Click Here to Submit Your Comments to NJDEP.
Written Comments are Due September 19th
Copy/Paste/Edit the below:
Thank you for this opportunity to provide comments. My name is ______, and I represent ________ (your business name).
New Jersey is home to 150,000 boaters, vital to its economy and identity, with recreational boating generating a $6.6 billion-dollar economic impact, supporting over 20,000 jobs, and sustaining more than 1,100 marine businesses, including the nation’s leading boat manufacturers.
Beyond its economic contributions, boating is a fulfilling and rewarding activity that enhances mental well-being, reduces stress, and fosters memorable moments with friends and loved ones. Access to open waters and water-dependent activities is vital to New Jersey’s quality of life. Yet, despite all of this, the state continues to do nothing to support the boating industry in New Jersey or understand the detrimental impacts of these proposed rules.
The many businesses that support water dependent activities are the ones that will be directly impacted by these regulatory changes. The proposal continues to be fundamentally flawed, and these amendments do nothing to protect these critical businesses.
Marinas and marine support businesses are water-dependent businesses that are not only tied to the water but exist to provide access to our waterways and important boating infrastructure and services. They provide slips, public boat ramps, fuel, fishing supplies, boat maintenance and service, boat building, manufacturing and more. Our marinas provide the most meaningful public access by the nature of their businesses.
Environmentally, marinas play a key role in coastal ecosystems when managed sustainably. These facilities are highly regulated and are required to not only ensure 100% compliance with all environmental rules and regulations but implement many best management practices that go above and beyond to protect our waterways, marine life and habitats. Preserving marinas ensures these standards are upheld, preventing degradation from neglect or development pressures. The effects of this proposed rule will prohibit upkeep, maintenance of aging infrastructure and expansion of these facilities which will lead to their eventual demise and conversion of these valuable resources to private development.
The Department HAS recognized, as written in the original proposal, the importance of marinas yet has not taken any action to protect them. In fact, removing the IRZ from the list of special coastal areas does nothing to address the restrictions for these businesses. The 3% impervious cover limit will continue to be applied to projects in environmentally sensitive planning areas, such as on barrier islands. Marinas on the barrier islands, for example, will not be able to conduct any site development that triggers a CAFRA Individual Permit.
Additionally, the reduction in the Climate Adjusted Flood Elevation from 5 feet to 4 feet does not adequately address the practical challenges posed by the current FEMA tidal base flood elevation mapping. Elevating structures to this height remains infeasible for boat repair shops, manufacturing facilities, and boat showrooms. Essential equipment, such as boats on travel lifts, boat trailers, or forklifts, cannot be maneuvered into elevated structures for repairs or storage, rendering compliance with these elevation requirements impractical.
Given the enormity of the original proposal and subsequent amendments, it is nearly impossible to fully grasp the far-reaching impact this will have on the entire industry now and for many years to come. Therefore, we are strongly recommending, again, that marinas and marine service and support businesses be exempted from these requirements.
We believe the state should be actively seeking ways to support the recreational boating industry. We need to work together to provide more opportunities to protect these businesses and working waterfronts. Our industry is shrinking, and we are losing more marinas, more access to our waterways and the businesses that provide the services and supplies to the boating and fishing communities. We must find solutions to preserve our marinas and support businesses and not implement costly and burdensome regulations like these that will force more businesses to forgo improvements and deteriorate or sell to private developers when they can no longer operate. New Jersey needs more marinas and marine support businesses to provide the access, resources and infrastructure that is needed to enjoy our waterways, not less.