REALsmart, the league for real smart growth
68 S. Main Street
Phillipsburg, New Jersey 08865

September 21, 2007

Commissioner Lisa Jackson
NJDEP
Trenton, New Jersey

Re: Functional Value Analysis for C-1 buffer reductions

Dear Commissioner:

Your Administrative Order No. 2007-01 of January, 2, 2007 certainly hit the mark by raising the bar on buffer
reductions. It did not, however, address buffer reductions granted before January 2.

Case in point, is a buffer reduction granted in Holland Twsp, Hunterdon County without benefit of the Functional
Value Analysis required by NJDEP rules.

That buffer reduction is coming under review again as a result of an application to expand sewer service. Therefore an
opportunity has been provided to get the information of creek impacts provided by a Functional Value Analysis by
requiring the applicant to comply with Administrative Order No. 2007-01. Specifics of the case are outlined in the
comment posted below.

Mike King, Coordinator