Public comment on:

LURP File No.: 1325-06-0011.1 (CAF 060001)-CAFRA Permit

The Peters Family and Takanassee Developers (Long Branch, NJ)

Submitted February 14, 2008 by:

Captain David Sutton, United States Merchant Marine

8 Knollwood Road, Hackettstown, NJ 07840

I have been following the above matter with interest, and wish to draw your attention to a matter of which you may not be aware. The area directly offshore of the proposed development, beginning only yards from the shoreline, is the site of the only natural-rock reef structure in the near-shore waters of New Jersey.

This reef structure hosts an extremely diverse biomass that is unduplicated along the New Jersey shoreline. Innumerable fish and invertebrates inhabit this reef structure, and it is a unique micro environment that has no equal along what is essentially a flat featureless natural-sand submarine desert that extends from Sandy Hook to Cape May. The reef is a geologic extension of the rock that forms the features of Atlantic Highlands, and it is the only exposed rock protruding above the seafloor along the entire NJ coastline.

Submerged rock, as you may be aware, is the catalyst that allows biomass and biodiversity to flourish under the sea. As a diver, I have witnessed the loss of much artificial rock substrate habitat in New Jersey due to beach replenishment activities that cover the only available substrate upon which the food chain of algae, seaweed, and sessile invertebrates attach, thus causing the loss of many hundreds of tons of biomass along the New jersey coast ranging from these low-order members of the food chain to the apex predators that eat at the top of the food chain, and the loss of animals at every stage between the two. While it may be argued that this was “unearned biomass”, it being lost due to the coverage by sand of man-made artificial substrate (jetties and groins), any potential loss of the natural Takanassee Reef would be loss of an irreplaceable natural habitat. In addition, the natural reef is of an entirely different texture and relief as compared to the more common artificial rock substrates formed by jetties, and it lays at a deeper water depth, thus having a different photosynthetic value, and thereby attracting different species to inhabit the area. I am absolutely certain that the proposed development of this area would inevitable lead to loss of this fragile reef which is literally at the foot of the water at the proposed development site.

I strongly urge you to require a proper formal marine study of this area prior to any approval process continuing, and an immediate denial of the current development plan while the study is underway. It is imperative that a baseline be established in this area, and that any potential future development is proposed in such a way as to permanently prevent any possibility of destruction of this unique area. Further, I urge you to consider designating this area a submerged cultural resource area, and to take steps to protect it in perpetuity for the citizens of our state as well as visitors to this area.

Respectfully,

Capt. David Sutton