Strengthen Plenary          Public Advocate      The Review Board was established
          Hearing and abandon                             by the Legislature in CAFRA and
          Coastal Area Review                             could be modified or abolished
          Board.  (Page 159)                              only by them.
    *305. Can the pre-application  New Jersey Shore    DEP can and does give a preliminary
          conference establish      Builders Assoc.       indication in writing to the appli-
           approval or disapproval.                        cant after the pre-application
                                                         conference. DEP must retain the
                                                         right to modify that judgement on
                                                         the basis of the complete applica-
                                                         tion and public hearing.

    I306. Review of a specific       American Littoral   This is not the in-tent.  The
           proposal may result in   Society                proposed adoption of Chapter
           a variance with the                             Three as regulations will mini-
           Strategy. (Page 24)                            mize the likelihood of variance.

     307. Arthur Kill has special  Middlesex -208         This will be addressed in the program
          water quality problems.  Agency                 to be prepared for the rest of the
          Granting of riparian                            coastal zone in late 1978.
           permits should reflect
           environmental standards.
           (Page 64)
    *308. The National Resource    Vivian Li               One of the purposes of the Coastal
           Council cannot function                         Program is to provide such a state-
          without a design scheme                        ment of direction for riparian
           as mandated by CAFRA                           decision-making.  See page 19.
           (13:19-1) which is not
           fulfilled by Strategy.
    I     ~(Page 64)

    COMMENT                         SOURCE               RESPONSE

    309. DEP does not have an      Hartz Mountain        Chapter Three of the Coastal Program
        overall riparian land    Industries            provides overall policy for riparian
        policy.  It only reacts                         lands in the Segment.
         to individual applica-
         tions. (Page 64)

    310. Wetland/Riparian are      National Resources  This will be addressed in the Program
        not sufficient to         Defense Council       for the rest of the Coastal Zone to
        manage activities out-                          be prepared during 1978.
         side the CAFRA area,                                                                       I
         since their authority
         ends at mean high water,
        which is not acceptable.
         (Page 64)
    311. Wetlands/riparian         Public Advocate       Same comment as above.
         should be kept separate.I
         They do not do what's
         needed to manage the
         coastal zone. (Page 64)
    312. Will Wetlands denials    Delaware River         A wetlands permit decision can be
         be reviewable by CAFRA?  Basin Commission    appealed to the DEP Commissioner and
         (Page 64)                                      then to the Courts.

    313. Consolidate state per-   SEED                   The publication of a single set ofI
        mit programs into a                             coastal policies for the three programs
         single Coastal Permit    Middlesex - 208       in this document is a major step in
         Agency.  (Page 64)        Agency                this direction.

                                 Viking Marina -
                                 Marine Trades
                                 Associat ion
    314. Aquifer recharge areas   Burlington OCS         To make responsible coastal decisions
         should be considered      Task Force           and to fulfill the mandate of CAFRA         I
         and coordinated exclu-                         (Section l0a and 10d), the Coastal
         sively by the Division                         Program must consider recharge areas.
         of Water Resources.                            Its activities will, however, beU
         (Page 64)                                      closely coordinated with the Division
                                                     of Water Resources which is part of
                                                     the same Department.3

    315. Water Pollution Control  DEP - Division of   Agreed.
         Act and Water Quality    Water Resources
         Act will require all
         DEP permits to be
         consistent with these
         laws.  (Page 64)

      COMMENT                         SOURCE               RESPONSE

    E 316. Do new state water         National Resources  The new state acts are not relied
           quality acts serve to    Defense Council        upon to meet the federal Coastal
           meet Federal CZMA                               Zone Management Act requirements.
     I    ~requirements?  (Page                             See page 168 in Chapter Four.  As
            63)                                             rules and regulations are developed
                                                          for the acts, they will
                                                          be more formally integrated into
                                                          the Coastal Program Management
                                                          System.

    I 317. Is the Pinelands pipe-   Burlington OCS         Yes, they are synonymous.  See the
            line exclusion area in   Task Force             revised map on page 143.
            the same as the Division
           of Water Resources cri-
           tical areas? (Page 28)

      318. There are other areas    New Jersey Conser-  These areas are not in the coastal
    *     ~~in the Pinelands         vat ion Foundation   zone, and are being addressed by
           besides exclusion areas                         the Governor's Pineland Commission.
           that are as critical and
    I    ~as worthy of preserva-
           tion. They should be
            identified. (Page 29)

      319. A two tier local-state   U.S. Environmental  This is not feasible under current
           permitting system as in  Protection Agency   New Jersey laws.  Under the state-
           the Virgin Islands                              county contract, however, the desir-
           should be considered.                           ability and feasibility of admini-
           (Page 63)                                       strative or legal changes in the
                                                          decision making process will be
                                                          explored.

    * 320. The Office of Shore        American Littoral   The Coastal Program has been written
           Protection is the lead   society                with the concurrance of, and will be
           agency for beach erosion                        followed by, all parts of the Division
           programs and can con-                           of Marine Services, including the
            flict with Coastal                             Office of Shore Protection.
           Policies. (Page 64)

    * 321. How is DEP coordinating  Vivian Li              Most coastal decisions are made by
    *     ~~its agencies?                                  the Director of the Division of
                                                          Marine Services. See Chapter Four.

    I 322. The Strategy should        National Marine      The issue of economic harm, as well
           address the need for      Fisheries Service   as benefit, must be considered as a
           compensation when                               possible impact of some development.
    .3     ~development is                                  the Resource Policy on "Secondary
           allowed and fishery                             impacts" in Chapter Three states that
           habitat is lost. (Page                          probable secondary impacts must be
           64)                                             considered part of all development

                                                          applications. See page 159.

    COMMENT                         SOURCE               RESPONSE

    323. The creation of multi-   New Jersey             The Coastal Program adds 'no new con-     m
         ple land use controls    Chamber of             trols.  By presenting written policies
         is anti-business. There  Commerce              for existing programs, it will lessen
         is rising uncertainty                          uncertainty and increase coordination
         as to land ownership.                          of existing programs.  Also, by con-
                                                      sidering development potential, as        I
                                                      well as environmental sensitivity,
                                                      the Coastal Program will help guide
                                                      developers to suitable sites where        I
                                                      permit approvals are likely.

    324. DEP should not control   New Jersey             DEP, along with the other agencies, has
         land use.  DCA, DOE,      Chamber of           been given land and water use regulatory
         and DOT should be more   Commerce              powers by the Governor and Legislature.
         involved.  (Page 64)3

    325. Will other state agen-   National Resource   Yes.
         cies cooperate with       Defense Council
         the Program? (Page 64)
    326. The Strategy does not    Sierra Club            Agreed. The Coastal Policies and Manage--
         cite other laws which                          ment System Chapters (Three and Four)      3
        makes the implementation                        have been revised to include references
         of some policies possi-                        to other relevant laws.
        ble.  (Page 64)3

    327. DEP should have a memo   National Marine        While the DEIS is being publically
         of understanding with    Fisheries Service   reviewed, DEP will evaluate the need
         other agencies.  (Page                          for such memoranda.  A draft of such      I
         64)                                            a memo between DEP and the Department
                                                      of Energy is included in Appendix
                                                      J beginning on page 277.
    328. What is the relation-    Bureau of Land         This is now spelled out in the
         ship and conflict         Management           "Department of Energy" subsection of
         resolution mechanism                           Chapter Four on page 170 and inI
        between DEP & DOE.        Public Service       Appendix J on page 277.
         (Page 64)                 Electric & Gas3

    329. The document should       U.S. Fish &           Issues related to the HMDC will be
         indicate that the         Wildlife Service    addressed in the Coastal Program for
         Hackensack Meadowlands                          the rest of the coastal zone, to be
         Development Commission                         completed in late 1978.
         is exempt from the
        Wetlands Act. (Page 19)

    330. State reviews should      Public Service        As recognized by Congress in the
         not duplicate, and        Electric & Gas        federal CZM4A, states have distinct
         should be limited to      Company              knowledge and interests which should
         those items not already                        be expressed.  When this does lead to
         handled by the federal                         multiple agency review, DEP will try
         regulatory process.                            to coordinate review procedures,3
                                                      including when possible a joint public
                                                      hearing.

      COMMENT                         SOURCE                RESPONSE

    I 331. The make-up of the         Public Service        The Board was formed by the Legisla-
            Energy Facility Review   Electric & Gas          ture in the Department of Energy Act.
            Board is not broad         Company
            enough to provide
            complete input.
            (Page 64)

    I 332. The Strategy favors        Public Service        The management system of the Coastal
            decision-making at the   Electric & Gas          Program is consistent with the belief
            lowest practicable         Company               that the state should have a role in
    1     ~~level of government,                             the siting of a coastal facility which
            which is not always                              could bring major economic benefit
            desirable if a project                           and/or a major environmental cost.
            would benefit all N.J.                           The lowest "practicable" level for
            residents, and then                              such a decision is the State.
            contradicts itself by
            requiring State con-
     I    ~currence with locally
            approved proposals.
            (Page 62 and 70)

      333. Does the N.J. Depart-    U.S. Department         The N.J. Department of Energy is
           ment of Energy have        of Energy             required to prepare a ten-year
           responsibility for any                           master plan for the production,
            long range energy plan                          distribution, consumption, and
            supported by permits?                            conservation of energy in the state.
                                                           The Department is also considered to
                I                                        ~ ~~~~~~~~~~~be part of any permit decision-making
                                                           by state agencies concerning energy
                                                           facilities, but it does not exercise
                I                                        ~ ~~~~~~~~~~~~its own permit program concerning
                                                           energy facility siting. See Depart-
                                                           ment of Energy sect ion of Chapter Four
                                                           on page 170.
      334. What legal basis           U.S. Department       The statutory findings under Section
           supports such words        of Energy             10 and 11 of CAFRA which, invests the
     I    ~as  "will be encouraged"                          Commissioner of DEP with broad dis-
           or "to the maximum                               cret ion to make positive findings
           extent possible" or                              before a permit may be approved,
           "in a manner that                                provide a basis for these phrases.
           respects the built                               See Chapter Four, especially pages
           and natural environ-                             164-167.
           ment of the coastal
           zone

    1335. The state must coordi-   Mid-Atlantic              References to the Council has been
    *     ~nate more closely with   Fishery Manage-         added to the Management System Chapter
           the Fishery Management   ment Council            (see page 173) and to DEP's future
    I     ~Council.                                         plans (see page 198).

    COMMENT                         SOURCE               RESPONSE

    336. Where legislation         Association of        References to such other authorities
         exists to protect         New Jersey           has been added, particularly in
         sensitive areas or        Environmental        Chapter Four.  See pages 167-173.
        manage development,       commission
         the policies should
         refer to existing
         supportive statutes
         and at a minimum                                                                          I
         reflect the intent
         of these statutes.

    337. State must provide        Association of        Agreed.  The clearer statement of
         governing officials       New Jersey Envi-    policies in this document, and DEP's
         of coastal municipali-   ronmental Commis-   contracts with coastal counties are
         ties with clearer defi-  sions                 steps in this direction.
         nition of how they can
         incorporate Strategy
         policies into localI

    338. Final decisions on        Regional Plan         The staff in DEP's OCZM includes
         development in the        Association           a geologist, economist, landscape
         CAFRA area should not                          architects, planners with experience       -
         be made exclusively                             in topics ranging from energy facility
         by an agency with the                           siting to development of new towns to
         special environmental                          health and education, who have had
         and park outlook of                            experience in private industry'and
         DEP.                                           government agencies.
    339. Give attention to         Regional Plan         Office buildings and shopping centers
         elements totally          Association          are not included in the list of
         ignored here that                              facilities under CAFRA unless they
         will shape develop-                            require more than 300 parking spaces. -
        ment patterns e.g.                                                                        f
         offices, shopping.-

    340. The Strategy, as          Association of        Agreed.  DEP has formally proposed
         amended, should be        New Jersey Envi-    adoption of Chapter Three as a rule inU
         adopted as rule by        ronmental Commis-   the May 1978 New Jersey Register.  See
         reference in its          sion                 page 19.
         entirety and usedI
         in all rulings which      Regional'Plan
         bear a direct and sig-   Association
         nif icant impact on
         the coastal zone.

    341. The goals should be       New Jersey            They have been coordinated, and they      U.
        better coordinated with  Chamber of             appear consistent.  See appropriate
         other land use guidance  Commerce              sections of Chapter Four on pages
         programs such as DCA,                           171, 172, 171, 170, and 172.
         DOT, Agriculture, DOE    Regional Plan
         and DLI.                  Association

      COMYIENT                        SOURCE               RESPONSE

    I342. There should be a basic  U.S. Department of  Such consistency has been addressed
           coastal policy assuring  Housing and Urban   by DEP through review of the Guide
           consistency with the      Development           Plan and meetings with DCA and HUD
    .1    ~State Development Guide                          officials.  It was not felt necessary
           Plan.                                           to include it as basic policy.  See
                                                          pages 171-172.

    I343. How much coordination    Rutgers - Center    There is mutual sharing of planning
           is there between DEP-    for Coastal and       documents and consultation on specific
           OCZM and Pine Barrens,   Environmental          decisions affecting the jurisdiction
    ~~1    Wild & Scenic Rivers,    Studies                of more than one program.
           and Natural Preser-
           ation? (Page 213)

      344. DEP-OCZM has failed to   National Marine        DEP-OCZM has been in contact with the
           establish coordination   Fisheries Service   Council.  The Segment document includes
           with the Mid-Atlantic                           the Council as one of the "~Regional and
           Regional Fisheries                              Interstate Agencies" in Chapter Four on
           Management Council.                             page 173.

    1345. DEP-OCZM should coordi-  League for              This comment refers largely to the area
           nate with existing city  Conservation           outside the Bay and Ocean Shore Segment.
           plans on expansion of    Legislation            It will be part of DEP's activity later
     I    ~waterfront programs.                             in 1978, particularly through the
                                                          State-County contracts.

    I346. First line review          New Jersey            The present system cannot be changed
           responsibility should    Conservation          without an act of the Legislature.  DEP
           be with the local gov-   Foundation             encourages early coordination with the
           ermient.  CAFRA should                          Coastal Program so that potential devel-
     I    ~be the second line.                             opers still have the flexibility to more
                                                          easily revise their plans to be consis-
                                                          tent and approvable under the Program.

      347. Should there be an         Lawley Engineering  NOAA-OCZM at the federal level and
           interstate coastal                             informal working relationships between
           agency?                                         states fill this function.  An addi-
                                                          tional level of bureaucracy does not
                                                          seem necessary.

    I348. Tri-State should be        Tri-State Regional  Such recognition has been added to
           recognized for assess-   Planning Commisson  to the "Regional and Interstate
           ing consistency between                        Agencies" section of Chapter Four.
     I    ~plans financed by HUD,                          See page 173.
           DOT and CZM. (Page 70)

      349. There is a conflict        Save Our River       Development managed by the Coastal
     -     ~between the Strategy      Environment          Program will require both state and
           which recommends con-    (SORE)                 local approvals.  DEP plans to work
           centration in buillt                           with county and municipal governments
     *     ~up areas and current                           to encourage local understanding,
           municipal master plans                          acceptance and adoption of the
     *     ~do not.                                        Coastal Policies.

    COM4MENT                        SOURCE               RESPONSE

    350. Local zoning might be    Pureland               Many individual local decisions created
         adequate to protect the  Industrial             a pattern of development which led the
         coastal zone.             Complex              public and Legislature to conclude a
                                                      ,state role is necessary. Local zoningU
                                                      often cannot address issues of regional
                                                      or statewide significance.

    351. If a municipality         New Jersey            Because of this potential conflict,
         requires single dwell-   Builders Assoc.        the Coastal Program encourages rather
         ing units and the state                        than requires, clustering.  DEP expects
         requires clustering,                           to undertake a study in 1979 and work
        how is this resolved                           with municipalities to explain the
         by a developer.                                benefits of clustering.

    352. Include tourists in       American Littoral   DEP has attempted to involve tourists
         the decision making       Society              by scheduling summer public meetings
         process.                                       and displays at county fairs.  Their       I
                                                      general concerns are addressed by the
                                                      emphasis in the Coastal Program on
                                                      support for the tourism industry.

    353. Will OCZM mapping be      Department of         DEP will review the scope of services
         consistent with muni-    Community Affairs,  for the mapping contract with DCA
         cipalities under the      Division of State   staff.I
        Municipal Land Use Law?  and Regional
         (Page 69)                 Planning

    354. What would happen if a   Speaker at             Under an approved Coastal Program, DEP
        municipality would ask   Public Meeting        will be able to provide planning assis-
         for planning aid?                              tance to any municipality with an
                                                      approved Coastal Program. DEP may be
                                                      able to pass through funds to specific
                                                      municipalities for a particular task.

    355. DEP must begin to edu-   Atlantic County        Agreed.  DEP-OCZM's publication of
         ate the municipalites    Executive             "Coastal Zone Legislation" and "State
         as to what powers the                          Government and Coastal Zone Management" U
         state has.  (Page 69)                          were steps in'that direction.

    356. There must be a strong   Middlesex County    Agreed.  DEP has continued a contract
         county role in coastal   Planning Board        with coastal counties to provide county
         decision making.                                input to planning and to explore option s
                                                      for the future state-county relationship

    357. The Coastal Program       League of Women       This option, provided by the federal CZMA,
         should consider the       Voters               is not feasible under current New Jerse yf
         local implementation                           law.U
         option.                   Jersey City
                                  Planning Director

      COMMENT                         SOURCE               RESPONSE

    I 358. The lack of state          New Jersey           It is true that the state cannot over-
           override of municipal    Petroleum              ride municipal decisions except for
           decisions is a weak-      Council               public utilities.  See "Regional
    I    ~ness of the program.                             Benefit Decisions" in Chapter Five
           (Page 69)                                      on pages 192-193.

    * 359. The statement on page    New Jersey             For development managed by the Program,
    -     ~63 that "local govern-   Petroleum              State and local approval is required.
           ment will be urged to    Council                For others, where only local approval
           respect the OHS poli-                           is necessary, DEP can only offer its
           cies" should be                                 policies as advice under current
           stronger.  (Page 63)                            state law.

    I 360. There must be a demon-   New Jersey Shore    Such cooperation is a goal of DEP,
           stration of municipal    Builders Assoc.       but DEP can apply the policies for
           and county cooperation                          its own decisions while its seeks
    I    ~before CLAM can work.                            their acceptance at a local level.
           (Page 207)

    fl361. There is no effort in    National Marine        This coordination does take place,
    *     ~the document to coordi-  Fisheries Service   particularly with neighboring New York,
           nate with other State                           Pennsylvania and Delaware.
           CZM departments.

      362. It should be stated        U.S. Navy            It now is.  See "Excluded Federal
           clearly that all                                Lands -Segment'" section of Chapter
           federal lands are                              Two.
           exempted from coastal
           management planning.

    * 363. It should be stated        U.S. Air Navy        See Appendix G:  Excluded Federal
           that federal agencies                          Lands on pages 264-265.
           will determine con-
    I    ~sistency with state
           programs. (Page 77,
    I     ~~71)

      364. State review process      U.S. Air Force        Agreed.  It will be used whenever
           for federal consistency                        possible.  See "Federal Consistency"
           should use A-95 process.                        section of Chapter Five, especially
                                                         page 190.

    I 365. A more detailed discus-  U.S. Department        This has been added and now appears
           sion of federal con-      of Agriculture        in the "Federal Consistency" section
           sistency is necessary.                         of Chapter Five on pages 186-192.

    * 366. Omit the words "major    U.S. Department        This whole section has been expanded
           federal actions" in       of Agricultue        and rewritten.  See "Federal Consis-
           the federal consistency                         tency" section of Chapter Five on
           section, it has the                            pages 186-192.
           connotation of EIS.
           (Page 71)

    COMMENT                        SOURCE                RESPONSEI

    367. Coast Guard authority    U.S. Department        This is not an activity DEP wishesI
         for commercial vessel    of Transportation   to review for consistency with the
         safety and port safety                         Coastal Program.  It therefore is
         should be listed as a                          not listed in the "Federal Cons is-
         federal action. (Page                          tency" section of Chapter Five.I

    368. When will the list of    U.S. Fish &            It is now included in the "Federal
         Federal permits and       Wildlife Service    Consistency"' Section of Chapter Five
         licenses which require                         on pages 186-192.
         certification be avail-
         able for review.
         (Page 71)

    369. National Defense and      U.S. Navy             "Uses" are activities for which people I
         Security should be                             will apply for a permit.  The Coastal
         listed as a use policy.                        Program recognizes the national interest
                                                      in Defense in the "National Interests" f
                                                      Section of Chapter Five. See pages
                                                      177-178.

    370. Is Great Bay Boulevard   U.S. Fish &            No.  This is a state owned area.
         Fish and Wildlife         Wildlife Service
        management area going
         to be considered feder-I

    371. There are existing laws  Charles Irwin          DEP has explored existing legislation      I
         and new legislation                            and incorporated relevant laws into
         possibilities that                             the Management System.  See Chapter
         are not being dealt                            Four.  New legislation provides options
         with.                                          DEP will explore, although this is
                                                      primarily the responsibility of the
                                                      Legislature.

    372. Property owners should   New Jersey Shore    The Coastal Program respects the
         be compensated for        Builders Assoc.      constitutional prohibition against
         restricting the use of                         taking land without compensation.I
         their land.  (Page 88)                         The program may, however, lead
                                                      property owners to reap smaller (or
                                                      greater) economic gains than theyI
                                                      had anticipated.

    373. Discount should be        Cumberland County   The Legislature and municipal govern-
         provided on real estate  Board of Free-        ment, not DEP, set taxes.
         taxes for lands           holders
         afected by CAFRA or
         the Wetlands Act.

    374. Taxes should be higher   Ruth Fisher            This is beyond the power of the
         along coast to discour-                        Coastal Program or DEP.                     I
         age development.

    ICOMMIENT                         SOURCE                RESPONSE

     375. "Resource Conservation   U.S. Department         This is not an acitivity DEP wishes
    *     ~and Development" should  of Agriculture          to review for consistency with the
          be added to the list of                          Coastal Program.  It therefore is
           Federal Actions covered                          not listed in the "Federal Consis-
    I    ~by Federal consistency,                           tency" section of Chapter Five.
           since South Jersey is a
           research area. (Page 221)

     376. Will "variance clause"   Natural Resources   This phrase has been omitted.
          be maintained in the       Defense Council
           Strategy? (Page 24)

     377. It is beyond juris-        New Jersey Shore    Under CAFRA, DEP must issue a permit
          diction of CAFRA for       Builders Assoc.       for development of marine terminal and
    I    ~DEP to control boating                            cargo handling facilities and under thE
           facilities, ports, and                          Wetlands Act and riparian statutes, DEP
           commercial boating,                              must regulate development crossing
    I    ~and dredge spoil dis-                            or using wetlands or riparian lands.
           posal. (Page 40, 41).

    1 378. The Strategy is not        Natural Resources   Disagree.  See Chapter Four.
    -     ~suffi.cienEtfor imple-    Defense Council
          mentation requirements
           of the Federal CZMA.
           (Page 61)
    * 379. The policies are not       Natural Resources   Chapter Three containing the coastal
    *     ~legally binding.           Defense Council       policies is proposed for adoption
                                                         as formal rules and regulations.

    I380. The Strategy does not    United States            As the request of NOAA-OCZM, these
    -     ~have an inventory and    Fish & Wildlife         issues will not be addressed until
           planning process for       Service               DEP prepares the program for the
           energy facilities,                               rest of the coastal zone.
           assessing effects of
           shoreline erosion, etc.

    I381. Performance standards    Natural Resources   This has often happened with past
           should be issued as        Defense Council       decisions under CAFRA, Wetlands
           conditions to each                              Act and riparian statutes, and it
    I    ~permit approval, making                          will continue under the Coastal
           remedial actions pos-                            Program.
           sible if standards are
           not followed. (Page 49)

     382. Without new legisla-       U.S. Fish &           Such legislation is not necessary for
           tion, upland portions    Wildlife Service    federal approval of the New Jersey
    I    ~of the coastal zone are                           coastal program and is not being
           left unregulated.  Also                          proposed by DEP at this time.
           new legislation must
           address sub-threshold
           development in the
           CAFRA area.

    COMMENT             -SOURCE                          RESPONSE3

    383. Legislation should        Monmouth County       This must be done by an act of the
         address single family,   Environmental         Legislature.
         strip development         Commission
         throughout the coast.

    384. Is the non-CAFRA area    Charles Erwin          This must be addressed by the legisla-
        gDoing to be legisla-                           ture.  In the absence of legislative       -
         tively delineated?                             action, DEP will define a coastal zone
                                                      boundary and program for the
                                                      coastal areas outside the segment,
                                                      using existing legal authorities.

    385. North of Raritan River,  Vivian Li              Probably no new legislation will be
        how will wetlands,                             necessary.  This issue will beadrse
         riparian and CAFRA                             in the Program for the rest of the coast
         function?  Won't CAFRA                         later in 1978.
        have to be amended?
         (Page 17)

    386. Does the Program take    Charles Erwin          Some discretion is inevitable, andI
         away sufficient discre-                         the program administrator will, and
         tion that you would                             should, make some difference in the
         trust it in the hands                          way a program is run.I
         of a cigar smoking
         industrialist?

    387. Why has transfer of       Public Advocate       New Jersey legislation has only
         Development Rights (TDR)                        addressed TDR on an experimental
        been omitted from                              basis to date.  While it is a crea-
         the management possi-                          tive possibility supported by DEP,I
        bilities.                                       its use is not yet sufficiently
                                                      feasible to help manage coastal
                                                      resources.
    388. Will DEP do environ-      Public Advocate       Yes.  DEP has done such mapping and
        mental mapping?                                will propose mapping as an activity         I
                                                      to be funded by NOAA-OCZM probably
                                                      in 1979. See page 197 in Chapter
                                                      Seven.

    389. Will CLAM development                           Same comment as above.
         categories be mapped?

    390. The coastal program       League of Women       Agreed.  The Segment document is more
         should be much more       Voters               specific than the Strategy and future       *
         specific.                                      documents will make it more specific.
                                  Atlantic County-
                                  Executive

      CONM4ENT                        SOURCE               RESPONSE

    I 391. The Strategy is slanted  National Marine        The planned handbook is intended for
           toward developers.  How  Fisheries Service   everyone interested in the Program
           about an environmental,                         and will be called a "Coastal Hand-
           instead of a developer,                        book".

      392. If federal money is        Burlington OCS       This will be addressed in the Program
           going to be used on       Task Force            for the rest of the Coastal Zone later
           HMDC, projects should                           in 1978.
           be specified for 1.
           water quality; 2. salt-
           marsh restoration, and
           3. use of filled lands.
           (Page 66)
    393 Is the developers hand-  DEP - Division            No.  The handbook will provide spe-
           book the same as the      of Fish, Game &       cific implications and requirements
           EIS guideline handbook   Shellfisheries         of the Coastal Program, but will
           to be prepared by the                          build up on the guideline document
           Division of Fish and                            prepared by the Division of Fish,
           Game.  (Page 80)                                Games and Shellfisheries.

    * 394. A tourism study is         Ocean County         The Division of Travel and Tourism in
    *     ~needed.                   Planning Director   the Department of Labor and Industry
                                                         may sponsor such a study. DEP will
                                                          also explore the possibility of con-

                                                         ducting such a study.
      395. How long will it take    American Littoral   The Program for the entire coastal zone
           to complete planning      society               should be in place by the end of 1979.
           work? (Page 82, 9-10)

    I 396. What is the procedure    New Jersey             See Chapters One and Seven.
           and time table for        Petroleum
           seeking NOAA approval.   Council
           (Page 9-10)

      397. What is the nature of    New Jersey             NOAA, in conjunction with DEP, will
           forthcoming public        Petroleum            hold public hearings as required by
           meetings?                 Council               the National Environmental Policy
                                                         Act. In addition, DEP-OCZM staff
                                                         will continue to meet less formally
                                                         with interested individuals and
                                                          groups. See rear cover of Segment
                                                         document.

    'I 398. There should be a         Society for Envi-   DEP has a flawless record for com-
           clarification of the      ronmental and         pliance with the 90 Day Law.  The law
           90 Day Law, and DEP's    Economic Develop-   is cited in Chapter Four.
    SI    ~record in complying        ment (SEED)

    ~~~iti.

    COMMENT                         SOURCE               RESPONSE

    399. When will the federal    American Littoral   The federal CZMA and rules and regu-
         requirements mesh with   Society                lat ions provide criteria states must
         the state CAPRA require-                       meet in their coastal programs.  CAPRA  f
         ments?                                          provides a regulatory scheme which
                                                       will be part of the management system
                                                       for the program being submitted for
                                                       federal approval, and also require        I
                                                       the management strategy which was
                                                       prepared in the fall of 1977.

    400. Should developers and    Department of          While the Coastal Program is still in
         reviewers continue to    Community Affairs,  draft form, the Interim Guidelines,-
         use the Interim Guide-   Division of State   should be used.  DEP reviewers may use
         lines?  (Page 77)         and Regional         the DEIS to provide greater specificity
                                   Planning             and clarity to its discussion and
                                                       decisions.

    401. What would be the use    Speaker at             Funding regulatory programs such as
         of funding from a         Public Meeting       CAFRA which is now paid for with state
         federally approved                              funds, projects such as the Beach
         Coastal Program?                               Shuttle to Is land Beach State Park,
                                                       planning assistance to local government s
                                                       continued planning and other projects.

    402. Beach and dune restora-  U.S. Department        Agreed.  These issues are now addressed
         tion, stabilization,      of Agriculture       in greater detail.  See "High Risk
         and protection should                          Erosion Areas" and "Dunes" in LocationU
         be studied (Page 82,                           Policy and "Shore Protection" in Use
         83)                                            Policies in Chapter Three on pages 50,*
                                                       54, and 149.                               f

    403. Who will determine        U.S. Fish &           The Legislature has determined this
         greater than local        Wildlife             through CAPRA, Wetlands Act, riparian
         significance.  (Page                           statutes and the Department of Energy
         215)                                           Act.

    404. Give examples of local,  Natural Marine         Issues of greater than local signifi-
         and greater than local   Fisheries Service   cance, such as natural land or water
         decisions.  (Page 63)                           systems, or energy manufacture and
                                   Cape May County      distribution do not respect political
                                   Planning Board       boundaries.  A local decision is
                                                       whether to zone an area for housing        I
                                                       or industry.

    405. Can local zoning be       Jersey City           Yes.  The Board of Public Utilities
         overridden to site        Planning Director   can override municipal decisions
         energy facilities "in                          for public utlities.  See "Regional
         the national interest"?                        Benefit Decision" in Chapter Five

                                                       on page 192.

    I COMMENT                         SOURCE               RESPONSE

      406. National interest          Cape May County      This section has been expanded and now
           should deal with          Planning Board        addresses these and other issues.  See
    U    ~energy, recreation,                              National Interest in Chapter Five
           and open space.                                beginning on page 176.
           (Page 63)

      407. Does CAFRA have to be    New Jersey             No.  See section on National Interest
           amended in view of the   Petroleum              in Chapter Five beginning on page 176.
           National Interest re-    Council
           quirement of CZM Act?
           (Page 215)

    IPUBLIC PARTICIPATION

    - 408. There is no plan for       Public Advocate      opportunities for public involvement
    *     ~public participation.                           have been part of the Coastal Program
           DEP must involve public  American Littoral   since it began and DEP will continue
           early in process and      society               to encourage public participation.
           offer financial assis-                          See "Public Participation" in Chapter
           tance for participa-                            Four on page 174.  As funding becomes
           tion. (Page 207)                                available DEP will explore providing
                                                          financial assistance. See page 198.

    * 409. Not enough time to         Atlantic Audubon    The comment period was one month before
           react to Strategy.        Society               the public meetings and three months
           Hearings should be                              afterwards.  There will be a minimum
           before revisions.         Chamber of            60 day comment period on the DEIS.
                                     Commerce

                                     American Littoral
          *                         ~~~~~~~~Society

      410. There is no more than    Pureland Indust-    Strongly disagree.
           token consideration       rial Complex
    I    ~of public comments.
                                     League for Conser-
                                     vation Legislation

    I 411. Industry's views           Manchester Manu-    Disagree.  Preparation of the Strategy
           were not considered.       facturers Assoc.    has involved extensive public
                                                          involvement including industry's
               I                                        ~ ~~~~~~~~~~~~participation at public meetings.
                                                         The comments of the Manchester
                                                         Manufacturers Association and
                                                         others were considered and reviewed
                                                         as indicated by this document, in
                                                         preparation of the Bay and Ocean
                                                          Shore Segment. See page 174 and
                                                         pages 233-240.

    COMMiENT                       SOURCE               RESPONSE

    412. DEP must increase         Association of       DEP continues to hold a public hearing
         public participation      New Jersey Envi-    on each application, to discuss
         in permit decisions.     ronmental Commis-   pending applications with the Environ-
                                 s ions              mental Advisory Group each month, to
                                                     assist the "Coast watch"' program of     I
                                                     the American Littoral Society and to
                                                     welcome additional specific suggestions.*

    413. CLAM was developed        Association of       CLAM has been substantially revised on
        without substantial       New Jersey Envi-    the basis of public comments.  In
         public input, and         ronmental Commis-   addition, the Cape May Pilot Study to   f
        needs more detail.        sions               be published shortly by DEP, will be
                                                     made available for substantial public
                                                     comment.

    414. The Strategy was pre-    Asarco Inc.           Disagree.  DEP meets frequently with
         pared solely by a very                        energy representatives, builders
         small representation                          associations, engineers, marineI
         of our total society,                         trade associations and a number of
         namely, environ-                              Rotary and Kiwanis Clubs, who have
        mentalists.                                   made extensive comments on theI
                                                     Coastal Program.

    415. A much broader public    Regional Plan         As can be seen from this document
         should understand the    Association          public comments were received from a
         plan and participate                          wide range of individuals and groups
         in its preparation.                           and were incorporated into the Segment.

    416. Prepare the environ-      Regional Plan        The Inventory was prepared and
        mental inventory as       Associatio~n         submitted to the Governor, Legislature
        mandated by law.                               and public in September 1975.

    417. When applying CLAM,       Stephen Gabriel      Yes.
        will the local citi-      Ocean City
         zens continue to have    Resident
         input?

    GENERALI

    418. The alternate manage-    Public Advocate       Disagree.  The Strategy does comply
        ment strategies based                         with N.J.S.A. 13:19-16.  Also,I
        on inventory and          New Jersey          these comments address requirements
         carrying capacity have   Petroleum Council   of CAFRA, not of the federal CZMA.
        not been done.  The                           Using the Location Policies in
         Strategy fails to                             Chapter Three, specific policies
         comply with Section 16                        can be delineated for any land
        of CAFRA since it does                        or water area.  This is a finer
        not delineate various                          tool, better able to respond toI
         areas appropriate for                         change, than older forms of
        development of residen-                      analysis.
         tial and industrialU
         facilities.

      COMMENT                         SOURCE               RESPONSE

    I419. The terms "encourage"    U.S. Fish &             In the Segment document DEP has
           and "discourage" should  Wildlife Service    sought to close the loopholes.
           be discussed thoroughly                         Key terms are defined at the start
           and defined in greater   Natural Resources   of Chapter Three.  Some qualifying
           detail.  Also words       Defense Council       language is necessary to allow for
           such as "to the maximum                         the unique aspects of particular
           extent feasible", "pre-                         projects and to comply with the
    I    ~~ferable", "generally                            law.  A glossary is included on
           significant", and                               pages 310-316.
           "'inadequate"~ leave
    I     ~~disturbing loopholes.
           (Page 23)

    1420. If policies are to be    Public Advocate         Where legally permissible and justi-
    -     ~binding, "discourage"                           fiable, the term "prohibit" has been
           is not strong enough.                           added.
           "Prohibit" should be
           used instead. (Page
           23)

    I421. The Strategy should         Pureland Industrial One of the bases for the Coastal Program
           include an analysis       Complex              was a series of economic analyses per-
           of economic impact.                             formed by the Department of Labor and
           (Page 47)                                      Industry.  The economic impact of a
                                                          program such as the Coastal Program
                                                          would be difficult to isolate.

    I422. Will impact include an   Speaker at              This is difficult, if not impossible,
           indication of how many   Public Meeting         to determine reliably.
           jobs were lost and
           gained due to the
           Strategy and the
           alternatives.

      423. Will rights of property  Dredge Harbor          The rights of property owners are pro-
           owners be protected?      Yacht Basin           tected under the Fifth Amendment to
                *                                         ~~~~~~~~~~~~~the U.S. Constitution.

      424. What is the enforcea-    New Jersey             DEP can use the policies in areas man-
           bility of Strategy        Petroleum             aged under the Wetlands Act and riparian
    I    ~policies in areas          Council               statutes.  This issue will be addressed
           outside CAFRA.                                  in the Program for the rest of the
                                                          Coastal Zone.

      425. If CAFRA has no juris-   New Jersey Shore    Pipelines would have to cross through
           diction over the Pine    Builders Assoc.        land or water regulated under the
    I     ~Barrens, how can it                            Coastal Program to get from the oil
    *     ~prevent pipelines from                         or gas source to the Pine Barrens.
           being routed through
           the barrens.  (Page 28)

    COMMENT                         SOURCE                RESPONSE

    426. There is not enough        American Littoral   Agreed.  DEP tries to balance the need I
         time between presenta-   society                 for detailed review with the need for
         tion of CAFRA material                          efficient permit reviews which comply
         (preliminary analysis)                          with the 90 Day Law.I
         and the public hearing
         for individual permit
         decisions.
    427. Granting of the CAFRA    Citizens Assoc.         Disagree.  The decision balanced the
         permit for Tranquility   to Protect the          Tranquility Park as designed would have
         Park in Cape May County  Environment            been denied.U
         is very bad, especially
         filling wetlands and
         absence of buffers.I
         This destroys farming
         life style.

    428. How to amend the           Public Advocate       The Coastal Program can be amended
         Strategy, once it is                              through administrative action of the
         adopted, is neglected.                          Governor.  Major revisions would
                                                      require the approval of NOAA-OCZM.
    429. Networking process as    New Jersey              This is now addressed in Chapter
         it applies to riparian   Petroleum              Four on pages 165-167.I
         and wetlands legisla-    Council
         tion has not been
         addressed.

    430. Shopping centers and       Public Advocate       Facilities with more than 300 parking
         malls should be brought                          spaces requires a CAFRA permit.  DEP
         under DEP jurisdiction.                         review of smaller facilities under
                                                      CAFRA would require an act of the
                                                      Legislature.

    431. The Strategy fails to    New Jersey              Disagree.  Energy Policies in Chapter
         cons-ider 'national inter- Petroleum Council   Three were formulated with considera-
         est by not complying                             tion for the national interest.  See        I
         with specific require-                           also National Interest section of
         ments of federal regu-                           Chapter Five on pages 176-186.
         lat ions.

    432. How is consistency         Public Advocate       See Department of Energy Section
         between DEP and DOE                              of Chapter on pages 170-171 and
         going to happen.                                Appendix J on pages 277-283.
    433. There should be a          Natural Resources   Same comment as above.
         description of how         Defense Council                                                   I
         the Department of Energy
         or the Energy Facility
         Review Board will be
         governed by the poli-
         cies. (Page 26)

    I COi'MENT                        SOURCE               RESPONSE

      434. DEP should make final    Atlantic Audubon    Under state law, the Department of
           energy siting decisions  Society                Energy must be involved in the decision,
           if the coastal zone is                          and the relevant municipal government

           involved.                                      must agree.

                                     APPENDIX I

         I                    ~~~~~~PUBLIC MEETING QUESTIONNAIRE

           In November 1977, DEP's Office of Coastal Zone Management conducted a series
     of eight public meetings with interested citizens to discuss the policies of New
    IJersey' s Coastal Zone Management program,  and more  specifically,  to review the
     newly  released  Coastal Management Strategy for New Jersey.    Four  meetings  were
     held in the evening, two in the afternoon, and two in the morning.   The meetings
      included a tape recorded slide presentation, a short talk by a DEP-OCZM staff
    Irvember, and open discussion and questions and answers.   The meetings each lasted
     about two hours.

    *     ~At the suggestion of several environmental groups,  a questionnaire was dis-
      tributed during these meetings. Although there were not always available question-
     naire forms for all attendees, a sufficient number of the questionnaires were
    Ireturned to give an idea of the specific concerns regarding the coastal area that
     brought people to these meetings,  and their reactions to the presentation.   The
     questions and the responses from the fifty people returning questionnaires are
      listed below.

    IWHAT ARE YOUR MAJOR CONCERNS ABOUT THlE COAST?

    * - Protection and preservation of the natural coastal environment, especially
    *     ~the Wetlands area (This basic concept of "preservation" was expressed more
          then any other single concern).

    I-    Beaches--beach erosion, flooding, salt water intrusion, public access to
    W     ~all dry sand beaches, pollution of water and land.

    I-     Maintenance of waterways.

     -    Control of developers.

    I-     Water and air quality.

        - Exploring the reaction potential of the coast, especially with respect to
          linear reaction opportunities (trails, bike paths, canoe ways).

        - Ways in which the Green Acres program should acquire more total land from
    *     ~private parties.

     -    Coordination-'regarding Federal and State regulation; federal consistency.

    I  -General  land use planning.

     WHAT SHOULD THE STATE DO ABOUT THEM? WHO ELSE SHOULD BE INVOLVED?

    -    Constrain development.

    3-    Stop everything.  No development.

        - Enforce existing laws and enact stricter leglisation.

      - Implement all legal recourses open to DEP-OCZM to provide access to all
        beaches.

      - Strict enforcement of water quality standards and sewage treatment standards.
        Deny building permits to all municipalities until adequate sewage facilities
        are provided whereby the waterways can be cleaned up.
      - Stop ocean dumping.

      - Encouragement from the State to localities to maintain their beaches.

      - Advance identification of prime recreational areas.  Local recreational
        needs must be addressed through continuous public education and participation.

      - Wider dissemination of summary material in simple language to encourage
        more citizen input.I

      - Allow concerned groups to serve on committees taking a more direct part in
        making up the final management strategy.I

      - Provide workshops on proposed regulations to discuss them with the public
        at greater detail than meetings afford.I
      - Specific policies and siting criteria for OCS facilities must be delineated.

      - Maintain contact with Federal agencies, including periodic meetings with
        representatives.

      -County  and municipal zoning should be tied in with coastal zone management.I

      -Effective land use policies.

    WHAT WAS YOUR OVERALL IMPRESSION OF THIS MEETING?

        Interesting and Informative                                  32
        My concerns were not addressed                                5
        Not enough depth on discussion of certain types               9
        Not enough background provided                                4
        Too much speaking by DEP staff                                4I
        Ground rules should have further limited time allowed
             each speaker                                             4
        Meeting was too long                                          4I
        Meeting was too short                                          1
        Location of the meeting was poor I
        Time of the meeting was poor I

    Additional Comments

    -    Purpose of the Strategy was not made clear.I

    -    Meeting was well run.  OCZM staff impressive and professional.                             I

        Explanations by staff were done in simple, understandable language.

        IComments by others in audience were interesting.

    U~~Go o ifrain but greater depth is necessary.

    I- ~More extensive notification is needed.

        - All statements should be recorded by a court reporter.

    I  -   ~Speaker would not address himself to the questions.

      WHAT DID YOU THINK OF THE SLIDE SHOW?                       Number of People

           Interesting and informative                                   31
          Too much detail I
          Not enough detail I
    I       ~~Not enough background   6
          Too long
          Too short I
           Boring                                                         0
           Important Topics not covered4

    I  Additional Comments

    I  -Good  background information to serve as a general introduction.

      -    More information on OCS facilities needed.

    I  -Good  narration but illegible slides.

      -    Great music.

    I  DID YOU SPEAK AT THE MEETING?

          Yes                                                           15
    *       ~~No                                                           32

      HOW DID YOU LEARN OF THIS MEETING?

    I      ~~The Jersey Coast (DEP-OCZm newsletter)
          Newspaper Article                                              8
          Newspaper Ad I
    U     ~ ~Radio Announcement                                             0
          Fri end                                                        4
          Other                                                         25

     U           ~~~Communication from DEP-OCZM
               League of Women Voters
               New Jersey Chamber of Commerce
    I          ~ ~~American Littoral Society
               School
               Cape May County Environmental Council
    .3         ~ ~~Bayonne Chamber of Commerce
               SEED

    ARE YOU LIKELY TO COME TO FUTURE MEETINGS ON COASTAL ZONE MANAGMENT? WHY OR
    WHY  _   NOT

                                                       Number of People

        Yes                                                          40
        No                                                            2

    Reasons

    -    Relevant to work requirements.

    -    To monitor inclusion of recreation concerns in both New Jersey and federal
        CZM strategies.

    -    It is important to preserve vital natural resources.I

    - Continued  interest.

    -    To keep up to date on coastal zone policies and the progress of the Strategy.

    ARE YOU REPRESENTING AN AGENCY AT THIS MEETING?

        No                                                           20
        Elected official I
        Federal                                                        7I
        State                                                         4
        County                                                        4
        Municipal                                                     4I
        Private Group                                                10

                                          APPENDIX II

           I                           ~~~~~~~~LIST OF COMMENTERS

    I       ~~This list of people who commented on the Coastal Management Strategy indicates
        each person's professional affiliation or place of residence, if known.  The names
     *  of people who signed in at public meetings are included, except for those that were
     *  too difficult to read, regardless of whether they actually spoke at the meeting.
     -  Several speakers, who stressed that they were appearing as private citizens, rather
        than as representatives of organizations with which they were associated, are
     *  listed only by their home address.

     I  REGIONAL AGENCIES                               Michael Wolfe
                                                         Delaware Valley Regional Planning
        Lynn Alan Brooks, Chairman                          Commission
          Tri-State Planning Commission                   3rd Floor - Penn Tower Building
          One World Trade Center, 82 Floor                1801 John F. Kennedy Boulevard
          New York, New York   10048                      Philadelphia, Pennsylvania   19103

     I  Robert V. Everest                               Steven R. Woodbury
          Delaware River Basin Commission                Wilmington Metro Area Planning
          25 State Police Drive                             Coordinating Council
          West Trenton                                    2162 New Castle Avenue
               I                                       ~ ~~~~~~~~~~~~New Castle, Delaware   19720
        David S. Hugg, III
          Delaware State Office of Management,
    I    ~    ~Budget and Planning                     STATE AGENCIES
          Dover, Delaware   19901
                                                      Paul Arbesman, Director
        David R. Keifer                                   Department of Environmental Protection
          Mid-Atlantic Fishery Management                 Office of the Director & Bureau of
            Council                                         Air Pollution Control
    I    ~Room 2115 Federal Building                      Rm. 1108 - Labor & Industry Bldg.
          North and New Streets                           Trenton, New Jersey   08625
          Dover, Delaware   19901
                                                      Ken Bosted, Senior Planner for Green Acres
        James R. Kelly, Director                          Department of Environmental Protection
          World Trade Division                              Green Acres
          Delaware River Port Authority                   1301 Parkside Avenue
    I   ~Bridge Plaza                                     Trenton, New Jersey   08625
          Camden, New Jersey   08101
                                                      Jed Callen
        Edward S. Olcott, Director of Planning            Department of Environmental Protection
          and Development                                   Division of Water Resources
          Port Authority of New York & New Jersey         Office of Regulatory Affairs
          One World Trade Center, 72S                     1474 Prospect Street
          New York, New York   10048                      Trenton, New Jersey   08625
        Sheldon Pollack, Information Director          Russell A. Cookingham, Director
          Regional Plan Association                       Department of Environmental Protection
    3     ~235 East 45th Street                             Division of Fish, Game & Shellfisheries
            NwYork, New York   10017                      363 Pennington Avenue
                                                        Trenton, New Jersey   08625

    Ray Dyba
     Department of Environmental Protection      William Shoemaker
                  Burea of ir Pllutin CotrolDepartment of Environmental Protection             *
      Bre.10 aubofAr Polto  Condutryol       d       g Division of Fish, Game & Shellfisheries
      Ten.t110, Newbor&Idstry 08625                 363 Pennington Avenue
                ~~~~~~~~~~~~Trenton, New Jersey   08625TrnoNwJse        082

    Charles Formnan, Staff, Deputy Commissioner
     Department of Environmental Protection      Chris Smith
                Labor &    Industry    Bldg. Department of Agriculture
     Trenon, Ne Industry 08625                       Division of Rural Resources
                Trenton, NewJersey   08625State Soil Conservation Committee

    Joseph Gates                                    John Fitch Plaza
         DeprtentofCommunity Affairs/State          Trenton, New Jersey  08625
       and Regional Planning                     Robert SoeSpriigPanro
      329 West State Street           GroesSuervsng PAcrerso
                Trenton, NewJersey 08625Department of Environmental Protection

    Thomas Hampton, Supervisor                        Green Acres
     Department of Environmental Protection  1301on Naiew Avenuey   82
       Office of Wetlands ManagementTrnoNwJse082
      Labor & Industry Bldg., Room 711            Barry Sullivan
      Trenton, New Jersey   08625                   Department of Community Affairs/State

    James Johnson, Supervisor                          and Regional Planning
     Department of Environmental Protection        329 West State Street
       Office of Riparian Lands Management         Trenton, New Jersey   08625
      Labor & Industry Bldg., Room 711JefyZeisnAcngDrto
      Trenton, New Jersey   08625                   Department of Environmental Protection

    Bernard Moore, Supervisor                         Division of Water Resourcesm
      Department of Environmental Protection        1474 Prospect Street
       office of Shore Protection                  Trenton, New Jersey   08625
      Labor & Industry Bldg., Room 711
      Trenton, New Jersey   08625                 COUNTY AND MUNICIPAL AGENCIES

    Ralph Pasceri                                 Chester W. Ambler, III, PlanningI
      Department of Environmental Protection        Director
       Bureau of Air Pollution Control             SalemConyPaigBar
      Rin. 1108, Labor & Industry Bldg.                   Courtyhlnnn   ous e
      Trenton, New Jersey   08625   Salerthouesey 87

    William Potter                                Eugene Amron, Consulting Engineer1
      office of the Public Advocate                 West Long Branch
      520 East State Street 2 omnt rv

                 Trenton, NewJersey 08625West Long Branch, New Jersey  07764
    Samuel Race Mri .Bubr
      Department of Agriculture          Atantic ont Plnnn Boabrd
       Division of Rural Resources         70Gatlantee Trusty BuldningBor
      State Soil Conservation Committee             70GAtlantiCtyNeweTrusey Buildin
      John Fitch PlazaAtatcCtNwJre 081
      Trenton, New Jersey   08625                                                               I

      -  Burlington County OCS Study Team               John Ober, Economic Development Director
     *    ~Office of Burlington County Planning           City of Camden
     *      ~~Board CmeNwJre
           Burlington County Board of C~hosen             CmeNwJre
             Freeholders              Du                      plk
                      Mt. Holly New Jerey 08060Middlesex County Planning Board

         Louis Carnevale, Project Coordinator             40 Livingston Avenue
           Hudson County'Office of Planning               New Brunswick, New Jersey  08903
           County Administration Bldg.                 Andrew C. Paszkowski, Planning Director
    *      ~~595 Newark Avenue                            Ocean County Planning Board
           Jersey City, New Jersey   07306                1 Madison Avenue

         Ms. Jeanne Clunn, Vice-Chairperson               Toms River, New Jersey   08753
           Cape May County Environmental Council       John Runyon, Chairman
           Mechanic Street                                Lower Raritan/Middlesex County
           Cape May Court House, N.J.  08210                Advisory Committee

         Dennis J. Enright, Director of Planning   20Pae ulit anaigeProgra
           Office of the Mayor                            Midee   onyPlanning Progard
    I     ~City HallMideeConyPaigBar
           Jersey City, New Jersey   07302                40 Livingston Avenue
                                                        New Brunswick, New Jersey 08901
         Chuck Fisher, Director                         Clay C. Sutton, Jr., Environmental
           Cumberland County Board of Chosen              Planner
             Freeholders                                 Cape May County Board of Health
           Bridgeton, New Jersey   08302                  Crest Haven Complex on Parkway

        Alvin Griffith, Secretary                        Cape May Court House, N.J.  08210
          Lawrence Township Planning Board             Chris Warren, Assistant Director
           Cedarville, New Jersey   08311                Salem County Planning Board

        Carl Hinz, Planner         S    a     l e , rthouesey 87
          East Brunswick TownshipSaeNwJry087

                    Robet Huuley  E nironenta PlanerCharles D. Worthington, Executive
     RMonoueth CougeEniomntal Plannineor          d    Atlantic County Executive offices
          MOneot  Lafaytty PlannngBor                    741 Guarantee Trust Building

                I  Freehold, New Jersey   07728Atlantic City, New Jersey   08401

     I  Elmwood Jarmer, DirectorINUTILADDVOPETRGIZIN
          Cape May County Planning BoardINSTILADEVOPNTRGIZTN
           Cape May Court House, N.J.   08210          William J. Abbott, Executive Director

     I  Middlesex County Planning Board                  New Jersey Asphalt Pavement Association
          New Brunswick, New Jersey  08903               629 Amboy Avenue
                                                       Edison, New Jersey 08817
     *  David W. Morris, Jr., Assistant
    I    ~Environmental Planner                        Vincent Bellviso
      -Monmouth County Environmental Council             New Jersey Builders Association
           I Lafayette Place                              P.O. Box M
          Freehold, New Jersey   07728                   Ramada Inn, Route #18

                                                       East Brunswick, New Jersey   08816

    Robert A. Briant, Executive Director           John F. McDonald, Senior Vice President-
      Utility Contractors Association of             Govermental Affairs
        New Jersey, Incorporated                     Public Service Electric & Gas Co.
      146 Route #1                                   80 Park Place
      Edison, New Jersey   08817                     Newark, New Jersey  07101

    John Graham                                   William R. Parsons
      Jersey Central Power & Light Company           Dredge Harbor Yacht Basin
     Madison Avenue at Punch Bowl Road              P.O. Box 158, St. Michiel Drive
      Morristown, New Jersey   07960                 Riverside, New Jersy   08075

    Arthur M. Cox, Jr., Secretary                  Plainsboro Chamber of Commerce
      New Jersey State Chamber of Commerce
      5 Commerce Street                           L. A. Pollitt, Superintendent
      Newark, New Jersey   07102                    Asarco Incorporated
                                                    Route 70
    Donald F. X. Finn, Managing Director             Mile Marker No. 41
      Geothermal Energy Institute                    Lakehurst, New Jersey   08733
      P.O. Box 392
      Highlands, New Jersey   07732               Kenneth E. Pyle, President SEED
                                                    Society for Environmental and Economic
    John J. Flannery                                   Development
      Association of General Contractors             Suite 1519, Inn of Trenton
                                                    240 West State Street
    Morton Goldfein, Vice President                  Trenton, New Jersey   08608
      Hartz Mountain Industries, Inc.
      11 Harmon Plaza, P.O. Box 1411              Michael Redpath, Executive Director
      Secaucus, New Jersey   07094                  Marine Trades Association of New Jersey
                                                    P.O. Box 70
    A. Carl Helwig, President                        Island Heights, New Jersey   08732
      Pureland Industrial Complex
      603 Heron Drive                             Leonard H. Ruppert, Executive Director
      Bridgeport, New Jersey   08014                New Jersey Petroleum Council
                                                    A Division of American Petroleum
    Michael J. Gross, Esquire, Legal Repre-            Institute
      sentative for New Jersey Builders             170 West State Street
      Association                                    Trenton, New Jersey   08608
      c/o Giordano, Halleran, & Crahay
          P.O. Box 667                            James A. Shissias, General Manager,
          1005 Hooper Avenue                        Environmental Affairs
          Toms River, N.J.    08753                 Public Service Electric & Gas Co.
                                                    80 Park Place
    William Kaier                                    Newark, New Jersey   07101
      Manchester Manufacturers Association
      Route #7 - Box #120                         Thomas E. Tipton, Manager, Environmental
      Lakehurst, New Jersey   08733                 Affairs
                                                    Jersey Central Power & Light Co.
    Donald Kennedy                                  Madison Avenue at Punch Bowl Road
      Mercer County Building & Construction         Morristown, New Jersey  07960
        Trades

    John Maddocks
      Public Service Electric & Gas Co.
      80 Park Place - Room 8317
      Newark, New Jersey   07101

         ENVIRONMENTAL GROUPS                           Elizabeth Mullin
                                                          Natural Resources Defense Council, Inc.
         Candace Ashmun, Executive Director               Atlantic Coast Project
           Association of New Jersey Environmental        917 Fifteenth Street, N.W.
             Commissions                                  Washington, D.C.   20005
     I    ~300 Mendham Road
           Route 24, Box 157                            Daniel O'Connor
           Mendham, New Jersey   07945                    Save Our River Environment
               1                                        ~ ~~~~~~~~~~~~R.D. Box 114
         Francis Beinecke                                 Port Norris, New Jersey   08349
    *      ~Natural Resources Defense Council, Inc.
           Atlantic Coast Project                       Martha L. Pokras,' President
           917 Fifteenth Street, N.W.                     Atlantic Audubon Society
           Washington, D.C.   20005                       Absecon, New Jersey   08201

      I  Dery W. Bennett, Executive Director            Nancy Richardson
           American Littoral Society                      Bayonne Against Tanks
           Sandy Hook                                     92 West 42nd Street
           Highlands, New Jersey   07732                  Bayonne, New Jersey   07002
         Darryl F. Caputo, Assistant Director           Kay Rippere
           New Jersey Conservation Foundation             League of Women Voters, N.J.
           300 Mendhanm Road                              460 Bloomfield Avenue
    I    ~.Morristown, New Jersey   07960                 Montclair, New Jersey   07042

         Ernest Choate                                  Dana Rowan, New Jersey Coordinator
           Cape May County Environmental Council          American Littoral Society
           Library Building                               Sandy Hook
    I    ~Central Mail Room                               Highlands, New Jersey   07732
           Cape May Court House, N.J.   08210
                                                       Helen Sciarra, CAPE
         Ruth Fisher, CAPE                                Citizen's Association to Protect the
           Citizen's Association to Protect the             Environment
             Environment                                  South Dennis, New Jersey   08245
           South Dennis, New Jersey   08245
                                                       A. Jerome Walnut, President
         Diane Graves                                     Conservation Society of Long Beach
           Sierra Club                                      Island
    U    ~New Jersey Chapter                              P.O. Box 245
           360 Nassau Street                              Barnegat Light, New Jersey  08006
           Princeton, New Jersey   08540
                I                                     ~ ~~~~~~~~~~~John Wilson, Project Director
         Peter Lafen                                      Association of New Jersey Environmental
           League for Conservation Legislation              Commissions
           32 Lafayette Street                            300 Mendham Road, Route 24
           Trenton, New Jersey   08625                    Box 157
                                                          Mendham, New Jersey   07945
         Vivian Li
    'I   ~League for Conservation Legislation
           Air Quality Office                           FEDERAL AGENCIES
           31 Green Street
    'I   ~Newark, New Jersey   07102                    Thomas Appleby, Regional Administrator
                                                          Department of Housing & Urban Development
                                                          Regional Office
                                                          26 Federal Plaza
                                                          New York, New York   10007

    Lewis H. Blakey, Deputy Director for           Jeff Swinebroad, Manager
      Technology and Engineering                     United States Department of Energy
     Department of Defense                           Environmental Program
       Department of the Army                       Division of Biomedical and Environ-
     office of the Chief of Engineers                 mental ResearchI
     Washington, D.C.   20314                       Washington, D.C.   20545

    Norman Chupp, Area Manager                     Robert L. Wong, Chief, Environmental
     United States Department of Interior            Planning Division
       Fish and Wildlife Service                    Department of Defense
      1500 North Second Street                         Department of the Air Force
      Harrisburg, Pennsylvania   17102               Regional Civil Engineer, Eastern Region
                                                   526 Title Building, 30 Pryor Street, S.W.
    R. M. Engle, CDR, CEO, USN, Deputy                Atlanta, Georgia   30303
      District Civil EngineerI
      Department of Defense
      Department of the Navy                       OTHER GROUPS
      Commandant, Fourth Naval District
      Philadelphia, Pennsylvania   19112           Charles Goodman, President
                                                  Joint Council of Taxpayers
    Warren Fitzgerald, State Conservationist          32 Holly Drive
      United States Department of Agriculture        Loveladies, New Jersey   08008I
        Soil Conservation Service
      1370 Hamilton Street                         Robert Lattore, Secretary
      P.O. Box 219                                   Ocean County Tourism Advisory Council        I
      Somerset, New Jersey   08873                    Seaside Heights, New Jersey
    Ronald Gatton                                  George ScarleI
      Department of Commerce                         Tower Marina
        National Marine Fisheries Service            Marine Trades Association
      Environmental Assessment Division              Chapter 3
      Oxford, Maryland   21654                       Middlesex County 208 PAC
    Norman H. Huff, Senior Staff Officer           Walter P. Stepier, Jr.
      Department of Transportation                   Lawler, Matusky & Shelly EngineeringI
      Regional Representative of the Secretary       Pearl River, New York
      26 Federal Plaza - Room 1811
      New York, New York   100073
                                                 OTHER INTERESTED CITIZENS
    William Kebblish, Liaison Officer
      United States Department of the Interior   William Beren
        Bureau of Mines                              904 Hudson StreetI
      P.O. Box 783, Federal Building                 Hoboken, New Jersey   07030
      Harrisburg, Pennsylvania   17108
                                                 Jon Berger, Assistant ProfessorI
    Robert Schoen, Coordinator                        The Graduate School of Fine Arts CJ
      U.S. Department of the Interior                Department of Landscape Architecture
      RALI Program, LIA                                 and Regional Planning
      United States Geological Survey                University of Pennsylvania
      Mail Stop 750                                   Philadelphia, Pennsylvania   19174
      Reston, Virginia   22092TerBo                                           w              I-

                                                   New Jersey Shore Audubon Society
                                                   Home: 512 Riverwood Park

                                                          Point Pleasant Beach, N.J.

      Henry Callaghan
        First Jersey National Bank

      Al Coleman
        Pennsville, New Jersey
                                                     Richard Lavin
      Eleanor Coleman                                    3307 Pacific Avenue
        Pennsville, New Jersey                          Atlantic City, New Jersey

      Allen Davidow                                   Susan Lyons, Teacher
        Camassa Agency                                  60 Spruce Court
        310 Ocean Avenue                                Bricktown, New Jersey   08713
        Long Branch, New Jersey
                                                     Thomas Milton
      Lawrence Elrod
        Mannington, New Jersey                        Carole Nemore
                                                        2017 East Genesee Street
      Joseph Forsyth                                     Townhouse F
        * Wetlands Owner                                 Syracuse, New York   13210

      Stephen Gabriel                                 Michael Pisani
        850 St. Charles Place                           1120 M orris  Avenue
        Ocean City, New Jersey   08226                  12   orsAeu
                    Ocean City, New Jersey   08226      Point Pleasant, New Jersey   08742

      Nancy Gahn                                      Arthur Ponzio
        Monmouth County                                 Atlantic City

    I Bruce Hoff
      Bruce Hoff                                      Aron Salzburg
        Center for Coastal and Environmental
          Studies
                     Studies                         ~~~~~~J. W. Speer, Sr.
        Doolittle Building, Busch Campus              J. W. Speer, Sr.
        Rutgers University                              Pandullo Quirk Associates
        Rutgers University8HadAeu
        New Brunswick, New Jersey  08903                8 Hand Avenue
                                                       Cape May Court House, N.J.  08210
      Robert Houseal, Architect                       Leo Sterenberg
        2175 Terrace Place                              Cape May County
        Sea Girt, New Jersey   08736ape May County

                  U   ~~Charles Irwin  ~Robert Wiegands
      Charles Irwin

      * Jean W. Jones                                 Martha Wilder
        Greenwich, New Jersey                           Ocean City, New Jersey

      Joann Katzban
        940 Hudson Street
        Hoboken, New Jersey   07030

      Katherine Duffy Kievitt
        Ocean and 22nd Avenues
        South Seaside Park, New Jersey 08752

      Ira S. Kupperstein
        Kupperstein Consultants
        Department of Civil Engineering
        N.J. Institute of Technology
        323 High Street
        Newark, New Jersey   07102