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Extending beaches seaward by adding sand through replenishment projects has become a common strategy for slowing the effects of erosion. As tons of sand are brought to the beaches, new land literally rises out of the water. Courts and state legislatures have invoked the public trust doctrine to vest title to this new land with the people, but questions remain as to how much public access must be provided to replenished beaches. New Jersey, North Carolina, and Florida are examined as three different approaches to applying the public trust doctrine and pro-viding public access to replenished beaches.