WolfeNotes.com

 [Update: 12/5/10 - From the Creation Museum to Noah's Arc! No bullshit, you can't make this stuff up. NY Times reports:  In Kentucky, Noah’s Ark Theme Park Is Planned

Today is the 50th Anniversary of The Flinstones (Source: Google)

"When you enter the Garden of Eden there are lots of animals and it shows Adam when he named all of them.

Before the fall Dinosaurs were herbivores that lived in the Garden of Eden along with Adam, Eve, and the rest of the animals.  

If you look closely in this picture you can see the serpent in the tree. He actually looked much creepier than I have ever pictured him in my mind!"  Scenes from The Creation Museum

Is this a form of child abuse?

h/t to Matt Tiabbi’s latest Rolling Stone article “Tea and Crackers“. A taste:

Buried deep in the anus of the Bible Belt, in a little place called Petersburg, Kentucky, is one of the world’s most extraordinary tourist attractions: the Creation Museum, a kind of natural-history museum for people who believe the Earth is 6,000 years old. When you visit this impressively massive monument to fundamentalist Christian thought, you get a mind-blowing glimpse into the modern conservative worldview. One exhibit depicts a half-naked Adam and Eve sitting in the bush, cheerfully keeping house next to dinosaurs — which, according to creationist myth, not only lived alongside humans but were peaceful vegetarians until Adam partook of the forbidden fruit. It’s hard to imagine a more telling demonstration of this particular demographic’s unmatched ability to believe just about anything.

Even more disturbing is an exhibit designed to show how the world has changed since the Scopes trial eradicated religion from popular culture. Visitors to the museum enter a darkened urban scene full of graffiti and garbage, and through a series of windows view video scenes of families in a state of collapse. A teenager, rolling a giant doobie as his God-fearing little brother looks on in horror, surfs porn on the Web instead of reading the Bible. (”A Wide World of Women!” the older brother chuckles.) A girl stares at her home pregnancy test and says into the telephone, “My parents are not going to know!” As you go farther into the exhibit, you find a wooden door, into which an eerie inscription has been carved: “The World’s Not Safe Anymore.” 

Lurching from Drought to Flood

As we’ve observed again and again, read today’s news:

National Weather Service issues flood watch throughout N.J.

Heavy rain on its way to New Jersey has prompted the National Weather Service in Mount Holly to issue a flood watch for the entire state from tonight into Thursday night.

The storm will move up the East Coast tonight and Thursday, with heavy rain starting tonight and slowing down Thursday night, according to the service.

Total precipitation is expected to average two to four inches, but could reach six or seven, according to the service.

The western area of the state is expected to be hit the worst.

Flash flooding caused by thunderstorms is also expected south of Interstate 195.

[Update: 10/1/10: Jim O'neill of the Bergen Record: DEP looking for private contractors to oversee some permit applications

Where did DEP find $600,000 in this year’s budget to fund this contract?

Was this money appropriated for this specific purpose?

Press Release

For Immediate Release:  Tuesday, September 28, 2010
Contact:  Bill Wolfe (609) 397-4861; Kirsten Stade (202) 265-7337

 New Jersey to Privatize Land Use Permitting

Contractors to Write Flood Control, Coastal Wetlands and Other Approvals

 
Trenton — New Jersey is now looking for private companies to review applications and draft permits for all of its land use programs, according to a request for proposal posted today by Public Employees for Environmental Responsibility (PEER).  The five-year contract would radically extend Governor Chris Christie’s privatization agenda into regulatory decisions traditionally seen as inherently governmental.

The request for proposal quietly posted on a state web site solicits bids from contractors to assume permit review and drafting for virtually all state land use regulations, including permits for flood control, coastal protection, wetlands, tidelands, stormwater management, the touted Highlands area protections and even threatened and endangered species reviews.  Up to $600,000 “is expected to be available” during the first year of a five-year base contract that could be extended to a total of eight years, however, the source of funds in a strapped state budget are not identified.  Bidding is slated to close on November 4, 2010.

“This is not just the fox guarding the henhouse; this is the fox issuing henhouse tickets to other foxes,” stated New Jersey PEER Director Bill Wolfe, noting that privatization of air pollution permits under former Governor Christie Whitman scandalously imploded after state consultants were discovered stealing proprietary information from permit applications.  “This is a hurried, secretive corporate giveaway of the entire suite of safeguards for soil, water, wildlife and landscapes.”

The request for proposal is structured on a sliding scale, where the contractor could take just a portion or all of the permit preparation duties from Department of Environmental Protection (DEP) scientists and technical specialists who now review applications and write conditions attached to permits.  The DEP Commissioner under Christie, Robert Martin, had no prior environmental experience but did specialize in privatization and deregulation of water and energy public utility systems.

“This contract is structured so that any DEP scientist who raises a troublesome issue could find his or her job outsourced at the drop of a hat,” Wolfe added, noting that an internal DEP “cultural transformation” stresses collaboration with business.  “Privatization is a means to impose corporate control over what are supposed to be independent government experts.” 

 
The land use permit contract would continue a steady march of privatization of state public health and environmental protections.  For example, the Christie administration put a number of industry consultants onto a newly formed Science Advisory Board which will determine what and how science is used to support tighter regulation of chemicals and pollutants, work formerly done by DEP scientist.  Similarly, DEP is putting the finishing touches on a Corzine administration-backed plan to privatize oversight of clean-ups of toxic chemical sites, substituting for state review to ensure that hazards are abated.

“Corporate consultants can work both sides of the street, advising polluters one day and the regulators the next,” Wolfe concluded.  “Business as usual will soon take on a special ominous meaning in New Jersey.”

###

Read the Request for proposal

 http://www.state.nj.us/treasury/purchase/bid/summary/11×21651.shtml 

 Look at Christie eco-privatization agenda

http://www.peer.org/news/news_id.php?row_id=1317

See privatization of scientific reviews

http://www.peer.org/news/news_id.php?row_id=1345

Note privatization of toxic site remediation program

http://www.peer.org/news/news_id.php?row_id=1034

New Jersey PEER is a state chapter of a national alliance of state and federal agency resource professionals working to ensure environmental ethics and government accountability

Another Legislator Indicted  for Pushing DEP Approvals – Will Christie Repeat Corruption in Expediting DEP Reviews?

The recent FBI Operation Bid Rig resulted in convictions of NJ legislators for taking bribes to expedite DEP approvals. (for all criminal complaints see this).

Today, the US Attorney issued more indictments involving political intervention in expediting and securing DEP approvals, so lets trace some recent history.

Even before the Corzine administration era Bid Rig scandals, we always knew that efforts to “Fast Track” DEP permits and approvals were fundamentally corrupt, in terms of compromising protections of public health and the environment for the economic profits of special interests and developers.

After Governor McGreevey signed the Fast Track bill into law in July 2004, we led a succesful statewide environmental group campaign, which led directly to Acting Governor Codey’s Executive Order #45 which established a moratorium on implementing the law.

Subsequently, but prior to the Bid Rig indictments, the Encap Meadowlands project became the poster child for abuse of Fast Track and Pay To Play.  Our assessment of DEP’s role in Encap:

“It’s an egregious failure in oversight,” said Bill Wolfe of the New Jersey chapter of Public Employees for Environmental Responsibility.

We noted:

Bill Wolfe, of the New Jersey Public Employees for Environmental Responsibility, said the loan “is a deep conflict of interest” for state environmental regulators who must also approve the validity of EnCap’s plans to close the landfills and clean up ground water in the Meadowlands.

“These limited state funds should be targeted to give us the biggest bang for the buck in terms of reducing water pollution — not more bangs for those with the biggest bucks,” Wolfe said.

Now it looks like those efforts were criminal too.

According to today’s US Attorney’s criminal indictments of former NJ State Senator Wayne Bryant and prominent attorney Eric Wisler:

BRYANT provided a consistent vote for legislation that was favorable to WISLER’s clients, such as a 2004 amendment to the Redevelopment Area Bond Financing Law that facilitated bond financing for the Meadowlands project, appropriations legislation by which the Meadowlands project received more than $200 million in loans from the New Jersey Environmental Infrastructure Trust (”NJEIT”) and New Jersey Department of Environmental Protection (”NJDEP”), and “fast-track” legislation that required the NJDEP and other state agencies to expedite their review of applications for permits or have those permits deemed granted. BRYANT also sponsored a bill in 2005 for a $112 million loan from NJEIT to be used for the Meadowlands project.

Bergen Record reporer Jeff Pillets deserves a lot of credit for investigating and breaking the Encap story that led to these indictments - we like to think we helped him do so!

More to follow as details emerge.

[full disclosure: I witnessed attorney Eric Wisler in action in my capacity at DEP during loan negotiations on incinerator loans - federal investigators should look into the Newark incinerator financing.]

Shamefully, NJ Governor Christie Backs the Frack

Live hand-in-hand
And together we’ll stand
On the threshold of a dream.  ~~~  Moody Blues (1969) (read lyrics and listen to the music)

Binghamton, NY (9/13/10)

Sorry for delay in writing about the important September 13  EPA public hearing in Binghamton NY to take public comment on the scope of a scientific research study to assesss the impacts of fracking.

Congressman Maurice Hinchey (D/NY)

Creation of  that EPA  study was spearheaded by NY Congressman Maurice Hinchey and has generated enormous public interest  (the deadline for public comment is September 28)

Despite the public outrage, many well publicized destructive impacts, and a wild west gold rush mentality, since that public hearing, it looks like the Obama Administration is corrupted by gas industry lobbying (see NY Times: ”Obama Rejects Time Out for Natural Gas Drilling in NY, Pa.”

Remarkably, it appears that EPA is about to cave in to gas industry pressure to politicize the science. This would repeat the 2004 scientific  fiasco  (exposed by EPA whistelblowers) when Vice President Cheney and his Energy Taskforce installed Haliburton lobbyists to be in charge of EPA’s initial study that led to 2005 Congessional exemptions from environmental laws.

If the Obama EPA and Science Advisory Board allow a repeat of that, they will destroy all credibility EPA may have gained by what appear to be good faith efforts thus far.

Propublica has been doing outstanding work on the fracking issue, which excuses my laziness. So I urge anyone involved or interested in the fracking issue to read that coverage. It is extremely unusual for journalists to so beautifully investigate, understand, and report on a complex scientific and regulatory issue.

All I can say is a huge thank you to ProPublica, and to urge our home town NJ reporters to emulate that superb work.

Anyway, getting back to the issue at hand – EPA held a public hearing to take comments in Binghamton NY back on September 13. The hearing was preceded by a street protest (I was proud to discover that I went to college with Binghamton’s Mayor, Matt Ryan, who was a fellow graduate of SUNY Binghamton’s environmental science and public policy program. In a superb irony, my later graduate thesis topic at Cornell was “Land Use Controls to Prevent Groundwater Contamination of NY Southern Tier River Valley Aquifers  “).

Technically, my only comment on the scope of the EPA study is that it seeems like EPA is too narrowly focusing on drinking water impacts of chemicals, and ignoring the massively destructive land use and ecological impacts of thousands of fracking wells. And with current drought conditions, how are DRBC and NY, NJ, and Pennsylvania officials going to allocate reductions among current users that are necessary to account for the 5 million gallons of water needed for each of thousands of fracked gas wells?

Strategically, I’d note that some NY activists seems hopelessly naive in presuming a “de facto” drilling moratorium. But NY activists were already screwed by NY Governor Paterson and the Legislature when they enacted the so called “spacing bill“ that provided the gas industry a certain “by right” drilling density. (read the PR cover story here). In a rare and refreshing bit on honesty, a western NY spokesman from the Onandaga Indian Nation recognized this by stating “we’ve already been fracked”. 

The links above provide more than enough technical information, so all I will do below is post a few pictures of the event.

US EPA Region 2 Administrator, Judith Enck

In addition to posting photos, I also take this opportunity to do three things:

1) to recognize the leadership of longtime environmental warrior Congressman Maurice Hinchey (D-NY), who sponsored the legislation to conduct the EPA study, as well as the “Frack Act”  (HR 2766) to regulate fracking;

2) to thank EPA Region II Adminsitrator Judy Enck for her sincere and outstanding efforts; and

3) to condemn NJ DEP Commissioner Bob Martin and NJ Governor Christie for quietly acting behiond the scenes to support fracking.

(some photos)

residents welcome EPA, as Binghamton mayor Matt Ryan addresses protestors

Lehigh River (at Jim Thorpe, Pa.) is threatened too

NY State's Southern Tier remains rural (underlain by Marcellus gas bearing shale)

Sergeant at Arms tries to seat a packed labor crowd at Senate LNG hearing.

“Deputy Christie spokesman Sean L. Conner said, “We’re against all LNG.”  Bergen Record, April 23, 2010

Yesterday, the Senate Environment Committee either made a huge political blunder or they walked into an avoidable ambush. 

I wonder whose advise legislators were listening to?

The firestorm was in response to non-binding Senate Resolution 85, opposing the development of liquefied natural gas (LNG) facilities off the New Jersey coast.

The rhetoric was heated.

Some environmental groups, such as Clean Ocean Action (COA), have dubbed off shore LNG “insanity Island” and a huge threat to the ocean, natural resources, and fisheries. 

COA’s testimony conjured up the energy equivalent of ”an invasion by a foreign country”. COA warned that LNG facilities would become targets for terrorists and that LNG imports would come from “middle eastern” countries, including Yemen. COA warned legislators that off shore LNG would increase “foreign dependence” and undermine Homeland Security and “energy independence”. They said an LNG tanker had the explosive power of “55 Hiroshima bombs“.  (I almost felt as if a 9/11 Mosque alert was next!).

COA managed to say all this in support of the Resolution, while giving Governor Christie a pass on his campaign pledge and Earth Day promise to kill off shore LNG.

The lobbyist for one LNG project developer, Liberty Energy, fired back. He claimed that the COA testimony was flat out “false and misleading” and then proceeded to rebut via a ”Fact versus Fiction” factsheet. He said his $800 million investment would create 1,100 jobs and have no impact on the ocean or create any emissions to the environment.

Organized labor was out in force, and framed the issue as a “vote against jobs”.

But why would anyone needlessly put themselves in such a position, especially under current economic conditions and unemployment rate?

I say needlessly for several important reasons:

1) The legislature has no role in off shore LNG. The LNG permit review and approval process is pre-empted by federal law.

2) Even if the Legislature had jurisdiction, a Resolution is a non-binding and essentially meaningless symbolic gesture. No gain, lots of pain.

3)  The ONLY NJ official with a role in LNG approval process is the Governor, who has a veto power under federal law.

4) Governor Christie has pledged to use his veto power and already has come out in strong opposition to off shore LNG.  

To high praise by COA and glowing press coverage, during Earth Week, Governor Christie held a big event down the shore (at a private beach club) to announce:

Gov. Christie issues potentially fatal blow to liquified natural gas proposals

Friday, April 23, 2010

BY JAMES M. O’NEILL

The Record

STAFF WRITER

Governor Christie used Earth Day on Thursday to issue a potentially fatal blow to private investors who want to build a $2.2 billion artificial island 20 miles off Sandy Hook for ships to unload liquefied natural gas.

 

 Christie expressed opposition to any facilities for liquefied natural gas off New Jersey’s coast, saying they “are not the answer for New Jersey’s needs.”

[...] 

 Asked for clarification of the governor’s comments, deputy Christie spokesman Sean L. Conner said, “We’re against all LNG.”

So why would a legislator agree to hold a hearing on a symbolic gesture opposing a dead project the Governor already killed???

5. On top of all that, private sector economic forcasters say the glut of domestic gas has killed all investment prospects for LNG import facilities:

 One by one, developers of US LNG import terminals pulled the plug this summer as overabundant domestic natural gas production turned what had been a challenging outlook for imported gas into an all but impossible business model. (full article here)  

By the end of the hearing, Senator Beck (R-Monmouth) was running away from supporting the Resolution and her Party’s Governor’s position to kill off shore LNG.

In our view, the entire hearing was an embarrassing self inflicted wound that stoked a far broader anti-environmental backlash – and all for no nothing!!.

COA somehow had managed to lose the battle, undermine their credibility, strenghten their opponents, and let the Governor off the hook.  Wow!

ps – In a comment to the Bergen Record story cited above, I submitted this comment:

Friday April 23, 2010, 12:33 PM – Gracus says:
How economically feasible are these projects in light of huge glut of domestic natural gas, including new large reserves in the Marcellus Shale? They were dead projects walking.

Christie gets big in California (photo credit: Star Ledger)

While the Cat is away the Rats will play!

Lt. Gov. Kim Guadagno takes the oath of Office

With Governor Christie out of Town yesterday doing the Opra Show and other orchestrated political stunts, Lt. Governor Guadagno (AKA “Red Tape Czar”"), got into the Christie “decider” spirit and did some first rate State House ordering and directing. 

Guadagno issued an Executive Order of her own (click to see EO # 41).

Just like Dick Cheney who led the Bush search team for Vice President and found himself, Guadagno named herself as Chair of a new Red Tape Review Commission.

The Guadagno Order creates more bureaucracy and more centralized, politicized, murky, and unaccountable  review processes:.

The Order states: 

NOW, THEREFORE, I, KIM GUADAGNO, Acting Governor of the State of New Jersey, by virtue of the authority vested in me by the Constitution and by the Statutes of this State, do hereby ORDER and DIRECT:

1. A Red Tape Review Commission (“Review Commission”) is hereby established. The Department of State shall provide support to the Review Commission from existing staff and resources.

Guadagno seems blissfully oblivious to the supreme irony that her 90 day temporary Red Tape Review Task Force has now created more permanent Red Tape!

The Order grants the new Red Tape Commission a very broad mandate.

The Order lacks any procedural or substantive safeguards to protect the public interest, promote ethics and transparency, or limit behind the scenes influence of powerful special interests. 

While the Order calls for 3 public hearings per year, there are no requirements that the Red Tape Commission abide by open public meetings, sunshine, or ethics laws.

There are no conflict of interest restrictions on Commission members.

There are no requirements that the Commisison meet and deliberate openly and comply with Open Public Records laws.

We view this Commission as a back channnel for secret business community attacks on regulatory protections.

The only positive aspect I see is that the Commission appears to be limited to review of existing rules and regulations and was provided no role in developing new regulations. 

However, there are no prohibitions on the Commission intervening in:

• 1) the rulemaking process for new rules; 
• 2) the reauthorization of existing rules; 
• 3) pending DEP permit decisions or enforcement actions; or
• 4) rate making processes of BPU .

And that ambiguity is a HUGE problem.

Clean Water Act Tools and Mandates May Strengthen Bay Response

[Update 2 - 10/8/10: Trenton's Sultan of the sound bite pans a science based Clean Water Act regulatory tool - Asbury Park Press story:  Bill requires limits on nutrient pollution for Barnegat Bay

In theory, the limits can be a powerful regulatory tool that forces state and local governments to track and clean up heavy nutrient sources in the watershed. Excessive nutrients are fueling algae blooms in the bay and changing its ecosystem at a basic level, according to marine scientists, who think last summer's outbreak of stinging jellyfish in the bay is linked to those long-term shifts.

But even some environmental activists are skeptical. Establishing load limits is a scientifically complex and expensive process, and good results are not guaranteed, said Jeff Tittel of the Sierra Club.

Clean-water groups filed a lawsuit to get load limits for the Delaware River and Bay, "and the limits they came up with weren't very good," Tittel recalled.

Real smart move Tittel, just brilliant.

Update 1: 9/27/10 - excellent Kirk Moore story in today's Asbury Park Press: Sen. backs daily limits on pollution in the bay. Given that just a few weeks back, Senator Smith was quoted that my recommendations were "wrong", of course, I liked this line best:

A similar plan is needed for Barnegat Bay, said Bill Wolfe of Public Employees for Environmental Responsibility, a former DEP official. In addition to the Chesapeake model, New Jersey can look to Florida, where EPA administrator Lisa Jackson is seeking to enforce phosphorus limits on Florida to clean up the Everglades, Wolfe wrote on his blog wolfenotes.com.

"I'm not afraid to listen to Bill Wolfe when he has a good idea," Smith said. Wolfe says he would like the Legislature to take a stronger stance with a bill to require action by the DEP.

Something potentially significant happened today as the Senate Environment Committee heard a new addition to the 4 bill package designed to protect and restore Barnegat Bay.

That package was initially heard on August 12, 2010 (i.e. S 1410 (soil compaction); S 1411 (fertilizer standards); S 1815 (stormwater demonstration project) and S 1856 (stormwater utility).

The package is stalled due to lack of support by Governor Christie and strong opposition by the Ocean County Freeholders and the fertilizer and lawn care industries.

Back in August, in hearing testimony, I criticized the package as technically flawed and called the voluntary approach unworkable due to Ocean County opposition.

I followed that testimony up with an August 17 Asbury Park Press Op-Ed .

To emphasize and elaborate on those flaws, I later wrote:

This [Rutgers Professor Kennish] quote from an August 6 Kirk Moore story from the  Asbury Park Press series on the Bay sums that perspective up:

“We have the data already. We’ve had it for years,” said Michael Kennish, a research professor who heads Rutgers University efforts to study Barnegat Bay’s pollution problems. “We know what the problems are. We need to have big stuff done, mandates and requirements imposed by DEP.”

I outlined some of that “big stuff” and DEP mandates by citing the need to enforce the federal and state Clean Water Act.

Under the Clean Water Act, both the New Jersey DEP and the US EPA have a mandatory duty to assure that water quality standards are met in Barnegat Bay so that the Bay is safe for fishing, swimming, and supports healthy aquatic ecosystems. Currently, the Bay is not meeting any of those fundamental Clean Water Act goals.

But let’s get back to today’s developments.

In keeping with the small bore piecemeal approach of the original package, the new additional bill, S 2275, would direct NJ Department of Transportation to inventory DOT owned stormwater basins in the Bay watershed.

The bill  amounts to a political concession to the Ocean County Freeholders, who complained that DOT failed to maintain DOT owned stormwater basins, in contrast to Ocean County, who allegedly did a fine job maintaining county basins.

The bill’s sponsor and Committee Chairman Bob Smith, introduced the bill to the Committee with an unusual statement. He said that he would hold the bill for testimony only, because he agreed with written comments he had received from myself and Tim Dillingham of the NJ Chapter of American Littoral Society.

I wrote Smith to note that yesterday EPA published a Clean Water Act based draft “Total Maximum Daily Load” (TMDL) for nutrients and sediments into Chesapeake Bay (click here to read EPA’s Federal Register publication).

I reiterated that the Chesapeake Bay TMDL should be the model for Barnegat Bay.

I also warned that if NJ DEP continued to drag its feet on taking necessary steps to protect and restore Barnegat Bay, then NJ was vulnerable to a Clean Water Act lawsuit and the kind of harsh remedy that was imposed in Florida earlier this month via an EPA Order. 

An  EPA issued an Order directed the State of Florida to take specific steps to reduce nutrient pollution loadings to the Everglades to restore that precious ecosystem. According to PEER:

EPA PRESCRIBES FLORIDA TOUGH MEDICINE FOR EVERGLADES — State May Balk at Stringent Federal Water Quality Measures and Timetables

 Tallahassee — Facing a federal contempt citation, the U.S. Environmental Protection Agency has ordered Florida to take immediate and dramatic attempts to reduce water pollution in the Everglades, according to documents posted today by Public Employees for Environmental Responsibility (PEER). If EPA cannot get Florida to accept its conditions, it may lead to a federal takeover of state water pollution controls.

On October 7, 2010, EPA Administrator Lisa Jackson will personally appear before U.S. District Court Judge Alan Gold in a contempt hearing into repeated violations by EPA and Florida of a 2008 ruling to comply with phosphorous limits for sensitive Everglades waters. On the September 3rd deadline set by Judge Gold, EPA announced that it had a plan to comply with the order and avert a contempt finding but the agency did not release any details. This coyness may be explained by the fact that this new set of EPA Everglades dictates, called the “Amended Determination,” go far beyond any previous actions, including –

• Florida is ordered to amend both its controversial Everglades Forever Act and its phosphorus rule to significantly cut pollution flows;
• In order to reduce phosphorus loading into canals, the state must purchase at least 42,000 acres of land as Stormwater Treatment Areas; and
• Existing water pollution permits must be tightened to conform to new limits by December 3, 2010.

The EPA Amended Determination also flatly declares that Florida is violation of the Clean Water Act and can no longer be allowed to ignore nutrient standards for the Everglades Protection Area. It indicates that if Florida does not take the stipulated steps EPA will directly impose these actions under federal law.

Much to my surprise, Senator Smith agreed to support a TMDL and to introduce a Resolution urging EPA and DEP to adopt one for the Bay.

So this is an opportunity to educate the Committeee on the DEP’s TMDL program and force DEP to ramp up efforts and make the Bay a priority.

While I don’t think a simple Resolution is sufficient, we may have a breakthrough in recognizing the TMDL as the proper regulatory vehicle on the Bay.

We will keep you posted and urge you to contact Senator Smith and members of the Committee in support of a TMDL approach.

After all, even the Ocean County Freeholders said that the Bay is a state resource and if it is of such economic importance, then the legislature should mandate a state solution. So I say:

Give them what they asked for!