Christie Hijacks State Plan – DEP’s Bob Martin: A “Paradigm Shift”
Planning Commission Drives the Getaway Car
DEP Commissioner Bob Martin defends Christie Plan as a "paradigm shift"
[Update: 11/15/11 – Tom Johnson at NJ Spotlight does a nice job, see: Agency Approves Strategic Growth Plan Without Specifying Where the Growth Will Be – ]
Something truly extraordinary and unprecedented (in my recollection) happened in Trenton today.
The State Planning Commission formally approved – via unanimous votes – the following:
- Resolution No. 2011-06 Approval of Impact Assessment
- Resolution No. 2011-07Â Approval of The Statement Of Agreements and Disagreements (SAD) and Statewide Issue Response Team (SWIRT) Report and Completion Of The Cross-Acceptance Process (hit this link for those documents)
- Resolution No. 2011-08 Approval of Draft Final State Development and Redevelopment Plan and Draft Infrastructure Needs Assessment for Distribution and Commencement of Final State Plan Approval
Now the extraordinary part:
1) The Commission voted to approve these three Resolutions WITHOUT the presentation of the draft Plan that was listed on the Commission’s agenda or ANY discussion of the Plan or the other key documents approved (SAD, SWIRT and Infrastructure Needs Assessment);
2)  The Commission voted to approve all three Resolutions PRIOR TO allowing public comment;
3) In the most mind bending and perverse move of all (and that is saying something in light of actions #1-2 above), the Commission approved an Impact Assessment (dated December 21, 2009) SAD and SWIRT that were based on a draft Plan the Commission abandoned. The documents approved had nothing to do with the draft Final Plan they approved!
After the Commission approved the Resolutions, they allowed public testimony, but set a strict, arbitrary, and totally unnecessary 3 minute limit on testimony (only 10 people testified and the hearing adjourned before the 9:30 – 11:30 am hearing time published).
Bait and switch is too kind a description – how can you approve an assessment and cross acceptance Reports from 21 counties on a version of the Plan that no longer exists?
Even Wilma Frey of the moderate NJ Conservation Foundation (NJCF) said that those assessments “had no relevance” to the Christie Strategic Plan and called the Commission’s actions “intellectually dishonest“. (NJCF Executive Director Michele Byers was a member of the SPC for 10 years or more).
Sandy Batty of the Association of NJ Environmental Commissions (ANJEC) raised several concerns, the most important being that the local government officials and environmental commissions she works with had never even heard of the Christie Strategic Plan, never mind had an opportunity to review and comment on it.
Other environmental groups that have worked on State Plan issues for many years offered major criticisms, including the NJ Chapter of  Sierra Club, the American Littoral Society (ALS), and Stonybrook Millstone Watershed Assc.
As I wrote previously, the Christie Plan abandons both the State Plan Policy Map and the Cross Acceptance/Municipal Plan Endorsement process elements of the prior State Plan.
Hundreds of NJ Towns and thousands of residents had spent countless hours in the cross acceptance process, seeking to bring local Master Plans and zoning maps adopted under the Municipal Land Use Law (MLUL) in line with the State Plan.
All of that effort now is for naught, as the Christie Strategic Plan just abandoned the cross acceptance process, Â as well as the State Plan policy map.
[Update: funny, I don’t ever recall the Legislature adopting amendments to the State Planning Act to make this policy shift:
Traditional statewide land use planning must give way to strategic, action-oriented planning that integrates all relevant State resources. A conscious shift from managing growth to planning for physical change is also required. Coordinated investment will be the foundation for a new model that recognizes market conditions as a significant driver for change. (page 6)
I testified briefly to make a few general points:
- The Christie Strategic Plan abandons all non-market values
Planning, as an intellectual tradition and a profession, is informed by broad non-market values which are rooted in the concept of the public interest.
These values include beauty, fairness/equity, public health, natural resource conservation, and democratic participation in government processes.
Those values are encoded in the APA Code of Professional ethics and embedded in the State Planning Act pursuant to which the State Plan is adopted.
Yet the Christie Plan would replace the State Development and Redevelopment Plan (SDRP) with a singularly economic development oriented Strategic Plan that makes a mockery of non-market planning values and notions of the public interest.
The State Planning Act (SPA) authorizes the State Planning Commission to adopt a State Development and Redevelopment Plan (SDDRP) (see statutory objectives for the SDRP @ § 52:18A-200. ).
The SPA does not authorize or call for a narrow “strategic plan” or economic development strategy the Christie Administration is foisting on the State Planning process.
Of course Governor Christie, as Chief Executive, is empowered to issue Executive Orders and enact his own State Strategic Plan.
But he may not call that Plan the SDRP or hijack the State Planning Commission and the SDRP planning process to do so.
- The Resolutions are a Sham because they Approve Impact and Infrastructure Assessments that were based on the old State Plan. That Plan has been rejected by the Commission and replaced with the Strategic Plan
The Impact Assessment and Infrastructure Assessment documents are dated December 2009 (prior to the Christie Administration, which took office in January 2010).
Since then, the prior version of the State Plan was abandoned, rendering these assessments meaningless.
The State Planing Commission is now misleading the public by creating a false appearance that these prior assessments are based on the entirely different Christie Strategic Plan.
Wilma Frey said it best – this is “intellectually dishonest” (and shabby to boot!).
I addition, although the assessments make findings about reductions in air pollution, and water pollution, conservation of more than 50,000 acres of land, deep reductions in greenhouse gas emissions, the assessment documents fail to consider or to base those findings on facts in specific and directly relevant DEP functional plans.
The assessments fail to mention or incorporate the laws, policies, and regulations in applicable DEP functional Plans, including federally delegated State Implementation Plan ((air quality); Water Quality Management Plan or the State law mandated Water Supply Master Plan and Global Warming Response Act implementation plan, among others (there is a federal law structure transportation planning process that is ignored as well).
Worse, the Christie Plan requires that all State agencies, such as DEP, align their functional plans and program regulations with the Strategic Plan.
At a prior meeting of the State Plan Development Committee, DEP Assistant Commissioner Siekerka called this alignment process the “deconflicting” of DEP regulations.
Working in concert with the DEP proposed waiver rule, the State agency alignment process has a huge potential to represent an across the board rollback of DEP regulations, and result in violations of state and federal laws, which DO NOT recognize the State Planning Act or Christie EO 78. (more to follow specifically on this set of issues).
As I wrote previously, the Christie Plan explicitly criticizes and rejects the DEP WQMP program and Landscape Project Map.
The Landscape Project is one of the few positive developments of the Whitman DEP under Bob Shinn.
To his credit, Shinn emphasized mapping initiatives, cartographic expertise, technology, and development of “geographic information system” (GIS) capabilities at DEP.
The Christie Strategic Plan was supported by NJ Future, NJ Chapter of the American Planning Association (APA), the NJ Farm Bureau (on behalf of “landowners”); and a group called PlanSmart NJ. (more to follow on the NJ APA approval, which I feel is as important and unprofessional as the recent American Psychological Association’s ethics debate about psychologists who supported torture at Guantanamo Bay).
How can the Christie Plan be credible without either a Map or location criteria to apply the policies? How can a professional planner embrace that concept?
A I said before, that’s equivalent to writing the Plan in invisible ink.
[Update: after today’s hearing, I had a brief chance to ask a Ms. Mercer, who delivered the NJ APA testimony and is a former planner with the former  Office of Smart Growth, about the NJ APA review process. I also took strong exception to their support and several statements Ms. Mercer made during our brief conversation. I advised that although I was not a licensed PP, I wanted to open a dialogue to understand how a professional planning organization could possibly have supported the Christie Plan the SPC approved in draft form today.
So, not surprisingly, I just got an email from the  President of NJ APA, taking “some exception to to your recent opinion about our organization’s position”.
I assume this is not targeted at my characterization of their testimony (which I merely said “supported” the Christie Plan), but rather to other controversial issues I raised above.
Without going into that discussion here (as I said, more to follow), let me just say that I am pleased to open a dialogue and for now will post this ink to the NJ APA comments of Nov. 13. – end update]
Here’s a list of defects identified in a press release by NJ Sierra Club:
Violates State Planning Act- The Strategic Plan violates the State Planning Act because the Act calls for natural resource protection, protection of open space, with the environment and public health beings its main goals as we as infill and redevelopment as its priorities.  However the State Strategic Plan trumps growth over our resources. The State Plan itself is supposed to be a balance between growth areas and non growth areas while Strategic Plan is all about growth. Under the State Planning Act the State Plan is supposed to be based on other plans, but under this plan all other agencies plans are trumped by the Strategic Plan in violation of the Act.
Repeals Water Quality Management Rules – Attacks the Water Quality Management rules (WQMR) stating it hinders the ability of municipalities to have economic growth because it limits development in environmentally sensitive areas. Also these plans regulate septic for the first time with a third of New Jersey septic when tested shows levels of pollution from over development makes them more important.
Eliminates Landscape Project – The award winning Landscape Project is being threatened since the Governor wants to eliminate it because it is an important environmental planning tool and can be used to repeal numerous regulations. These regulations include flood hazard, stream buffer rules, sewers, wetlands, Highlands, Pinelands and habitat protections for endangered species.
Weakens Environmental Protections -Â Â Economic considerations are supposed to trump environmental protections and public health. The Plan states that all agencies plans and rules have to promote economic growth even in conflict with the environment. These include coastal rules CAFRA, Wetlands protection and Air Toxic rules. We believe this will also violate laws like the Clean Air Act, Clean Water Act, and even State Planning Act.
Removes Nongrowth  Areas – The State Planning Act prioritizes protecting environmentally sensitive areas and targeting growth for redevelopment while the State Strategic Plan only includes growth areas. The State Planning Act takes input from ‘other plans’, but under the Strategic Plan those plans are subservient to State Strategic Plan. Also the Plan eliminated Planning areas 4 and 5. The Strategic Plan clearly violates the State Planning Act.
Blocks Green Acres Funds – Under this Plan if a town or county wanted to buy a piece of property for open space that was in a growth area they would not be able to get Green Acres funds.  Also if Green Acres itself wanted to buy an important piece property in a growth area they would not be able to purchase it either. Green Acres plan and funding mechanism would be subservient to the State Strategic Plan. Many of our green acres acquisitions was proposed for development and growth areas and this would block those key acquisitions. Under this Plan would not be able to buy property in a growth area, which will have detrimental impact particularly in urban areas.
Weakening Highlands and Pinelands Protections – In the Highlands and Pinelands the ‘existing community areas’ are now growth areas in this Plan promoting development. We believe that the Strategic Plan will be used to promote more development in the Highlands and Pinelands undermining their Master Plans violating both those laws.
Open Space -Â Preservation of open space and natural resource are based on fee simple acquisition only this Plan does not call for preservation of natural resources through regulation or planning.
Executive Order 78 -Â Implementation of the plan is already underway before the public has chance to review. This EO takes the power away from the State Planning Commission and gives it to this new group in doing so violates the State Planning Act. Clearly stated this is a continuation of Red Tape Review designed to weaken standards and environmental protections.
Attacks on Labor & Civil Service – The Plan also goes after labor and civil service, which has nothing to do with planning
Super Commission – State Strategic Plan and Executive Order is under the Business Action Center not under any planning agency. This sets up a super commission chaired by the Lieutenant Governor acting as if she is a lobbyist for developers.
As you are aware (and have repeatedly reported)this is not the first time the Christie Administration has made a run on dismanteling the state’s environmental protections (originally it was DEP as a whole, then the Administration got cute and started to piecemeal cut). How long can this go on without the populace putting a stop to the bulldozer? So – do we change the state’s motto to be “Development ho!”? Question-is the ‘plan’ to promote development anywhere so builders make a profit and create jobs? If so …who’s supposed to buy these houses being constructed? Wasn’t there a report that identified that residential housing was the most inefficient land use as it required many more services than generated by the assessed taxes (those that are supposed to be reduced)? I’m at a loss – I guess I’ll join the NJ State Agency Administrators (nee DEP)that live in Pennsylvania so I can sleep at night.
@Clorinda Montalvo
Thanks for commenting – how long can this go on? I don’t know, but a couple of things must change before we can stop the Christie onslaught:
1) environmental groups that are working with the Administration and providing them cover in the media must immediately cease and repudiate their prior disgraceful conduct – this is primarily NJ Environmental Federation, but there are others who have elevated their own organization’s single pet cause above the a lager statewide environmental interest. Advocates need to approach the NJEF Board and NJEF funders to make this argument;
2) we need to do a lot more education of the press and citizens about the damaging consequences of the Governor’s absurd pro economic development policies.
3) we need more courageous professionals at DEP to engage in “anonymous activism” that PEER promotes – see:
http://www.peer.org/about/how.php
4) ENGOs need to make higher demands of the Democratic Party, instead of setting the bar so low or giving them a pass
5) environmental groups have to get out of their silos and join other progressive causes -see Naomi Klein’s excellent essay:
http://www.thenation.com/article/164497/capitalism-vs-climate
And it is not just the developers that Christie is providing favors too – Big pharma, chemical, and other industries that seek DEP favors are given preferential treatment.
well we can all assume that Irene Kropp was not there today. Shes with her new husband Brian Horne, who is the owner of the Henery Harris Landfill in Mullica Hill. Before her promotion last year she and Horne were quietly involved. Mr. Horne is saying that the two will be retiring to his Florida condo very soon. Who will replace Irene? is Irene now a landfill owner threw marraige? How many questions can we ask, and what can we assume?
The Landscape Project designates 47% of the entire State of New Jersey as habitat for threatened and endangered species – that is 47% of the entire land mass of New Jersey, of both developed and undeveloped lands.
@Al Solomon
Al – please support that claim with evidence and links to sources.
For readers, Al left out this fact (from DEP fact sheet):
“Further, in the context of the various land use regulations, habitat patches ranked 3, 4, or 5 in the Landscape Project maps are not determinative but are used as guidance – habitat warranting protection under the Department’s land use regulations is not always present in the areas mapped and actual habitat suitability is determined on a case by case basis.”
http://www.state.nj.us/dep/fgw/ensp/landscape/landscape_faqs.pdf
It was kind of Bill to cite the Landscape FAQs as the source of my previous post. As you can see from the Landscape FAQs, 47% of the State’s entire land mass is ranked 3, 4 and 5 in the Landscape Maps – meaning that there is a DEP presumption that 47% of the State’s entire land mass is habitat for threatened and endangered species.
But Bill correctly points out that beyond the 47% there are additional areas that are not ranked 3, 4 and 5 under the Landscape Project but that may be also be suitable habitat for T&E species and would thus warrant protection. As DEP notes in the FAQ “habitat warranting protection under the Department’s land use regulations is not always present in the areas mappedâ€.
Of course, some areas that are not habitat are mistakenly ranked 3, 4 and 5, and perhaps one can convince DEP to fix the mistake after spending $$KK together with the right political backing. Good luck to the losers who’s property happens to be “in the other half of the Stateâ€.
More importantly if you were to measure the percent of lands ranked 3, 4 and 5 against undeveloped areas only, you probably have around 65%+ of undeveloped lands in the state designated as Ranks 3, 4 and 5 under the Landscape Maps.
According to DEP’s online GIS system, 29.2% of the State is categorized as urban land use, 70.8% is categorized as non-urban land use.
It is a fair assumption that there are no urban areas ranked 3, 4 and 5 under the Landscape Project. Hence it would be also be fair to conclude that 66.3% of the non-urban areas in the State are ranked 3, 4 and 5. (47 / 70.8 = 66.3%)
One just has to wonder, 47% of the State = T&E habitat!?
@Al Solomon
Al – please stop misleading my readers.
The basic point you fail to note is that Landscape 3,4, and 5 are NOT regulatory and do not limit development.
As such, those DEP designations have no real consequence, other than aspiration.
Regardless, DEP regulations are not the cause of the real estate, hosting and commercial office park market development collapses.
And – ideally – if habitat and species were not being destroyed – 100% of NJ would be suitable habitat
It is a GOOD THING to have suitable habitat.
What do you mean “not regulatory”?! It seems like YOU are the one misleading your readers. The whole purpose of the Landscape Project is to regulate, regulate and regulate! The Landscape Project is in fact used in the following DEP REGULATIONS!
Coastal Permit Program Rules (N.J.A.C. 7:7)
Coastal Zone Management Rules (N.J.A.C. 7:7E)
Freshwater Wetlands Protection Act Rules (N.J.A.C. 7:7A)
Flood Hazard Area Control Act Rules (N.J.A.C. 7:13)
Highlands Water Protection and Planning Act Rules (N.J.A.C. 7:38)
Water Quality Management Planning Rules (N.J.A.C. 7:15)
Send my warm regards to Alice in Wonderland!
@Al Solomon
Al – assuming you post here in good faith;
But you must have reading comprehension problems.
The above DEP words “not determinative” and “used as guidance” mean that 3,4, and 5 classifications are NOT regulatory.
The permit programs you cite apply to 1 and 2.
You are applying rules for apples to oranges, and thereby misleading my readers.
Please stop, or I will not approve further misinformation.
Bill-
Yes, there is a small margin of error in the Landscape Maps and DEP allows applicants to submit information showing that the certain areas were mapped in area. That is what DEP means by “not determinative”. However, the Landscape Project is by an large reference in the various regulations I cite:
For example, here is the Freshwater Wetlands Protection Act Rule
at 7:7A-2.4
…
(b) A freshwater wetland of exceptional resource value, or exceptional resource value wetland, is a freshwater wetland which:
1. Discharges into FW1 or FW2 trout production waters or their tributaries;
2. Is a present habitat for threatened or endangered species; or
3. Is a documented habitat for threatened or endangered species, and which remains suitable for breeding, resting, or feeding by these species during the normal period these species would use the habitat.
(c) The Department identifies present or documented habitat for threatened or endangered species for purposes of (b) above using the Landscape Project method, which focuses on habitat areas required to support local populations of threatened or endangered wildlife species. The details of this method are described in the Division of Land Use Regulation freshwater wetlands technical manual, available from the Department’s Office of Maps and Publications at the address in N.J.A.C. 7:7A-1.3. An applicant may request that a documented habitat not result in
the classification of a freshwater wetland as a freshwater wetland of exceptional resource value. Such a request shall include a demonstration of the long-term loss of one or more habitat requirements of the specific documented threatened or endangered species, including, but not limited to, wetlands size or overall habitat size, water quality, or vegetation density or diversity. Upon such a request, the Department shall review all available information, and shall make a
final classification of the wetland.
….
The Water Quality Management Planning Rules at 7:15-5.24(b) state:
…
(b) Environmentally sensitive areas shall be defined based on a composite geographic information systems (GIS) analysis, as any contiguous area of 25 acres or larger consisting of any of the following features alone or in combination:
1. Areas mapped as endangered or threatened wildlife species habitat on the
Department’s Landscape Maps of Habitat for Endangered, Threatened or Other Priority Species.
….
The WQMP Rules at 7:15-5.26, further state:
(a) Where an area is excluded from a sewer service area in accordance with N.J.A.C.
7:15-5.24 on the basis that it is within habitat patch of Rank 3, 4 or 5 on the Department’s Landscape Maps of Habitat for Endangered, Threatened and Other Priority Wildlife, an applicant may seek a Habitat Suitability Determination from the Department if it wishes to rebut the presumption that a habitat patch of Rank 3, 4 or 5 on the Department’s Landscape Maps of Habitat for Endangered, Threatened and Other Priority Wildlife is accurate.
Bill-
Yes, DEP allows you to “rebut the presumption that a habitat patch of Rank 3, 4 or 5 on the Department’s Landscape Maps of Habitat for Endangered, Threatened and Other Priority Wildlife is accurate.” But does that in any way diminish the far reaching effect of the Landscape Maps?
Most puzzling me about your response: Are you somehow suggesting that the percent of the State considered habitat for threatened and endangered species is far less than 47%? And is the basis for your suggestion because DEP is willing to acknowledge that its maps are not “determinative”? Of course there may be areas not mapped as T&E habitat that may have been inadvertently omitted.
Please stop throwing sand in the eyes of your readers. It does not take much to figure out that the Landscape Project is fundamentally flawed.
April 7, 2011 was the deadline for counties to submit WMPs. Only Hudson and Monmouth county have submitted WMPs.
The DEP’s WQMP Rules at 7:15-8.1 states “wastewater service area designations shall
be withdrawn in areas which fail to adopt and maintain a wastewater management plan in accordance with the requirements of N.J.A.C. 7:15-5.2(b), 5.13 and 5.23.”
QUESTION
Why aren’t any of the environmental groups suing the DEP to enforce this Rule? Isn’t this an open shut case? Isn’t DEP plainly ignoring its WQMP mandate?
@Al Solomon
Al –
1. I am not a scientist, but I understand that the Landscape Project was peer reviewed:
“Methodologies described in this document have been peer reviewed by:
Dr. James Applegate, Rutgers University; Dr. Joanna Burger, Rutgers University; Dr. Tim Casey, Rutgers University; Dr. David Ehrenfeld, Rutgers University; Dr. Joan Ehrenfeld, Rutgers University; Dr. David Fairbrothers, Rutgers University; Dr. Michael Gochfeld, Rutgers University; Ernie Hahn, NJ Department of Environmental Protection, Division of Land Use Regulation; Dr. Colleen Hatfield, Rutgers University; Dr. Marjorie Kaplan, NJ Department of Environmental Protection, Division of Science, Research and Technol- ogy; Dr. Michael W. Klemens, Wildlife Conservation Society; Kim Laidig, NJ Pinelands Commission; Dr. Richard Lathrop, Rutgers University; Trish Maggio, NJ Office of State Planning; Dr. Peter Morin, Rutgers University; Jessica Sanchez, NJ Office of State Planning; Larry Torok, NJ Department of Environmental Pro- tection, Division of Land Use Regulation; and Dr. Robert Zampella, NJ Pinelands Commission.”
http://www.state.nj.us/dep/fgw/ensp/landscape/lp_report_2_1.pdf
Please state your specific scientific objection – it seems like you are saying it over-classifies habitat. That sounds more like a economic or policy concern.
2. Here is the purpose of the LP:
“The Landscape Project has been designed to provide users with peer-reviewed, scientifically sound information that is easily accessible and can be integrated with the planning, protection and land management programs of non-governmental organizations and private landowners and at every level
of government — federal, state, county and municipal. As in Version 1.0, Version 2.1 of the Landscape Project has gone through an extensive peer review process. Landscape maps and overlays provide a basis for proactive planning such as the development of local habitat protection ordinances, zoning to protect critical wildlife areas, management guidelines for imperiled species conservation on public and private lands, and land acquisition projects.
Most importantly, the critical area information provided by the Landscape Project can be used for planning purposes before any actions such as proposed devel- opment, resource extraction (eg. timber harvests) or conservation measures occur. Proactive planning with accurate, and legally and scientifically sound informa- tion will result in less conflict. Less time will be wasted, and less money spent, attempting to resolve after-the- fact endangered and threatened species issues.”
What specifically do you find misguided and fundamentally flawed here?
3. With respect to regulations you cite, the Landscape Project maps serve to
a) enhance wetlands values (a policy call) and provide additional buffer protections (150 feet).
Give the ecological and economic value of wetlands and the historical and continuing lis of wetlands, what specifically do you object to here?
b) limit extension of sewer service that promotes high density development in environmentally sensitive lands.
Again, given the land loss, infrastructure costs involved, the huge deficit in existing infrastructure maintenance, and far superior alternative redevelopment locations, (and the current surplus in housing/commercial capacity due to the market collapse) are you arguing we need to spend scare dollars extending sewers into environmentally sensitive lands to build uneconomic projects?
Because we are in a policy argument, you must be clear on what your objectives are – what your values are – instead of using slogans like “fundamentally flawed” to attack DEP LP.
The
@Al Solomon
First pint of yours I agree with – I am not a lawyer, but it sure looks like DEP is breaking the law!
But I do know that it is almost impossible to get a court to rule that DEP must enforce its own regulations and environmental laws.
In fact, there are very few “mandatory duties” where such litigation is a slam dunk.
And, you and readers should know that there is a current policy at DEP to IGNORE legal mandates, wheterh in stature or DEP regulations.
s
There is FLAGRANT LAWLESSNESS and lack of respect for rule of law by Bob Martin, Irene Kropp. Ray Cantor, and the rest of the Christie/Martin management team.
They have openly stated that they will not enforce (or even implement) legal requirements they do not see as a priority (or consider a barrier to economic development) in the presence of many DEP employees.
This is the philosophy and policy behind the DEP waiver proposal – Martin wants to pick and choose what rules/laws to apply.
Reading between the lines: Silence of Sierra Club and their like regarding DEP’s failure to enforce its WQMP mandate; No lawsuits filed; No public hearings scheduled for WMP draft plans. Silence. Silence. Silence. In fact, DEP Commissioner, Bob Martin, at a recent luncheon hosted by the NJBIA, talked extensively about changes at DEP and how the regulations are being revisited, mentioning FWPA, C1 rules, CAFRA. But WQM regulations were completely off topic.
Are the environmentalists asleep at the wheel, or is something going on behind the scenes – i.e. secret political negotiations?