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Toxic Polluters Writing DEP Cleanup Regulations

May 31st, 2011 No comments

Christie DEP Mimics Bush/Cheney  Energy Taskforce

We bring in all different organizations so that we’re getting all different points of view before we make decisions. ~~~ DEP Commissioner Bob Martin (watch it)

We can cut through unnecessary red tape and provide real solutions to real-world problems, while maintaining our high protective standards. ~~~  DEP Commissioner Bob Martin said. (read it)

Closely following the testimony I delivered on December 9, 2010 to the Senate Environment Committee (see: DEP Puts Lipstick on Industry Dominated Toxic Site “Reform” Pig, today Jim O’neill of the Bergen Record wrote a killer story: Polluters rewriting rules for site cleanup.

O’Neill’s reporting flat out contradicts DEP Commisisoner Martin’s claims about seeking “different points of view”. The story begins:

Key committees writing rules for New Jersey’s new program to clean up contaminated sites are made up entirely of the polluting companies and their contractors.

The 16 committees, which have been putting together rule and guidance documents, include no one from environmental or resident advocacy groups, no health specialists, and no outside experts who aren’t affiliated with the cleanup industry.

“It’s a who’s who of corporate polluters and their hired consultants”, said the New Jersey Sierra Club’s Jeff Tittel. “These oversight rules will be written so loosely there will be nothing to enforce later.”

Well, so much for Martin’s commitment to obtaining “all different points of view” before making decisions! DEP proposed rules on May 2, 2011.

But that’s not the only DEP lie foisted on the public  - the more important lie is about ongoing DEP efforts to weaken public health and environmental standards.

Importantly, O’Neill broke a very important aspect of this rollback effort. For the first time, DEP is on record as saying they plan to revise cleanup standards:

The DEP is also creating a group of committees to revise the actual standards for cleanup the levels of contamination that can remain after cleanup depending on the site’s future use.

This contradicts repeated DEP assurances that current cleanup standards would be retained.

During debates on the controversial privatization of NJ’s toxic site cleanup program, the public was given repeated assurances by legislators and DEP that DEP would retain current stringent health and environmental standards, including current soil, groundwater, surface water, vapor intrusion, and drinking water standards.

But those repeated assurances have been betrayed.

When I warned the Senate Environment Committee on December 9, 2010 that standards would be weakened, Committee Chairman Bob Smith challenged that testimony and repeated DEP’s assurance that cleanup standards would NOT be weakened.  I urge anyone with doubts to listen to the testimony, including my exchange with Chairman Smith, which begins at time 1:26:20)

Current DEP Commissioner Martin is violating a commitment of his predessor and thus legislative intent, which was based on those commitments that standards would be retained.

On April 15, 2008,DEP Commissioner Lisa Jackson testified to the Legislature:

Under this plan, [toxic site cleanup] cases will be adddressed rapidly and properties will be developed to desired uses. We will be cleaning up sites and stimulating economic vitality vitality. We will not compromise on our standards or protection of the environment and public health. Nor will we delegate the inherently governmental functions of site remediation to private entities. The Department will maintain the functions associated with the issuance all NFA’s, review all cases with receptor and off-site contaminant migration impacts, audit cases based on potential risks and expand our oversight for the “worst” cases and for those with recalcitrant responsible parties.

But the Christie Administration’s new policy is even worse than that.

Vapor intrusion decisions are inherently governmental functions and essential public health protections.

Vapor intrusion sites are high risk cases that are required to remain under direct DEP oversight.

Delegating decisions on vapor intrusion to private entities and allowing them to exercise judgement in the absence of regulatory standards is absurd – get the whole story on DEP’s May 2, 2011 rule proposal below from our friends at PEER:

[Note 1: DEP summary of the SRRA does not even mention the mandate in Section 39 to adopt a "remedial priority system" (RPS) by May 2010.

The RPS was designed as the mechanism by which DEP would prepare a risk based cleanup priority list and retain direct oversight of high risk cases  while the LSP's were given low risk cases. Obviously direct contact exposure vapor intrusion would be a high risk case that would be under direct DEP regulatory oversight under the standards in the Vapor Intrusion Guidance, not an LSP case allowing discretionary use of "best professional judgement" to determine if vapor investigation is necessary and whether or not to mitigate.]

[Note 2: The Department could have proposed a rule that provided for direct DEP oversight of vapor intrusion cases. They chose not to do that. The Department’s proposal and  various facts sheets all fail to address the RPS mandate and risk based criteria for the DEP to retain direct regualtory oversight. Here is the statutory language – look specifically at b. 4 below:

C.58:10C-27 Direct oversight of remediation by department; conditions

b. The department may undertake direct oversight of a remediation of a contaminated site under the following conditions: 

(1) the contamination at the site includes chromate chemical production waste;

(2) the department determines that more than one environmentally sensitive natural resource has been injured by contamination from the site;

(3) the site has contributed to sediments contaminated by polychlorinated biphenyl, mercury, arsenic, or dioxin in a surface water body; or

(4) the site is ranked by the department in the category requiring the highest priority pursuant to the ranking system developed pursuant to section 2 of P.L.1982, c.202 (C.58:10-23.16).

Management 101 – set priorities.

[Update #1  - even the DEP acknowledges that their job is to retain direct oversight of the highest risk cases. In a recent regulatory adoption, DEP responded (to my comment opposing a “safety cushion”, code for elimination of mandatory timeframes) as follows:

Placing a significant number of cases under direct oversight would defeat the purpose of the LSRP program, which was to relieve the Department from overseeing the remediation of every case in favor of having enough resources for the Department to focus on the cases that pose the greatest risk to public heath and the environment.(@ page 25)

So, exactly what are those cases? What are the sites that pose the greatest risk to public health and the environment?

Shouldn’t we know this before giving ANY site to an LSP?

[Update #2: 6/1/11 - did an interview on WBAI radio (Pacifica affliate in NYC) “Wake Up Call” – runs in 6 am hour – from time 47:55 – 59:55 (to listen hit link in upper right)
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Memorial Day Message – “War is a Racket”

May 30th, 2011 No comments
Grandfather Peacox (seated on left)

Grandfather Peacox (seated on left)

Today, I’ll repost my Veteran’s Day post in respect for my maternal grandfather Peacox, a WW I vet; my paternal grandfather “Pop” Wolfe, a WW II Navy vet; my Dad, who served in the Army during Korea (but not in combat); and my Uncle Charlie, who was wounded in Korea.

None of them died in war, but they all were impacted by war, and poor uncle Charlie lost his soul in Korea.

We go first to WW I USMC General Smedley Butler, and then to former USMC Captain Mathew Hoh, who resigned in protest over Afghanistan war :

WAR is a racket. It always has been.

It is possibly the oldest, easily the most profitable, surely the most vicious. It is the only one international in scope. It is the only one in which the profits are reckoned in dollars and the losses in lives.

A racket is best described, I believe, as something that is not what it seems to the majority of the people. Only a small “inside” group knows what it is about. It is conducted for the benefit of the very few, at the expense of the very many. Out of war a few people make huge fortunes.

In the World War [I] a mere handful garnered the profits of the conflict. At least 21,000 new millionaires and billionaires were made in the United States during the World War. That many admitted their huge blood gains in their income tax returns. How many other war millionaires falsified their tax returns no one knows. [...]

Take our friends the du Ponts, the powder people – didn’t one of them testify before a Senate committee recently that their powder won the war? Or saved the world for democracy? Or something? How did they do in the war? They were a patriotic corporation. Well, the average earnings of the du Ponts for the period 1910 to 1914 were $6,000,000 a year. It wasn’t much, but the du Ponts managed to get along on it. Now let’s look at their average yearly profit during the war years, 1914 to 1918. Fifty-eight million dollars a year profit we find! Nearly ten times that of normal times, and the profits of normal times were pretty good. An increase in profits of more than 950 per cent. [...]

And let us not forget the bankers who financed the great war. If anyone had the cream of the profits it was the bankers. Being partnerships rather than incorporated organizations, they do not have to report to stockholders. And their profits were as secret as they were immense. How the bankers made their millions and their billions I do not know, because those little secrets never become public – even before a Senate investigatory body.

[Full text is here]

For anyone who might think Mr. Smedley Butler was some hippie pacifist, here’s his Wiki bio:

Smedley Darlington Butler (July 30, 1881 – June 21, 1940), nicknamed “The Fighting Quaker” and “Old Gimlet Eye”, was a Major General in the U.S. Marine Corps, and at the time of his death the most decorated Marine in U.S. history. During his 34-year career as a Marine, he participated in military actions in the Philippines, China, in Central America during the Banana Wars, the Caribbean and during World War I, he served in France. By the end of his career he had received 16 medals, five of which were for heroism. He is one of 19 people to twice receive the Medal of Honor, one of three to be awarded both the Marine Corps Brevet Medal and the Medal of Honor, and the only person to be awarded the Brevet Medal and two Medals of Honor, all for separate actions.

Next, we go to the words of USMC Captain Hoh. Hoh didn’t leak documents or blow the whistle, he honorably resigned in disgust. Here is his resignation letter:

… Our support for this kind of [Afghanistan] government, coupled with a misunderstanding of the insurgency’s true nature, reminds me horribly of our involvement with South Vietnam; an unpopular and corrupt government we backed at the expense of our Nation’s own internal peace, against an insurgency whose nationalism we arrogantly and ignorantly mistook as a rival to our own Cold War ideology.[...]

I realize the emotion and tone of my letter and ask that you excuse any ill temper.  I trust you understand the nature of this war and the sacrifices made by so many thousands of families … Thousands of our men and women have returned home with physical and mental wounds, some that will never heal or will worsen with time. The dead return only in bodily form to be received by families who must be reassured their dead have sacrificed for a future worthy of futures lost, love vanished, and promised dreams unkept. I have lost confidence that such assurances can anymore be made. As such, I submit my resignation.

[please read complete letter here]

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The Wisdom of Solomon – Is NJEF Credibilty Shot Yet?

May 29th, 2011 No comments
Lee Solomon - President, BPU

Lee Solomon - President, BPU

Today’s Star Ledger Auditor column reports that there was a behind the scenes battle in Governor Christie’s Cabinet on his controversial global warming denial comments.

The Auditor claims that Lee Solomon was the global warming denier: Global warming splits the Christie administration

Gov. Chris Christie might have raised some eyebrows when he announced he was “deferring to scientists” on the issue of global warming after being “skeptical,” but it seems to have come after some division in his office.

The Auditor has learned that in the lead-up to Christie’s Thursday announcement that he would pull out of the regional cap-and trade program designed to reduce greenhous gases, there was a split between his advisors.

Supporting the view that global warming is a man-made occurrence was Department of Environmental Protection Commissioner Robert Martin. On the other side was Lee Solomon, the president of the Board of Public Utilities.

Multiple sources tell The Auditor that behind closed doors, Solomon wasn’t shy about his skepticism over global warming.

So, I thought I’d remind folks of what the Christie backing  NJ Environmental Federation said on Jan. 21, 2010 about Mr. Solomon:

Christie’s BPU pick has a green past for a green future

 

Trenton, NJ — The NJ Environmental Federation (NJEF) released the following statement in response to Governor Christie’s pick today to head the BPU.

“Lee Solomon has the legal, environmental, personal, and political background to ensure a cleaner, greener 21st century. While we’ve obviously worked less with him more recently given his role as a judge and prosecutor, Lee Solomon was an environmental ally as a Freeholder and Assemblyman. His strong opposition to proposed garbage incinerators in Camden and Pennsauken, the latter of which was stopped, because of their negative enviromental and economic impacts bodes well for today. We need clean solutions for tomorrow not dirty ideas from the past. That’s Governor Christie’s agenda. That’s why we endorsed him and we look forward to working again with Lee to implement that agenda,” said Sharon Finlayson, NJEF’s Board Chair.

In addition to the Governor’s energy as industry agenda (http://christiefornj.com/issues/energy-as-industry.html) , BPU will play an important role implementing some of the key pieces of the Governor’s environmental agenda including but not limited to:

  • Aggressively implementing the Global Warming Response Act and Energy Master Plan to reduce greenhouse gas emissions with greater emphasis on clean renewables and energy efficiency;
  • Enacting policies in the first 100 days to stop the fish slaughter resulting from flawed cooling systems at the Salem and Oyster Creek nuclear plants; and
  • Opposing the proposed Linden coal plant, recognizing the environmental injustice it places on a community already overburdened by pollution.

Ahem… is it toast yet? Stick a fork in it!

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Christie DEP Slashing Air Pollution Enforcement

May 29th, 2011 No comments

In yet another sign of the ill advised polluter friendly deregulatory policy of the Christie Administration, today’s Star Ledger reports that DEP inspections and enforcement of air pollution laws hit a historic low in the first year of the Christie Administration:

Decline in N.J. pollution control raises environmental concern

 

Trenton – State scrutiny of air polluters ranging from oil refineries to neighborhood dry cleaners slipped during the past decade, according to a Star-Ledger review.

Statistics show that while oversight of New Jersey smokestacks often fluctuated during the decade, inspections, investigations and enforcement all hit lows in 2010.

Department of Environmental Protection numbers show that from fiscal year 2001 to fiscal year 2010:

•Routine inspections of air polluters decreased 65 percent, from 1,387 to 490.

•Surprise investigations, often spurred by complaints, fell 40 percent, from 1,027 to 621.

•Actions taken against polluters breaking the law fell 25 percent, from 984 to 739.

•Staffing for air pollution enforcement dropped 19 percent, from 75 people to 61 people.

Kudos to the Ledger for doing real journalism and reviewing DEP documents, instead of rehashing DEP press release spin.

Let’s hope this blood in the water is expanded to look at the Christie/Martin rollbacks in virtually all DEP programs – and show how those polluter friendly policies harm public health and environmental protection – and that Democrats in the Legislature intervene to start holding the Governor accountable for these policies by conducting oversight hearings to assure that NJ’s strong environmental laws are strictly enforced.

(hint: lots of skeletons in this closet)

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DEP Press Office Spins Greenhouse Gas Emissions Report

May 29th, 2011 No comments

Release of Emissions Inventory needlessly creates deep confusion

We just had a replay of the confusion created following Governor Christie’s Feb. 22 budget address.  

Recall that the Gov. went out of his way to brag that he slashed DEP’ budget by 10%, a claim that was contradicted just 1 hour later by DEP Commissioner Bob Martin, who issued a press release that said DEP’s budget had increased by 5.3% (see: Did Martin Pull a Schundler?).

To his business cronies, Christie wanted to appear a “fiscally responsible” budget hawk, particularly by starving the beast at DEP. Yet, he and Bob Martin also wanted to appear pro-environment.  

It’s deja vu all over again - but this time Martin didn’t wait an hour. He appeared with the Governor. They want it both ways again:

Last week, the NJ DEP issued a press release, announcing the release of a DEP Report on Greenhouse gas emissions during the calendar year 2008.

The lede of the press release highlighted that greenhouse gas emissions were declining and claimed that NJ had actually met the Global Warming Response Act’s 2020 emissions reduction goals.

The DEP release was issued the same day Governor Christie stirred national controversy  by announcing that he was withdrawing NJ from the 10 northeast states’ Regional Greenhouse Gas Initiative (RGGI).

Here is DEP’s lede:

TRENTON – Statewide greenhouse gas emissions decreased by more than 8 percent in 2008, bringing New Jersey under 2020 emissions levels targeted by the State’s Global Warming Response Act (GWRA), according to a legislatively mandated report issued by the DEP today.

We’ll get to that alleged “legislative mandate” in a moment (see point #1 below), but at this point will note that it implies some sense of independence between the release of the Report and the Governor’s RGGI statement.

The same day DEP issued the emissions inventory, Governor Christie held a press conference - accompanied by DEP Commissioner Martin. In addition to his RGGI statement, in an effort to have it both ways, the Governor issued a dubious statement highlighting bullets about Christie’s “Commitment to Protecting NJ’s Environment” . 

For national consumption, the NY Times coverage noted that Christie’s withdrawal from RGGI was based on this rationale:

Gov. Chris Christie of New Jersey said the regional climate initiative “does nothing more than tax electricity, tax our citizens, tax our businesses, with no discernible or measurable impact upon our environment.”

In NJ media circles, although Christie won praise for finally conceding that humans caused global warming (a scientific conclusion he previously denied), a close reading of the text of the Governor’s statement suggests just the opposite.

Instead of walking back his global warming denial, Christie actually is using classic propaganda techniques to manufacture false uncertainty about:

  • the scientific consensus on man made global warming (“we are at least part of the problem” – inference: we better figure out how much):
  • the urgency of the problem and strength of the science to support policy actions now (we are “just beginning to have a fuller understanding” - inference: guess we need to wait for more science to come in); and
  • the existence of currrent NJ laws and policies to control greenhouse gas emissions (“put policies in place” – inference: putting in place policy takes more time and we’re under no binding laws and policies now. Just like the New Normal, the past is not binding):

[Update: 6/6/11 - read this piece about risk versus uncertainty: "Risky Advice"]

Christie did all this by saying:

But when you have over 90% of the world’s scientists who have studied this stating that climate change is occurring and that humans play a contributing role it’s time to defer to the experts. Climate science is complex though and we’re just beginning to have a fuller understanding of humans’ role in all of this. But we know enough to know that we are at least a part of the problem. So looking forward, we need to work to put policies in place that act at reducing those contributing factors.

So, moving right along, from a communications perspective, what’s up with these deeply conflicting messages on a key issue? Can emissions be declining, and yet RGGI ineffective? What’s the relationship between RGGI and emissions reductions? What explains emissions reductions? How much is due to RGGI and how much does RGGI cost? What does the money go toward? Who benefits and who pays?

The Governor’s statement provided 4 reasons for killing RGGI (we will examine them in a subsequent post).

Getting back to DEP’s emissions inventory press release: Was DEP providing cover for the Governor by balancing the “good news” about emissions reductions with the bad Christie RGGI move? Did they expect more praise and cover from Pringle?

Do the Christie folks think they can have it both ways? Or was this incoherent chaos an intentional move to baffle the media and public by creating a plausible cover story?

Let’s first look at the media dynamics.

Predictably, the DEP press release on the emissions inventory Report prompted criticism from Jeff Tittel of Sierra Club, who also questioned the timing of its release, comparing it to discredited George Bush tactics:

“This report is the environmental equivalent of George Bush landing on an aircraft carrier with a sign that says ‘Mission Accomplished,’ ” said Jeff Tittel of the Sierra Club’s New Jersey chapter. “The data makes no sense.”

The DEP press office fired back, with another in what has become a pattern of increasingly harsh attacks on Tittel:

“The study speaks for itself. It’s just a factual report,” said DEP spokesman Larry Ragonese. “Jeff Tittel can criticize all he wants, but this study was prepared by DEP scientists who are viable, credible professionals who put the numbers together as required by the Legislature. The numbers are legitimate and valid.”

We agree with DEP on one point - yes, DEP scientists and staff are credible. But the DEP Commissioner and Press Office are not.

Shame on them for timing the release of this report to provide Christie RGGI cover and then hiding political spin behind the reputations of DEP professionals. 

That too is a page out of Bush media playbook. Bush shamelessly hid behind the troops. He did this to dodge criticism of Bush’s bad decision to go to war in Iraq. Critics were marginalized and attacked as unfaithful to the troops fighting his foolish war (this explains all the obligatory “Support the Troops” crap. The modern roots of that go back to Nixon administration lies about hippies spitting on Vietnam Vets as they returned to the US. But I digress).

Moving on to the technical front, I reviewed and will focus today of the emissions inventory Report (I intend to write a policy piece about Governor Christie and the RGGI issues in a subsequent post).

My intent here is not to get into the increasingly petty he said/she said DEP press office squables or to defend Tittel (he’s more than capable of that), but to illustrate how DEP Press Office is hiding behind and spinning the data in the DEP staff emissions inventory Report.

1. The timing is Suspect

The DEP Report releases data from 2008 – which leads to the obvious question of “why was it released now?”.

The timing of the release is highly suspected of political motives, for at least the following reasons:

  • The Christie RGGI withdrawal press conference. RGGI is one of 3 major components of NJ’s greenhouse gas emissions reduction strategy.
  • Section 7 of the GWRA requires DEP to submit biennial reports (i.e. every 2 years), starting in January 2009. According to DEP’s May 2011 Report, the last biennial report was completed in November 2009 and included estimated greenhouse gas emissions for years 2005 through 2007. The next biennial Report  was due in January 2011, but could be expected in November 2011, Regardless, it should include emissions for years 2007 – 2009. So why was this Report issued in May 2011 and limited to 2008 emissions? Why is DEP moving to an annual Report when the law specifies biennial reporting?
  • According to Appendix A of the DEP report, the 2008 electric sector in state emissions “data were downloaded from the Department’s database through WebIntelligece on  May 19, 2010. That was over 1 year ago – does it take over a years to format that data in a Report? What explains the delay? 

2) The Press release is selective and misleading with repect to attaining Global Warming Response Act Goals

The DEP staff report correctly notes that the GWRA has two very different emissions reduction goals: a 2020 target and a far more stringent 2050 target. Yet the DEP press release selectively mentions only the 2020 target. This cherry picking misleadingly implies that the Act’s requirements are met.  As Tittel said: “Mission Accomplished“.

The DEP staff Report noted that we have a long way to go in meeting GWRA goals. Here is what the Report actually says. But you wont find these key findings in the DEP Press Office spin:  

The Statewide greenhouse gas limit for 2050 is 80 percent less than the 2006 level of Statewide greenhouse gas emissions, or 25.4 MMTCO2e. To achieve this limit, greenhouse gas emissions must be reduced approximately 101.5 MMTCO2e compared to 2006 emissions. The 2008 releases are 124.9 MMTCO2e, approximately 99.5 MMTCO2e above the 2050 limit. 

3) Emissions inventory relies on EPA emissions factors, not actual emissions - This obscures the fact that Christie killed DEP’s proposed greenhouse gas emission monitoring and reporting rule

The DEP Report is based - and heavily reliant on – fuel use data from the Energy Information Administration and various EPA greenhouse gas emissions factors, not actual emissions data.

This reliance on emissions factors not only injects uncertainty into the inventory, but is masks the fact that Governor Christie killed DEP proposed emissions inventory monitoring and reporting rule, which would greatly improve the inventory by providing real actual emissions (see:   CHRISTIE SHREDS NEW JERSEY CLIMATE CHANGE PROGRAMS — Kills Emission Reporting, Diverts Green Energy Fund & Defunds Climate Office

4)  Alleged emissions reductions are exceeded by the 5% undertainty factor, adjustments in methods, and dubious assumptions

The DEP Report estimates that 2008 emissions are 124.9 MMT, down from 2007 by 11 million metric tons of CO2 equivalent.

This 11 MMT estimate is transparently  qualified with this caveat in a footnote to the staff Report:

All numbers are estimates; uncertainty of totals is likely in range of plus or minus 5 percent.

Thus, a 5% uncertainty factor  is about +/- 6.2 MMT, or more than half of the estimated 2008 reductions. The estimates should have been provided as a range, not a numeric value, e.g. as  118.7 – 131.1 MMT (+/- 6.2)

The DEP press release reports a numeric value and lacks this caveat. This elides uncertainty and thereby misleads about the accuracy and reliability of the inventory’s estimates.

Furthermore, the 2008 Report is based on various adjustments in methodology. The changes all have the effect of reducing emissions. For example, changes in methods result in reductions of 3.5 MMT for forest sequestration.

Thus, uncertaintly and changes in methods may actually account for LARGER than reported emissions reductions. Actual real emissions may have increased. 

5)  Adjustments to methodology from prior inventories clouds results and undermines trend analysis  

The DEP Report transparently concedes this set of problems and attemtps to address it – the DEP press release does not.

6) There is selective and biased adjustments, all of which lower emissions but ignore increases in emissions

Importantly, the DEP estimates that significant emissions reductions may have occured due to fuel switching from coal to natural gas. Yet the Report fails to consider that EPA recently revised its GHG emissions factors for natural gas, making them essentially the same as coal. (see: Climate Benefits of Natural Gas May Be Overstated)

Use of EPA’s current revised natural gas emissions factors very likely would signifciantly increase estimated electric sector and total emissions. 

7) forest sequestration estimate is not fully documented and contradicted by forest loss and land development data

The DEP report estimates that carbon is being “sequestered” in forests and soil – and that this has increased since 1990.

Yet, for many years, NJ has been losing 15,000 – 20,000 acres per year to development - including forests, wetlands, farms, vegetation, and soils that store carbon.

I don’t have the expertise or time to review the Rutgers study and DEP’s very confusing Appendix A “explanation” of this apparently glaring conflict, so let’s just say is injects serious doubt into the land clearing emisions (1.7 MMT) and sequestration estimates (7.6 MMT).

8. Electric sector fuel switching to natural gas estimate not documented and ignores EPA’s increase in emissions factors for natural gas

Natural gas emission factors are far too low – see point #6 above.

9)  Garbage incineration emissions reduced by 60% based on a dubious assumption

DEP subtracts 60% of garbage incinerator emissions (0.5 MMT) resulting from burning of paper on the highly dubious assumption that paper is manufactured from trees harvested in sustainable forests. Right.

10)  conflict and possible error in forest sequestration data reported in Appendix A

Table 1 (page 4) estimates forest carbon sequestration at -7.6 MMT, but Appendix A seems to report -4 MMT. Either I’m reading this wrong or there is an error.

Aside from delving into the weeds to raise these technical issues, the larger problem is that the simultaneous release of a DEP press release - which conflicts with Gov.’s conclusions for RGGI withdrawal - needlessly creates nothing but deep confusion.

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