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U.S. EPA to Investigate Why Key Air Monitor Went Offline for Nearly Three Days During Bridgegate

February 27th, 2014 No comments

[Intro note just to clarify the misleading headline in Star Ledger followup story: Per our request and EPA IG referral, EPA DID investigate the DEP monitoring station and found no problems from a regulatory perspective or violations of NAAQS, although they did not respond to all the questions we raised and their response evaded the basic question about whether people at the street level in Ft. Lee were exposed to unsafe levels of air pollution and whether the EPA/DEP monitoring network is capable of answering these kind of questions. ]

Update #4 – 11 pm – This will take a full post to explain, but in the meantime, here’s what a Rutgers professor said about the monitoring station in question:(link to story)

They’re missing data for 2 1/2 days – that’s weird,” says Ann Marie Carlton, an assistant professor at Rutgers University who studies air quality.

I was really, really shocked when I saw there was no data. You might see a monitor go offline for a day because they’re cleaning it or doing maintenance or calibration, but for it go down for this many days is intriguing.

Here what other experts said about the distance issue:

Thurston, Pope and others cautioned against reading too much into the monitor’s data.

“[Pollutant] concentrations get diluted pretty fast as you get away from the sources,” Rutgers environmental science professor Barbara Turpin says, arguing that the high PM2.5 levels measured by the Jersey City and Newark monitors, sitting so far from the George Washington Bridge, do not necessarily show the pollution levels being generated by the traffic jam.

Still, Carlton says, the only apparent change in the area from Sept. 9 to 12 was the traffic jam.

“If we think about what emits particles – Burger King, other industries like that – there was no new Burger King that started operating and caused that to happen,” she says. “But we know that particles can come from cars, and that’s the only thing that happened that was different.” – end update]

Update # 3 2/28/14 – 5 pm – Just got a reply from EPA Region 2 – According to EPA, although PM 2.5 pollution levels increased significantly in the area during the week of Bridgegate, there was no air quality problem with respect to PM 2.5 NAAQS compliance (no mention of ozone, or local “hot spot” ambient conditions) and NJ DEP is in compliance with EPA monitoring requirements (and no explanation of why monitoring station was inoperable or whether NJ DEP notified EPA or was required to notify EPA) full EPA reply available upon request, I have as a pdf – no link yet):

* We were in error and stand corrected on one point – the down monitoring station was NOT “closest to the GWB” as we stated. There are closer stations, including one in Ft. Lee. However, the Ft. Lee monitoring station is NOT listed in DEP website air monitoring network, so I had no way of knowing that. Second, we based the “closest:” claim on a priorJan. 22, 2014  national news report.

Update # 2 – there are legitimate questions and criticisms that the monitoring device was 11 – 12 miles away in Jersey City and could not havedetected the GWB traffic emissions. My understanding is that mobile source dispersion models rarely extend beyond 1,000 meters to measure impacts. I never claimed that the monitoring device was designed to detect GWB emission, but only  that it was the closest monitoring device to GWB – and it could have shown some regional impact, depending on conditions.

[Note: it was hot the week of 9/9/13, so regional ozone formation from mobile source emissions at GWB is a definite possibility. But the Jersey City FH monitoring station only measured PM 2.5 (fine particulate) not ozone.]

My response: 1) no doubt that ground level “hot spots” existed (in Ft. Lee where kids were stuck in traffic) exceeded EPA health based NAAQS for criteria pollutants, mostly like PM 2.5, CO, and perhaps ozone.; 2) DEP uses a statewide monitoring network that measures regional, not local, air quality conditions. Depending on the weather (i.e. hot sumer day) some of the pollutants from the mobile sources is regional and forms ozone – don’t recall what the weather was like on 9/11/13. ; 3) If local hot spots exist, NJ DEP’s monitoring network fails to detect them. ,Yet DEP still relies on  this network as “representative” of Statewide conditions when demonstrating compliance with NAAQS. So, DEP can’t have it both ways by saying the Jersey CIty station could not have detected GWB emissions yet also saying the Jersey CIty station reflects representative local and regional conditions – bottom line: we need more monitoring devices that more accurately detect “local hot spots”.

Update: 2/28/14: Tom Johnson NJ Spotlight story: BRIDGEGATE GETS DIRTIER: AIR-QUALITY MONITOR WAS OFFLINE DURING TRAFFIC JAM – end update.]

This is either just an amazing coincidence or evidence of an attempt to coverup the impacts of the GWB lane closures.

But even if it had nothing to do with Bridgegate, EPA should have been notified about the situation, because continuous air monitoring is required under the federal Clean Air Act.

We filed a complaint with the EPA Inspector General because DEP refused to provide an explanation and referred media inquiries to the Governor’s Office.

DEP is solely responsible for operating the State air monitoring network, so they should have provided a straightforward explanation about why the monitoring station was down – very odd for them to refer a strictly technical matter like this to the Gov. Office.

But, again, there is an explanation – it is possible that the Gov. Office issued a State government wide order that all media inquiries about the GWB scandal be referred to the Gov. press Office.

Let’s see if EPA can get a better answer from DEP than the media did – we’ll keep you posted.   From our friends at PEER:

Press Release

For Immediate Release:  Thursday, February 27, 2014

Contact:  Bill Wolfe (609) 397-4861; Kirsten Stade (202) 265-7337

Who Turned Off Air Pollution Monitor During Bridge Closure?

U.S. EPA to Investigate Why Key Air Monitor Went Offline for Nearly Three Days

Trenton — Through most of the period when lane closures on the George Washington Bridge ordered by associates of New Jersey Governor Chris Christie were in effect the federally required air quality monitor closest to the bridge was inoperative.  At the request of Public Employees for Environmental Responsibility (PEER), the U.S. Environmental Protection Agency (EPA) Office of Inspector General (IG) has opened an inquiry into who and what was behind the shutdown of the measuring device as thousands of vehicles idled for hours on the busiest motor-vehicle bridge in the world.

The closure of local access lanes on the George Washington Bridge for traffic entering from Fort Lee and the surrounding communities lasted from the morning of September 9, 2013 through the 13th.  On the night of September 8th and continuing for the next two-and-half days, the air quality monitor operated by the New Jersey Department of Environmental Protection (DEP) closest to the bridge ceased reporting data about the level of particulates in the air.  DEP has not issued an explanation for this outage, instead referring media calls to Gov. Christie’s press office.

These air pollution monitoring devices are required under the federal Clean Air Act and their use by state agencies takes place under regulations overseen by EPA.  Their purpose is to measure the amount of diesel, oil and other fuel particles in the air.  These particles are so small that they penetrate the deepest recesses of the lungs and are linked to asthma, other respiratory diseases and premature death.

Federal regulations require that these air pollution monitors operate continuously except for “routine maintenance” or “instrument calibration” without permission from EPA.  This particular monitor, located on top of a Jersey City firehouse, had previously experienced only very short outages.

“Public health safeguards, like pollution monitors, should be off-limits to political manipulation,” stated New Jersey PEER Director Bill Wolfe.  “Perhaps there is an innocent explanation for marooning thousands in a pollution Twilight Zone but no one in the Christie administration has yet to offer one.”

Readings from other monitors, as well as the shuttered monitor once it came back online, suggest that air quality reached unhealthy levels during the closure.  Particulate readings on the reopened monitor were more than twice the level it recorded before it was shut off.

Children are especially susceptible to lung damage from particulates.  Yet when one Christie official expressed concern about schoolchildren trapped on the bridge for hours, David Wildstein, a Christie-appointed Port Authority official, emailed in response: “They are the children of Buono voters.”

“This extended outage masked the health effects on those stuck on the bridge enduring hours of exhaust from idling vehicles,” Wolfe added.  “This act literally added injury to insult.”

PEER filed its request for investigation with the IG on January 31.  In a letter dated February 11, 2014, Special Agent Clay Brown, the IG “Hotline Manager,” indicated that EPA Region 2 which is supposed to oversee the Clean Air Act program in New Jersey, had been tasked with conducting an initial “review” and “Following this review, a determination will be made as to the most appropriate course of action.”

###

Read the complaint to the EPA IG

See IG reply

View federal requirement that monitors must be continually operating

Look at health concerns with particulates

Learn more about ambient air monitoring

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

 

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Why “Nobody Raised Their Hand”

February 26th, 2014 No comments

We’re Still Living On Chris Christie’s NJ Waterfront 

"On the Waterfront" - Crime Commission testimony scene

You just dug your own grave.

You’re dead on this waterfront, and every waterfront from Boston to New Orleans.

You don’t drive a truck, or a cab – you don’t push a bag of dreck.

You don’t work noplace! You’re dead! ~~~ “On the Waterfront” – (watch the Crime Commission scene)

 

I was stunned by a revealing and absolutely chilling quote by the DEP press Office in Mike Powell’s superb NY Times story yesterday:

In Plan to Dump Contaminated Soil, Classic New Jersey Politics Emerge

[…]

In a 2010 email, an [DEP] agency scientist noted that this project was “not sustainable” and that “developer/business profit driven motivation” fueled it.

In 2013, another agency expert offered that the proposal was “technically questionable.” Yet another scientist noted that if a flood washed through, the soil mound could collapse and “pose a threat to the environment or to the public health.” […]

Larry Hagna, (sic) a Department of Environmental Protection spokesman, said that the agency’s staff is no longer worried. The staff’s old emails — some written as recently as eight months ago — are yesterday’s news, he said. “We recently had said to the staff: ‘You’ve raised concerns. Does anyone remain in opposition?

Nobody,” he noted, “raised their hands.”

Indeed, nobody raised their hand.

And that, my friend, is the point.

But does anyone ever wonder why the many professionals on the inside of government who know about wrongdoing, corruption, and betrayal of the public interest rarely speak up?

Because dissent or disagreement is not tolerated in the Christie Administration.

Because DEP Commissioner Bob Martin – although slightly more sophisticated than Johnny  Friendly – is an intolerant, intimidating, vindictive bully – just like his boss.

Because the issues are complex, rarely black and white, and the press and the public have no appetite for complexity.

Because, in many quarters, there is a scientific and narrow technical culture at DEP that is loyal or deferential to management, discourages consideration of legitimate public policy discussion as “not my job”, and disrespects colleagues who are “advocates” who get labeled “troublemakers” or “difficult to work with”.

Because “the golden handcuffs” of a DEP career are sweet indeed – interesting and rewarding work, good salary and benefits, and job security.

Because if vindictive DEP managers want to make your life at work miserable, or destroy your career, or smear your character, they can do so with virtual impunity.

Because – as I learned in my own case – that while the whistleblower laws might look good on paper, they provide little to no effective protection for whistleblowers.

Because, like the scene above from “On the Waterfront”, when DEP managers do retaliate, they have Civil Service laws and time on their side.

If they trump up a criminal charge, like Official Misconduct, and convict on that charge, then the person convicted is blackballed – prohibited from working in the public sector in NJ for life. Put that on your resume.

The law and politics still work just like Johnny Friendly’s threat –  the current reality is that you don’t work no place – you’re dead.

And noplace is a tough place to be, particularly with a mortgage or a family to support – or a career or reputation to preserve.

So, the scumbags know that they have all the leverage and they use it with impunity, knowing that they incur little risk from the professionals in the know.

None of whom will raise their hands.

And its not just Gov. Christie and his minions who play this game in NJ – just look at the Obama Administration’s unprecedented war on whistleblowers and the media.

Even the Vatican is in on the game – a Frontline investigative piece last night Secrets of the Vatican, disclosed the fact that dossiers were kept on officials for blackmail to keep them quiet.

[and if they’re doing this stuff in the Vatican, can you imagine what’s going on behind the scenes in Wall Street, corporate america, or oil and gas energy companies?]

This is the corrupt institutional world we live in – from dirty deals on NJ dirt, to Kill List drones, to Vatican sex scandals.

Johnny Friendly and his corporate and political pals have won.

Once we admit that – and not until we admit that ugly reality – can we can begin to effectively struggle and fight back.

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Why Is Christie DEP Opposing Legislation to Update State Flood Maps?

February 25th, 2014 No comments

Yesterday, the Assembly Environment Committee released an important bill that would direct DEP to update decades old flood hazard maps, see A1726.

Last year, the bill was passed by the Assembly but died in the Senate, after DEP opposed the Senate version of the bill. On June 3, 2013:

DEP suggested amendments, one of which made sense (to set priorities based on flood risks). The other DEP amendment was designed to gut the bill by tying flood map updates to the availability of funds. When asked how much the map updates would cost, DEP repeated an inflated cost estimate of $82 million, based on $16,000 per mile and 5,000 river/stream miles.

Recall that in his December 3, 2012 testimony in response to Senator Gordon’s questions, DEP Commissioner Martin backed away from that and denied that this $81 million cost estimate (fiscal note) came from him. Martin now eats those words and doubles down, clearly an effort to derail the bill because he knows that the Gov. and legislators would never cough up that kind of money.

The issue of inland flooding has not gotten nearly the attention as coastal flooding in the wake of Sandy –

I wrote about those set of issues last year, see:

We hope this bill moves quickly and is put on the Governor’s desk as soon as possible so that DEP can get to work and the thousands of homes and businesses that currently are in flood zones and don’t know it can get insured and protected (and prospective purchasers can be warned of flood risks before buying property).

Similarly, updated DEP flood maps will limit new development in flood hazard areas.

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NJ Forests and Air Quality At Risk From Pending Legislation

February 25th, 2014 No comments

“Prescribed Burn” and “Forest Stewardship” bills are back

The Assembly Agriculture and Natural Resources Committee heard two forest related bills yesterday: the controversial “Forest Stewardship” bill that would allow commercial logging on State lands and the “prescribed burn” bill that would expand the current prescribed burn program (you can listen to the testimony here).

Tom Johnson at NJ Spotlight wrote about the Stewardship” bill (see: CONTROVERSIAL BILL COULD PERMIT COMMERCIAL LOGGING OF STATE FORESTS).

But Tom left some stuff out so I’ll just bullet a few points I and others made in testimony and then focus on the prescribed burn bill.

  • I)  Forest Stewardship bill – A1775

1. Original intent remains

I reminded the Committee that the original title was a “Forest Harvest” bill and the original intent was not disguised: it was to cut timber.

In fact, the Farm Bureau June 10, 2013 testimony reveals that objective (and this was after the bill was renamed from “harvest” to “stewardship”):

“In the early 1980′s, the state stopped participating in timber sales. So the state lands that were managed in timber, up to that point in time, were an important part of attracting the timber industry to the State. The State owns half or more of the wooded lands, so its been on the back of smaller producers to attract competition to the state. And what they’ve ended up with is the one guy who wants to come and cut in NJ, kind of setting the market price. And so we’ve had a depressed value of our wood products.

We see, by the State re-entering into a managed timbering process, that more vendors will be attracted  to come into the state and then they’ll pick up those smaller [private] parcels … and we’ll see an economic benefit to our state, for the private forest lands as well as the public lands, because landowners will have more options in how they do those managed cuts.

The other part of it is that pretty much since the State stopped timbering, there has been a decline of the overall forest health. It not a matter of what people envision when they see, like down south in Georgia timbering where they do paper cutting and take everything out. This is selective cutting. It’s choosing the best woods at the appropriate time. Removing older trees to let younger trees grow… creating appropriate breaks in the forest canopy to encourage diversity of wildlife . All of that is what goes into the stewardship plan.

And then its the ability of the State to recoup those costs through the sale of the timber. … 

With the increased participation by the state we will see increased competition amongst those that harvest these products and better prices  which them improves the overall wood and timber industry in the state.

As I noted last June, DEP forest managers share the same “commodity” oriented approach to forests, revealed in this chart and text:

Source: “Statewide Forest Assessment” NJDEP – (2010)

 An approximate, additional 652,800 cubic feet of wood are harvested on state lands annually for a total of approximately 2.1 million cubic feet harvested for commercial forestry annually. This is less than 4% of annual growth. Indicating that NJ’s timber resource is largely underutilized. 

As NJ’s forests mature and smaller trees grow into the larger size classes, the amount of sawtimber available on timberlands statewide is increasing as well.”   ~~~ NJ DEP “Statewide Forest Resource Assessment and Strategies” (2010)

2. Both the Governor and DEP rejected Forest Stewardship Council certification

I reminded the Committee that there were not only legal but institutional conflicts between DEP and FSC certification. If some view FSC as a safeguard, they are delusional – it’s not going to happen.

DEP made this perfectly clear in a June 10, 2013 letter to the Legislature – let me quote the pertinent text:

The DEP’s remaining concern would be a mandatory Forest Stewardship Council (FSC) certification required for any stewardship plans we develop … While we respect FSC and recommended incorporating the FSC standards into the legislation, this mandatory certification is an un-necessary and costly requirement.  The DEP is the steward of New Jersey’s environment; we do not need our work validated by somebody else. Moreover, this unnecessary requirement adds a significant financial cost to the program, which will approach approximately $100,000 in the first year.

3. Perverse incentives to log lands

Revenues generated from logging operations would be allocated back to the DEP forestry program. This is a bureaucratic incentive structure to log more state lands to support DEP staff. I’ve seen how this works for many years now in the various permit fee driven DEP programs. It is a formula for disaster.

4. Conflicts with allowable uses of State Lands purchased with Green Acres GSPTF bonds

A citizen activist named Bob Moss (I think with Sierra Club) testified that any commercial logging allowed by the bill on State lands purchased with Green Acres bond funds would be unconstitutional because the bond covenants and text of the authorizing ballot questions approved by the voters limits the use of purchased lands to conservation and recreational purposes.

5. Lack of Regulatory Safeguards

FSC standards and current DEP forestry management programs are not subject to regulation under various important NJ environmental laws that protect wetlands, water quality, soil erosion, steep slopes, flood hazards, and the Highlands Act.

The bill does not require that forestry activities comply with those law – that is a gaping loophole that must be closed.

[6. Real threats ignored – no afforestation or urban forestry policies or goals

The two biggest threats t NJ’s forests are climate change and developers’ bulldozers. Both are ignored.

In addition, the bill fails to include afforestation or urban forestry goals or policies – we should be encouraging afforestation of vacant and underutilized agricultural lands to increase NJ forest cover. Ditto for urban forestry, which has additional justification on climate change, air quality, and community aesthetics.]

II) “Prescribed burn” bill – A1275

This bill would authorize prescribed burning on public and private lands and eliminate important safeguards to protect  public health, environment, and property.

The bill was passed both houses last year but was pocket vetoed by Governor Christie.

While I support “prescribed burns” as  an ecological management tool in Pinelands forests (where it is scientifically justified and has the least public health, safety and nuisance conflicts due to low population density), the bill would apply statewide, including to north jersey hardwood forests adjacent to densely populated areas where signifiant public health, air quality, nuisance, and land use conflicts exist.

The bill is seriously flawed and I doubt that legislators considered or would support what the bill would do, particularly with respect to private property rights and liability standards.

I think EPA will object to the provisions of the bill that conflict with the Clean Air Act and gut DEP’s ability to enforce state air pollution control laws.

My sense is that this bill is being driven by certain conservation and farm groups who are unable to get private insurance to conduct burns on their property, and need this bill for liability protection.

There is a reason that the insurance industry will not insure “controlled burns” – they are dangerous!

As I wrote on June 2011: (This is what a “prescribed burn” looks like  -additional photos of an out of control burn are here)

It is not good public policy to pass such a bill.

The environmental groups supporting the bill were acting more in their own interests as private landowners seeking to avoid public accountability and liability, than stewards of the public interest.

In order to fix these major problems, I testified that the bill should be limited in scope to the Pinelands and to public lands, and that Sections 6 and Section 8 should be deleted (see below).

1. Not appropriate for north jersey forests and highly developed land use conflicts

I am not up to speed on the role of fire and the scientific and ecological rationale for controlled burns in north jersey hardwood forests.

But I am aware that controlled burns do get out of control and even if conducted fully under control raise major air quality, public safety, and nuisance conflicts due to high population density and road/traffic network in proximity to the forests.

In fact, last spring, a fireman was killed at a controlled burn at Round Valley State Park, see: Prosecutor: Thick smoke blinds driver who hit, killed N.J. fireman at Round Valley

2. Air quality issues

Smoke from fires is a significant source of air pollution, particularly fine particulate matter known as PM 2.5.

According to US EPA Guidance:

The major air pollutant of concern is the smoke produced. Smoke from prescribed fires is a complex mixture of carbon, tars, liquids, and different gases. This open combustion source produces particles of widely ranging size, depending to some extent on the rate of energy release of the fire. The major pollutants from wildland burning are particulate, carbon monoxide, and volatile organics. Nitrogen oxides are emitted at rates of from 1 to 4 g/kg burned, depending on combustion temperatures. Emissions of sulfur oxides are negligible.

Section 8.c. of the bill would eliminate DEP’s ability to enforce State and federal clean air laws by eliminating DEP jurisdiction and exempting controlled burns from air pollution control requirements:

c. Notwithstanding any State or local law, rule, regulation, ordinance, or resolution to the contrary, a prescribed burn conducted pursuant to this act, any rules and regulations adopted pursuant thereto, and an approved prescribed burn plan shall be deemed to not (1) be a source operation or source of an air contaminant, (2) be or tend to be injurious to human health or welfare, animal or plant life, or property, or (3) unreasonably interfere with the enjoyment of life or property, as those terms are used in the “Air Pollution Control Act (1954),” P.L.1954, c.212 (C.26:2C-1 et seq.), and any rules or regulations adopted pursuant thereto, or any similar provision of any municipal or county ordinance, resolution, or regulation. The provisions of this subsection shall also apply to smoke and ash caused by or arising from a prescribed burn. 

That would mean if a controlled burn created massive smoke related injuries (e.g. asthma attack or respiratory emergency) or nuisances, that local, country and state governments and citizens would have no recourse to pursue enforcement. That lack of accountability invites lax practices.

3. Eliminates common law protects and lowers liability and accountability standards

Section 8 also provides immunities and lowers the liability standard to a requirement that anyone injured by a controlled burn must demonstrate :”gross negligence”.

So, if your house were burned down or property damaged, you would probably not be able to sue to be compensated.

4. Violates private property rights

I am certainly no private property rights advocate, but even I was shocked by reading Section 6 of this bill.

I strongly doubt any legislator would publicly defend this section of the bill.

The bill would allow the NJ State Fire Marshall to trespass on your property and conduct a prescribed burn on your property, without your consent and over your objection.

If your property were damaged – e.g. barn burned down, crops destroy, animals killed –  the liability provisions in the bill would make it virtually impossible to sue to recover compensation for these damages.

I suggested that any controlled burns conducted on private property by State officials must be by consent of the land owner.

The sponsor, Assemblyman Dancer, promised to address these concerns and the bill was substituted for the version that passed both houses last legislative session on Jan 13 and was sent to the Governor.

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DEP Sandy Funding For Sewage Infrastructure Ignores Vulnerability and Risk Based Priorities

February 24th, 2014 No comments

DEP Funds Sewage Pump Station Replacement at  Lake Como 

Sewage Infrastructure Above Drinking Water Supply Intakes Is Highly Vulnerable and Poses Significant Risks

DEP’s Funding Priorities Not Based on Plans

DEP issued a press release today touting a $2.95 million bridge loan to replace and relocate a sewage pump station at Lake Como in Monmouth County, see:

CHRISTIE ADMINISTRATION TAKES ACTION TO PROTECT WATER AND WASTEWATER SYSTEMS AGAINST DISASTERS LIKE SANDY

TRENTON – The New Jersey Environmental Infrastructure Trust (NJEIT), working in partnership with the Department of Environmental Protection (DEP), has closed on its first-ever disaster-emergency bridge loan, a $2.95 million package that will pay for the replacement and relocation of a sewage pumping station at Monmouth County’s Lake Como that was damaged by Superstorm Sandy, DEP Commissioner Bob Martin announced today.

The announcement left me scratching my head in wonder: what the hell are they thinking about over at DEP?

DEP is prioritizing protection of Lake Como? A tiny 8 acre lake in Monmouth County. Are you kidding me?

What about all the highly vulernable sewage pump stations and infrastructure located along NJ’s rivers just upstream on drinking water supply intakes? Like the Raritan, Passaic, Pompton, and Delaware rivers where hundreds of sewage plants discharge pollution upstream of drinking water intakes. )see

As the entire nation just learned as a result of the West Virginia chemical spill – which shut down water supplies for hundreds of thousands of people for days –  drinking water supplies are at risk from upstream pollution sources.

NJ DEP should have learned this lesson from Sandy, where 94 sewage treatment plants and 400 community water supply systems were knocked out due to flooding or loss of electric power. As a result, we almost lost drinking water for major urbanized areas of north jersey, see:

What possible priority and risk is the Lake Como sewage pumping station compared to hundreds of other equally or more vulnerable infrastructure that could wipe out the water supply for hundreds of thousands of people?

This is nothing to brag about.

In fact, it illustrates DEP’ complete lack of priority and risk based infrastructure vulernability assessment, adaptation planning, and financial planning.

DEP’s absurdly self congratulatory press releases goes on to prove exactly that – i.e. DEP is not following a transparent and public vulnerability assessment and planning process based on rational criteria and standards:

The DEP and NJEIT are currently reviewing applications for short-term and long-term financing for a host of projects from other communities that include waterproofing of pumps and electrical equipment, installation of flood protection barriers and emergency generators, and studies to assess measures to prevent damage from floods and other disasters.

And finally, DEP ignores two important things:

  • 1) Under the federal Clean Water Act and the Safe Drinking Water Act, there already is a capital infrastructure needs assessment, priority setting, and financial planing process for water supply and wastewater infrastructure.

That process is transparent, public, and based on objective  criteria. The Legislature authorizes the DEP recommended funding priorities and project allocations. (i.e Intended Use Plans).

DEP ignored all that and reinvented the wheel – no, it is more accurate to stay that they eliminated the wheel.

There is no map, no destination, and no one is steering the ship.

  • 2) DEP issued permits for wastewater treatment & collection and water supply treatment & distribution systems already require emergency operations plans, including emergency backup power and infrastructure vulernability.

Most of those facilities either didn’t have emergency operational plans or had no ability to implement them.

Those permit requirements have been totally ignored by the water and sewer authorities and DEP did nothing to oversee or enforce these permit conditions.

DEP is not taking steps to strengthen the regulations or monitoring and enforcement of those permits.

All of that mismanagement and lax DEP oversight is now being swept under the rug and those negligent are not being held accountable.

This ad hoc approach illustrates NJ’s lack of any overall vulnerability assessment and adaption plan. 

And that is nothing to brag about in self congratulatory press releases.

BTW, there is over a $3 billion infrastructure deficit – just from Sandy – so a $2.95 million loan is a joke, not a press release.

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