US Army Corps of Engineers Issues BL England Plant Dredging Permit

February 27th, 2015 No comments

Corps Denies Public Hearing Request

Federal Agencies Ignore Obama Climate Adaptation Policy for Vulnerable Coastal Plant

Areas in yellow are flood risk areas based on FEMA flood hazard maps plus the most conservative estimate of sea level rise (0.3 feet by 2050). The entire BL England plant is within this flood zone.  (Source: Pinelands Preservation Alliance, link below)

BL England plant circled in red. Areas in yellow are flood risk areas based on FEMA flood hazard maps plus the most conservative estimate of sea level rise (0.3 feet by 2050). The entire BL England plant is within this flood zone. (Source: Pinelands Preservation Alliance, link below)

The US Army Corps of Engineers, in a Friday afternoon move designed to minimize news coverage, issued a final dredging permit for the controversial BL England power plant in Upper Township, NJ.

The purpose of the permit is:

R.C. Cape May Holdings, LLC proposal [is] to perform hydraulic maintenance dredging to the B.L. England Generation Plant’s intake and outfall located in Great Egg Harbor Bay at Upper Township, Cape May County, New Jersey. The applicant’s stated purpose and need for the proposed work is to ensure an adequate supply of condenser cooling water for the intake, to avoid sediment re-suspension at the outflow and to ensure an adequate mixing regime for thermal discharge. A ten year maintenance permit is being requested for the proposed activities.

We learned of this draft permit very late in the process and were able to submit only cursory general comments, which is the main reason why we asked for an extension of the public comment period (for our comments, see):

Our requests strictly followed the criteria in NJ DEP rules to justify an extension or a request for public hearing. The Corps denied that extension request.

The Corps also denied our request to hold a public hearing, but provided no rationale for either denial. I am not familiar with the Corps rules and the basis for reviewing such requests, but the Corps seems to have just blown the requests off with no basis stated.

But none of that comes as a surprise, as the Corps is not generally perceived to be enthusiastic about dealing with environmental critics in public hearings.

But, what I was surprised by – perhaps because I have little experience in dealing with the Corps permit process – was how the Corps’ decision completely ignored President Obama’s Climate Adaptation Policy, issued on Nov. 1, 2013, so it was binding on the Corps, see:

More recently, that Nov. 1, 2013 Obama Executive Order was expanded upon by a January 30, 2015 Order, see:

The new Order included a proposed new Federal Flood Risk Management Standard that would require federal agencies to select one of three approaches for establishing the flood elevation and hazard area they use in siting, design, and construction:

  • Use data and methods informed by best-available, actionable climate science;
  • Build two feet above the 100-year (1%-annual-chance) flood elevation for standard projects, and three feet above for critical buildings like hospitals and evacuation centers; or
  • Build to the 500-year (0.2%-annual-chance) flood elevation.

I wonder if the BL England intake structures, facility, and dredging plans – or the Corps permit – consider these standards?

The Pinelands Preservation Allaince prepared an analysis of the vulnerability of the BL England plant in terms of sea level rise and storm surge. Maps that show portions of the BL England site as within the flood elevations -

In our comments, we wrote:

3) the plant is located in a coastal hazard zone and is vulnerable to climate change driven sea level rise and storm surge. The issue of coastal vulnerability and all forms of energy and critical infrastructure is a hugely controversial and significant issue to the people of NJ.

Even though the new Federal Flood Risk Management Standard is not legally in effect yet, the Corps had an obligation, under the prior Obama 2013 Executive Order, to consider these kind of climate change vulnerabilities and risks.

Without discussion, the Corps dismissed them, and they spread the blame and pointed fingers at their sister federal agencies for ignoring them too:

No objections to the issuance of this permit were received from other Federal resource agencies (United States Environmental Protection Agency, United States Fish and Wildlife Service, National Marine Fisheries Service and the National Park Service) concerning the effects of the proposed work on resources within their jurisdictions.

So, the entire federal government simply ignored President Obama’s Executive Order on adaptation to climate change – an Order that they are legally bound to implement.

And they did this just at the time Obama issued another Order and proposed new Federal Flood Risk Management Standards.

This is not a minor oversight. Will they be held accountable?

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Christie Administration Cuts Sweetheart Deal With Exxon Mobil For Bayway Refinery Pollution

February 27th, 2015 No comments

$250 Million Settlement Provides Just 3 cents on the Dollar


The New York Times is reporting that the Christie Administration just reached a $250 million settlement agreement with Exxon Mobil for decades of pollution damages from the Bayway refinery, see:

The State filed the lawsuit in 2004 under the McGreevey Administration, as part of a greatly expanded “Natural Resource Damage” (NRD) program launched by DEP Commissioner Brad Campbell (see Campbell’s NRD Policy Directive). We’ve written critically about that DEP NRD program many times, e.g. see this and this and this.

[see this ABC TV investigative report on Bayway’s pattern of violations of environmental laws, where Gov. Christie denies his own Executive Order #2 on “regulatory relief”.]

There is some speculation in the NY Times story that the State’s Settlement was suspect because it was reached just before a Superior Court judge was about to issue a decision, which the Times’ sources believe would had been significantly larger than what the State settled for.

I disagree with that assessment because I’ve had limited experience with the judge, Mike Hogan, who was Whitman DEP Commissioner Bob Shinn’s legal counselor. At the time, I was a legislative analyst at DEP. Hogan and I had a dispute over a bill to extend the life of the Cape May landfill, in violation of a federally approved Settlement that required closure. I noted the conflict with federal law, and Hogan threw me out of his office in disgust, nearly shouting that the federal government could not limit a State legislature.

The Whitman DEP was strongly anti-regulatory and pro-business.

My take on Hogan was that he was legally conservative, out of the Federalist Society mold, and not likely to be the kind of judge to stretch the law to hold a major corporation accountable.

The State’s lawsuit sought $8.9 BILLION in restoration and compensation for toxic pollution of over 1,500 acres of soil, wetlands, fish & wildlife, and marshlands:

“Today, many of these dredge fill areas still look and smell like petroleum waste dumps,” the report continues. “Spilled materials from pipeline ruptures, tank failures or overflows, and explosions have resulted in widespread groundwater, soil and sediment contamination.”

The attorney general’s office said in its brief in November that the sites had been “adversely affected by or buried under the discharge of hazardous substances,” including over 600 identified chemicals.

Although the NRD settlement money is supposed to go to ecological restoration and public compensation for lost use of the natural resources, the Christie Administration is likely to divert the settlement proceeds into the General Fund to pay for Christie’s multi-billion tax cuts for corporations. That’s what they recently did in diverting $140 million of a recent $190 million settlement on the Passaic River dioxin contamination.

As we’ve written previously, remarkably, although State environmental groups have blasted that $140 million Passaic River settlement diversion, NJ’s “Keep It Green Coalition” opposed Constitutionally dedicating these NRD settlement funds to the Open Space Fund.

So the Bayway settlement, even though for just 3 cents on the dollar, shines a bright like on the bad judgement and HUGE KIG missed opportunity - one of the biggest blunders of all time.

This is a breaking story. My purpose here was merely to put the deal in some NJ context.

We will be providing additional thoughts on this matter as the Settlement documents are made public.

There will also be an opportunity for public comment.

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Divide and Conquer – Heckofajob KIG! (Part II)

February 26th, 2015 No comments

Open Space, Farmland & Historic Preservation, State Parks, & Urban Advocates at Each Other’s Throats

Competition and Conflict Replace Mutual Support and Cooperation

Divide and Conquer: In politics and sociologydivide and rule (or divide and conquer) (derived from Greek: διαίρει καὶ βασίλευε, diaírei kaì basíleue) is gaining and maintaining power by breaking up larger concentrations of power into pieces that individually have less power than the one implementing the strategy. The concept refers to a strategy that breaks up existing power structures and prevents smaller power groups from linking up.  ~~~ Wiki

Shooting the messenger” or “killing the messenger” is a metaphoric phrase used to describe the act of lashing out at the (blameless) bearer of bad news. ~~~ Wiki

Tom Johnson at NJ Spotlight reports today on the latest development in the open space funding clusterfuck, the release of Governor Christie’s budget message:

… The budget proposal also allocates $32.7 million to programs previously funded by corporate business taxes — cleanup of toxic sites and underground storage tanks, as well as an assortment of water-related programs. The administration’s figure is down from $103 million in the current budget, which led some to oppose the ballot question.

As we expected, there were deep cuts in water resources, site remediation, and land-use regulations,’’ said Bill Wolfe, director of the New Jersey Public Employees for Environmental Responsibility. Wolfe was one of the biggest critics of the ballot question for precisely those reasons.

Given that we made the prediction, I need to update my own most recent engagement in this snake pit:

Think about it:

What better way to divide a community than to engage a $1 million PR campaign to mislead people, inflate expectations of future funding, prohibit discussion of any negative consequences, and then dramatically slash historic resource levels and force each member group to compete with each other for very scarce resources?

Is there a more destructive dynamic possible?

It didn’t used to be this way: planning and regulation complemented open space acquisition. But how Smith and KIG have chosen to finance open space has forced competition and conflict, creating collateral damage instead of mutual support. ~~~ “Open Space Funding: Holy Grail – or White Whale?

A Koch Brothers strategist could not have done a better job.

[Actually, there are other Neoliberal features of KIG’s initiative, see: “Stewardship” Becomes The Charter School of the Environmental Movement]

Well, that’s exactly what the Keep It Green Open Space campaign has done – and the disappointment, irreversible bad blood, and damage now underway from that campaign was predicted.

Before the ballot measure was voted on, virtually the only public interest group in NJ, we opposed it. On October 6, 2014, we warned voters:

Trenton — A November ballot measure would amend the New Jersey constitution to siphon $10 billion out of park facilities maintenance as well as toxic site cleanup and state water infrastructure over the next 30 years solely to finance real estate purchases for open space. Billed as a “green” proposition, it would devastate bread and butter environmental programs while lining the pockets of some key proponents, according to Public Employees for Environmental Responsibility (PEER).

“This is utterly irresponsible eco-policy cynically masquerading as an investment in our future,” stated New Jersey PEER Director Bill Wolfe, pointing out that it will likely trigger layoffs of state Department of Environmental Protection staff working in both waste and water programs. “Green Acres and open space preservation are good ideas but not to the exclusion of everything else.”

Well, here we are now, after the tremendous  (Pyrrhic – or “White Whale“) “victory” on a dedicated source of open space funding  - listen to the angry voices now:

  • “The imminent disappearance of the NJ Historic Trust and its funding for historic preservation capital projects is not what I voted for in November, and I don’t think it’s what you thought you voted for either.” ~~~ Cate Litvak, President, Advocate for New Jersey History

I could provide many more such angry quotes from people who are shocked by the cuts to various programs that were traditionally funded at much higher levels from open space funds.

And people still have yet to figure out what the devastating impacts will be to core DEP programs, who have suffered over $80 million in cuts to CBT funded programs – a topic I will write  about as FY’16 budget details emerge.

Unfortunately, a lot of angry people are mis-focused and blaming the wrong people.

They are all saying “I didn’t vote for these cuts in the November ballot” and are attacking the implementation legislation.

But they DID vote for these cuts.

They were duped, misled, and/or lied to by the Keep It Green Coalition.

Those, like myself and others, who tried to bring the facts to public light were shouted down, attacked, and or marginalized and ignored.

The KIG Coalition should be the target of people’s wrath.

All these cuts and the bad blood they have created was predicted. We predicted it. We tried to stop it.

We were ignored. We were called “enemies”. We won’t forget.

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EPA Admits Failure To Enforce Financial Requirements For Hazardous Waste Cleanup At Dupont Site for 23 Years

February 25th, 2015 No comments

Congress Established Financial Assurance Requirements in 1984 RCRA “HSWA” Amendments

EPA Issued Dupont a RCRA Permit in 1992 to implement the HSWA Amendments

Chemours Spinoff Reveals That EPA Failed To Enforce Those HSWA Permit Requirements

As we previously noted, the Dupont Corporation’s proposed spinoff of the Chemours company, including plans to shift liability for hundreds of millions of dollars in toxic site cleanup costs from Dupont to the new Chemours group, has prompted EPA national review, see:

Based on these concerns, on January 21, 2015, Pompton Lakes residents wrote EPA Region 2 Administrator Judy Enck a letter requesting EPA review of the Chemours spinoff and for concrete assurances that Dupont would continue to be held responsible for cleanup, including complying with RCRA requirements to demonstrate financial assurance to pay for cleanup and at least 30 years of post cleanup site monitoring and maintenance.

In an astonishing February 6, 2015 reply, Walter Mudgan, the head of EPA Region 2′s Superfund and RCRA cleanup programs admitted that EPA had not enforced RCRA “financial assurance” requirements for the full costs of cleanup for 23 years since those requirements were included in a 1992 EPA RCRA Corrective Action Permit.

Mugdan wrote:

The first question in your January 21 email concerns the dollar amount of financial assurance for the site.  There is not a specific dollar amount of financial assurance for corrective action at the site under the federal permit at this time, since the permittee is not as yet required to provide such assurance.  However, the Chemours Form 10 filing with the federal Securities and Exchange Commission (referenced in your January 21 email) contains an estimate of $116 million for remediation activities at the site, of which $60 million is estimated to be spent on remediation activities at the site in the next two to three years, including the dredging and other remediation activities contained in the proposed Acid Brook Delta permit modification.

Regarding questions 2-4 in your email, first, please note that the DuPont Pompton Lakes RCRA permit provides that financial assurance must be demonstrated to EPA for “approved” corrective measures.  The proposed RCRA Acid Brook Delta permit modification contains corrective measures, including dredging within Pompton Lake and remediation of adjacent Upland Soils Areas, which will become “approved” measures when the permit modification becomes effective in final form.  Within thirty days thereafter, the permittee is required to demonstrate to EPA in writing that it has financial assurance for the approved corrective measures.  The permittee’s submission should contain a cost estimate for the required work, including post remediation care requirements, and identify the method the company selects to provide the assurance.  Since the permittee’s financial assurance submission for the corrective action has not yet been made, EPA cannot at this time evaluate the nature and content of the assurance.  

[Would a mortgage bank not enforce homeowner's insurance requirements for 23 years? Could you get your car registered for 23 years without insurance? Ever try Mugdan's argument on a cop that asked for driver's license, registration & insurance? How many small contractors get let off the hook for posting performance bonds?

How much money did Dupont save by avoiding demonstrating $116 million financial assurance for 23 years? The financial assurance instruments may vary, but they all cost something. Plus, if EPA had Dupont's cash in hand for a complete cleanup, wouldn't that provide significant additional leverage to get Dupont to move a little quicker, under threat that EPA would just take their money and do the cleanup themselves?]

Mugdan’s bureaucratic obfuscation, about what the lawyers euphemistically call the timing and applicability of regulatory requirements, ignores the facts that Dupont has been conducting cleanup under the 1992 permit for 20 years, and that financial assurance requirements were established by EPA in the 1992 RCRA Corrective Action HSWA permit.

Mudgan’s shocking admission about failure to enforce basic requirements prompted outrage among Pompton Lakes residents,  who for many years have complained that DEP and EPA have not strictly enforced cleanup laws on Dupont.

On February 12, 2015, residents wrote another letter, this time to EPA Administrator McCarthy in Washington – with copies to NJ Senators Menendez and Booker.

The letter goes into great detail to rebut Mugdan, citing language from: 1) RCRA Corrective Action financial assurance regulatory requirements; 2) the specific financial assurance conditions of Dupont’s 1992 EPA permit; 3) EPA financial assurance guidance; 4) the EPA National RCRA Corrective Action Enforcement Strategy, and 5) EPA’s 2010 Dupont RCRA permit modification.

Residents are demanding that EPA take immediately enforcement action:

Given USEPA’s historic failure to enforce corrective action financial assurance requirements under RCRA/HSWA and EPA regulations; the enforcement options articulated in USEPA Guidance; USEPA’s reservation of discretion in the DuPont RCRA permit to “modify the enclosed Compliance Schedule should additional information become available that may impact DuPont’s ability to meet a specific scheduling Due Date or Due Dates”; and the new information legal and financial risks posed by the DuPont announced spinoff of Chemours, we respectfully demand that EPA must immediately issue an Enforcement Order to mandate demonstration of financial assurance for all corrective action, closure, and post closure monitoring.

We were shocked by Mudgan’s reply and learning that EPA had failed to enforce these basic permit requirements for 23 years.

EPA will now need to move quickly to assure that EPA has liquid assets that can be secured for site cleanup in the event that the Chemours spinoff company is recalcitrant or financially insolvent or unwilling or unable to finish the massive and costly cleanup at the Dupont Pompton Lakes site.

Based on Dupont’s SEC 10K filing documents, EPA estimated that will cost at least $116 million – and very likely much more because we do not have the cost breakdown of how that cleanup cost estimate waste derived.

Liquid assets must be obtained by EPA before July 1, 2015, which EPA claimed was the effective date of the Chemours spinoff deal.

We understand that EPA is preparing a written response – we’ll keep you posted when we receive that.

[* full disclosure: I drafted the EPA letters.]

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Sweeney and Christie-Crats Throw Pinelands Legacy Under the Bus

February 24th, 2015 No comments

Sweeney Dems Support Christie Abuse of Power – Pipeline Retaliation Scheme

Senator Gill Invokes Christie’s Failure to Reappoint Supreme Court Justice Wallace

all of a sudden, we are expendable, no matter what our qualifications” 

Commissioner Jackson (center, speaking) showed leadership and integrity. For that, Gov. Christie is seeking his replacement.

Commissioner Jackson (center, speaking) showed leadership and integrity. For that, Gov. Christie is seeking his replacement.

[2/26/15 – today’s Asbury Park Press editorial is even more critical than I am, superb, read the whole thing:

I put a photo of former Gov. Brendan Byrne at the top of my post yesterday - and one of former Gov. Florio at the bottom – for a reason: to signal that Gov. Christie’s nomination of Bob Barr for the Pinelands Commission was a test of whether the Democrats  would honor that 40 year legacy or go along with Governor Christie’s retaliatory scheme.

Today, we feature a photo of Pinelands Commissioner Jackson - first posted on Jan. 11, 2014 -  a thoughtful, independent, and principled man of courage and integrity.

I’m sad to say that the Christie-crat faction of the Democratic Senate- led by Senate President Sweeney who attended the hearing and was working the room pressuring Senators for support – were a total cowardly disgrace to that legacy.

Senator Gill

Senator Nia Gill

I was thrilled by – and applauded – Senator Gill’s principled opposition and her strong words, which invoked Gov. Christie’s outrageous disrespectful insult in not re-appointing Supreme Court Justice Wallace:

This is not about Mr. Barr.  But, if you want to make it about Mr. Barr and his qualifications, … it is clear that he is not qualified.

The larger issue here, is that we are doing here today what Gov. Christie did to Justice Wallace.

We are saying that Mr. Jackson is qualified, but Mr. Jackson is independent.

When he [Gov. Christie] did it to Justice Wallace, we stood together – He is removing the only African American to ever sit on the Commission.

And thereby removing any diversity or other voice to come to the table.

If we were principled enough to stand with Justice Wallace, then we should be principled enough today to stand and not let this go forward.

This is about power. This is about saying that if you disagree with Gov. Christie, you will be removed. [...]

As a party of diversity, we will not vote to replace a person who represents not only diversity, but, like Justice Wallace, represents excellence, represents that ability to make an independent judgement.

That’s what Mr. Jackson does , and for that, you are asking us to cast this vote to ensure his removal.

We would not have cast a vote for the removal of Justice Wallace and we should not cast a vote here today in support of Mr. Barr and against all the principles that we stand for. Thank you. (huge sustained applause)

I was pleased by Senator Weinberg’s refusal to go along with what she called Gov. Christie’s attempt to tell Commissioner Jackson to “sit down and shut up”:

We are sending a message today that if you stand up and do something that this Governor doesn’t approve of, you are replaced or told to sit down and shut up.

Vote was 7-4 – Republicans mindlessly supported the Gov., with the exception of Republican Senator Bateman, who emphasized that he took his advise and consent role very seriously and felt that the Pinelands Commission was set up as an independent Commission. Bateman said:

I view this as stacking the deck when you don’t get the result you want.  … I feel that there is a heavy hand being played here…. I just feel that this is wrong. We’re crossing the line and doing a disservice to the integrity of the Pinelands Commission.

Chairman Scutari voted no, as did Democrats Gill, Weinberg (I could not hear how Stack voted).

I was disappointed by Environment Committee Chairman Smith’s abstention – not exactly a profile in courage.

Same thing for Senator Lesniak [***see update below], who was conveniently out of town and ducked a controversial vote that was mis-framed as IBEW union jobs versus special interest environmentalists. Lesniak’s absence allowed Senator Van Drew – champion of both the pipeline and Mr. Barr – to sit in and be the swing vote in favor of Barr.

Games like this should be seen as a disqualification for any Gubernatorial ambitions – by Sweeney and Lesniak.

Read the dirty politics and blow by blow in the Politicker NJ story.

The only good that could come out of today’s disgrace would be a split in the Democratic party, with progressive Democrats using this as a pivot point to take control of the party and reject the Christie-Crat intimidation and crony politics of Sweeney.

Foremr NJ Suprem Court Wallace - not re-appointed by Christie, but now hard at work as Chairman of the Joint Legislative Committee on Ethical Standards

Former NJ Supreme Court Justice Wallace – not re-appointed by Christie, but now hard at work as Chairman of the Joint Legislative Committee on Ethical Standards

Again, Senator Gill laid that eloquently and righteously right out on the line – what do Democrats stand for and who do they stand by?:

This is a very serious vote and I think it says a great deal about where we are as a party and what we stand for going forward.

It also says that there are some issues, where certain people – no matter what, no matter what qualifications they bring to the table – are expendable for larger political reasons – until they come back to your community and ask for your vote.

And that is what this also says to me.

We can either be fair weather friends, or we can be partners in a larger issue, in a larger struggle.

I see that they will come to our community for a vote, but when they have to vote for the principles upon which they espouse, then all of a sudden, we are expendable, no matter what our qualifications – be it Justice Wallace, or be it Mr. Jackson.

I will vote no..

Here’s my testimony in full: (I was speaking extemporaneously):

Good morning Mr Chairman and members of the Committee. Thank you for the opportunity. My name is Bill Wolfe, I’m from Bordentown and I’m hear to oppose the nominee.

I want to make it clear at the outset that I think Mr. Barr is a fine man, that he’s done great public service, that he’s a good person.

What I say has nothing to do with Mr. Barr as an individual, other than, he comes to this committee in a large context.

Mr. Barr must be evaluated in context. That context is:

Mr. Barr is the Governor’s nominee.

This Governor has a pattern of retaliation and retribution when you cross his path.

This Governor has a policy of promoting gas in NJ, both at plants and through pipelines. His Energy Master Plan promotes that.

So you have a policy context that is very precise. And a we have a nominee that is selected to serve that agenda.

At the same time the candidate doesn’t have – what Tittel referred to as “intellectual curiosity” – but I would refer to as qualifications, experience, and knowledge, or even frankly interest throughout his life, on anything having to do with the Pinelands: history, cultural resources, natural resources, the Pinelands Management Plan – you name it.

I don’t think there’s anything in the record that shows he has qualifications – or even personal interest.

So, all this contextual baggage and Mr. Barr’s lack of qualifications put this committee on the spot: it’s now become a test of whether this committee will do the right thing on a non-partisan, non-ideoligical basis to preserve the integrity of the process, because the public expects the Judiciary Committee to advise and consent on the merits, not on the politics.

If you are inclined to vote in favor of this candidate, given his lack of qualifications and the context that I  just touched upon – and I’d be glad to elaborate in much more detail – then I think you are putting your own Senate position and this Committee in public disrepute, because that’s how obvious everything that’s going on here is.

Therefore I would appeal to you to do the right thing. Don’t bend to the political arguments you may be hearing as to why this individual should be appointed.

And if you do favor his candidacy, then at least go on the record with some substantive explanation as to his qualifications and to some evidence you find in the record as to his qualifications.

Realize that your actions today will establish a new standard – whether a high standard or a low standard remains to be seen – on both the qualifications for a candidate and it will set a new standard for whether a Governor can retaliate against a sitting independent Commissioner for policy and political reasons.

I’d be glad to answer any of your questions – I’d love to enter into discussion with any of you if you have any differences with what I’ve had to say.

[***Update – I just got a note from a friend asking me to correct the harsh words on Senator Lesniak, claiming that Lesniak was with us on this, worked Committee members in our favor, and that he was innocently in Florida, that Sweeney took advantage of his absence and would not let Lesniak be seated today, even after he hurried to get back to NJ especially for this vote.

I find that an interesting story, but since I have no first hand knowledge of that, I will stick with what I wrote, which is my judgement based on what I do know, which obviously is not everything. Readers can judge for themselves if Lesnaik took a pass, or if Sweeney is even a bigger problem here.  end update.]

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