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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