

They contend that AO-69 amounts to rulemaking and hence is subject to the procedural requirements of notice and hearing, whereas the Commissioner views his Order as no more than an intra-agency statement for which no such procedures are required. Annexed to the order is a "policy statement" regarding "Participation of Responsible Parties in the Development of Remedial Investigations and Feasibility Studies." Plaintiffs are "Responsible Parties" within the meaning of that policy statement. Plaintiffs, Minnesota Mining and Manufacturing Company and Rohm and Haas Company, known collectively as Woodland Private Study Group, challenge an Administrative Order, AO-69, issued by the Commissioner of the Department of Environmental Protection. The opinion of the Court was delivered by CLIFFORD, Justice. argued the cause for respondents (Pitney, Hardin, Kipp & Szuch, attorneys Mr. Gen., argued the cause for appellants (W. HUGHEY, COMMISSIONER, OF THE DEPARTMENT OF ENVIRONMENTAL PROTECTION, APPELLANTS. STATE OF NEW JERSEY, DEPARTMENT OF ENVIRONMENTAL PROTECTION, AND ROBERT E. WOODLAND PRIVATE STUDY GROUP, MINNESOTA MINING AND MANUFACTURING COMPANY, AND ROHM AND HAAS COMPANY, RESPONDENTS,
