Archive for June, 2020

This Is What Elite Privilege And Hypocrisy Look Like

June 7th, 2020 No comments

The Language of an Elite PhD and Professional Planner Is Instructive

Conservationist calls her colleagues “bought” and DEP program “propaganda”

On June 3, I got an unsolicited email from someone I didn’t know.

The email complimented me and asked a series of detailed good questions on my May 19 post about the NESE pipeline. The author wrote:

Your analysis of the big picture policy implications for New Jersey should induce panic in our environmental community.

I think your analysis also presents an organizing opportunity specific to bolstering state’s powers under the CWA. I’m not sure what this should look like, which is why I’m writing you. […]

With gratitude to you for your analysis, and for sticking your neck out.

Heather’s email stated she was a PhD, a professional planner, and head of the Lower Raritan Watershed Group. She was obviously familiar with my blog posts, if not all my work.

Without any background research on who Heather was, I substantively responded in good faith to her email – including at least 3 more of her replies that followed up with more questions – with detailed replies to what I thought were good and honest questions.

My replies were blunt, making it abundantly clear of my ideology and my loathing for NJ conservation groups and environmental leaders as either sold out corporate whores, incompetent, and worse.

This email dialogue included links to several of my prior posts, such that Heather – who approached me unsolicited – could clearly understand my “approach”, my past, and where I was coming from. In fact, I shared brutally honest personal assessments and very personal information with her.

So, to put it mildly, I was shocked to receive a response by Heather to my email complaining about the fact I learned that billionaire Peter Kellogg had more than doubled his financial support of NJ Audubon.

Heather’s reply to me provided detailed information and her personal assessments of Kellogg and DEP’s “conservation leadership program”.

Not surprisingly, after I’ve called out that corruption, Heather now wants her views and comments withdrawn. She does not want to be known as the source for my critical post.

Heather just emailed me to request that her words be deleted from my post:

While this is all true, I do sustain “hope” in the Chris Hedge’s sense of “holding out the possibility that we can touch and transform the souls of others.” (thanks for the suggestion that I track this down, btw).  I do maintain ties with these people and am in fact working to advance an urban habitat connectivity agenda with some of them, an agenda that is consistent with the LRWP’s commitment to Environmental Justice/Social Justice. I have hope that on an individual level some of them will eventually hold up a torch at the state level for what is right.

[…] As I was the most outspoken of the group on these things, the quote will no doubt be traced directly back to me if you could find your way to deleting my entire quotation I would appreciate that even more



Sorry Ms. Heather, it doesn’t work that way. As I replied:

My policy is to correct fact errors when I am made aware of them. Accordingly, I revised the attendees as you note below.

But sorry, if folks don’t ask – before providing it – that information is provided to me in confidence or off the record, then I don’t retract factually accurate materials that do not name individuals or represent ad hominem attacks.

Live and learn, I guess.

I also should have told her she obviously KNEW that I was including our emails in my posts, because I specifically included emails in the text of my June 3 post. After that June 3 post – which obviously revealed the I was including our email conversation in posts – Heather continued to send me emails – without any request for confidentiality or off the record status.

Not surprisingly, my reply really pissed Heather off!

It’s not surprising that Heather is embarrassed by her participation in this corruption. And for sharing her honest opinions with me. But that’s not my fault.

[update: I understand Heather’s plight – she called the DEP/Kellogg “leadership” program “propaganda” and said he colleagues were “bought”. Heather wrote (you can go back and read the complete text in my prior post):

Our cohort was wined and dined. And not just on propaganda. Kellog knows how to treat folks right. It’s delightful up there….Almost to a person the folks in my cohort are timid, and/or were already bought before participation in the program.

~~~ end update]

Ms. Heather, an elite PhD “conservationist” – trained by DEP in all forms of psychological manipulation and a licensed professional planner to boot – didn’t mince words in her reply to me.

Heather wrote:

Live and learn? More like hack journalism and basic asshole “principles” on your part.

At no point during our exchanges did you indicate that you might use my words in your material.

Basic personal and professional courtesy would include communicating, even as a tagline on your emails, that any communication w/ you is fair game for your material.

Some of us are trying to build a New Jersey environmental community on collaboration, mutual cooperation, transparency. You are a negative rebel. Screw you, Wolfe.

Did you get that? Heather touts her support of “transparency”. But at the same time she wants to keep the DEP program and her involvement in it secret. That’s classic hypocrisy.

“Asshole? “Screw you”? How nice. How professional.

And how can Heather seek “collaboration” and “mutual cooperation” with corrupt colleagues she called “bought”?

So much for what Heather seeks as “transparency”.

Thank you, lovely Ms. Heather! [BTW, I never said I was, nor do I pretend to be a “journalist”.]

I would never toast a real source (i.e. a government whistleblower) who actually took a career risk in providing information to me in confidence.

But a well fed “conservationist” who attends DEP billionaire funded soirees and calls her DEP program “propaganda” and her  colleagues “bought”?

No problem!


Take your hypocritical “collaboration, mutual cooperation, transparency” and shove it!.

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Murphy DEP Sponsors $5,000 A Week Junkets – Funded By A Wall Street Billionaire – To Entertain Their “Conservation Community” Friends

June 6th, 2020 No comments

A Shameful Episode

Beyond Regulatory Capture – A Billionaire Buys Bureaucrats & Conservationists

Note that financial support from Hudson Farms is not disclosed as a sponsor

DEP Program Logo – Note that financial support from Hudson Farms is not disclosed as a sponsor

At a time when many NJ residents can’t rub 2 nickels together, are worrying about paying rent and basic living expenses, the planet is burning, and local community activists are demanding an end to DEP logging of State forested lands in the Highlands Preservation Area, the NJ DEP created, organized, and sponsored two week long luxury junkets – called a “Conservation leadership program“- for 15 DEP managers and their “conservation community” friends and political supporters who just so happen to be promoting joint DEP logging projects (just more of the “Elite Charade”).

“Conservation” organizations who attended these soirees include NJ Audubon, a group who is working with DEP on the controversial Sparta Mountain WMA and other Highlands logging projects. Not surprisingly, elites from the Nature Conservancy and Ducks Unlimited were involved, but sadly, NJ Conservation Foundation also jumped on board this disgusting gravy train.

Adding insult to injury, I learned of theses junkets after being disgusted by an outrageously false, darkly cynical, and opportunistic promotional letter from NJ Audubon CEO Eric Stiles, who actually had the balls to claim some kind of leadership in the black lives matter movement. Stiles recently wrote (full letter provided upon request):

Dear Members and Supporters,

New Jersey Audubon cannot be silent in addressing the incidents of racial injustice that have roiled our country in recent weeks which include the tragic death of George Floyd and an act of discrimination against Christian Cooper, a Board Member of New York City Audubon, in Central Park. New Jersey Audubon extends our hearts and action to the families and communities that have been victimized and marginalized for far too long. New Jersey Audubon stands with you and always will.

Right. Are you fucking kidding me? NJ Audubon as champion of racial justice????

The billionaire funded DEP “conservation leadership” program was the brainchild of and created by DEP. It was funded by Wall Street billionaire Peter Kellogg, owner of an elite hunting compound in Sussex County known as Hudson Farms.

Regular readers here may recall that I blasted Kellogg and Hudson Farms for providing a $140,000 grant to NJ Audubon to prepare the controversial logging plan for Sparta Mountain Wildlife Management Area, see:

I’ve since learned that billionaire Kellogg’s Hudson Farms Foundation funding of NJ Audubon has more than doubled, to over $330,000.

One of the DEP soirees was held at Kellogg’s private Hudson Farms.

And of course PSE&G – who seeks to reap millions of dollars in profits by leveraging regulatory influence with DEP programs – including the DEP’s PACT climate regulations, carbon sequestration, and various mitigation programs now under development by DEP- couldn’t keep their grubby corporate hands out of and sponsored these junkets.

Several DEP manager attended the two weeklong junkets (several of whom are directly involved in the Sparta Mountain dispute). They include:

  • *Dave Golden, NJ DEP DFW *(clarification: only attended 1 day)
  • *John Sacco, NJ DEP DPF (*did not attend, member of planning committee)
  • *Todd Wykoff, NJ DEP DFP (*did not attend, member of planning committee)
  • Robert Auermuller, NJ DEP, DPF
  • Elizabeth Dragon, Coastal land Use Enforcement
  • Larry Fink, Green Acres
  • Jason Hearon, NJ DEP DFW
  • Chris Kunz, NJ DEP, BFWF&M
  • Tony McBride, NJ DEP DFW
  • Joshua Osowski,   NJ DEP State Parks
  • Sharon Petzinger, NJ DEP DFW
  • Kimberly Rennick, NJ DEP Project Manager
  • Courtney Wald-Wittkop, NJ DEP Green Acres
  • Brian Zarate, NJ DEP DFW
  • Bill Zipse, NJ Forst Service

How much did this cost State government to send 15 professionals for 2 weeks? Were these people paid while on these week long Wall Street funded and corporate PSE&G sponsored influence peddling junkets?

How much worse can it get?

Here is how one of the “conservation leaders” from NJ who attended both events – who obviously is feeling guilty after I asked about it – described the junkets:

in January I spent a week at Hudson Farms, on Kellog’s dime, as part of the New Jersey Conservation Leadership Program inaugural cohort (see info attached). The program was the brainchild of Dave Golden w/ NJ Division of Fish & Wildlife. It also included a week at the National Conservation Training Center in Shepherdstown, WV last October. Our cohort was wined and dined. And not just on propaganda. Kellog knows how to treat folks right. It’s delightful up there. Please don’t judge! I did not realize who was bankrolling the program when I applied.

The training itself, adaptive management work, is really quite useful. The rest of the experience was an eye opener, and depressing. Almost to a person the folks in my cohort are timid, and/or were already bought before participation in the program.

Here is the “program overview”. Note that the “tuition” is $4,850 for the weeklong event.

Here is the “purpose” – and note that logging is not included as a cause of fragmentation or “pressure” from “anthropogenic influences”:

Wildlife and natural habitats in New Jersey are under increasing pressure from expanding development, sea-level rise, habitat fragmentation caused by high road density, and other anthropogenic influences. When technical fixes alone cannot alleviate threats to conservation, adaptive problem solving becomes a key component to finding solutions. In a state like New Jersey, it is especially important to understand the complexities of the human element in conservation planning, management, and success.

Complexities of the “Human element? You mean complexities like the folks in Sparta NJ who are disgusted by DEP and billionaire Kellogg funded NJ Audubon logging of Highlands forests?

And look at how these elite, selfish, self promotional bastards view themselves in stating their “Vision”:

Elevate conservation in New Jersey by building extraordinary leadership throughout our conservation community. By providing our employees with adaptive leadership skills from a high-trust, shared learning experience, we will develop a network of highly effective professionals capable of magnify our individual or organizational outputs into exceptional collective accomplishments

Do they really believe their bullshit? That they are “extraordinary leaders” producing “exceptional collective accomplishments”? Delusional.

Heads should roll for this kind of Orwellian and manipulative bullshit that seeks to co-opt conservation groups and other professionals.

I want to know if the DEP attendees were paid and collected their DEP paycheck for these vacation weeks.

Can someone file OPRA requests for their time sheets they filed for the two weeks of these events and find out?

This needs to be widely shamed.

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Murphy Administration and PSE&G Making The Same Attacks On Environmental Regulations As Trump Is

June 5th, 2020 No comments

PSE&G Seeks DEP Waiver Of Environmental Regulations For Energy Infrastructure

NJ Gov. Murphy Used The Same COVID Pretext As Trump

Two important NJ based observations that you’re not likely to get in NJ media.

Yesterday, President Trump issued another Executive Order that attacks and rolls back key environmental regulatory protections.

Of course, this Order is being blasted by environmental groups and widely correctly reported by national media as another radical Trump outrage on public health and the environment.

This most recent Trump attack is targeted at the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and the Clean Water Act (CWA). It cynically uses the COVID crisis to justify “emergency” exemptions and waivers, which is obviously an Orwellian pretext.

Here is the NEPA language – very smiler language is used for ESA and CWA rollbacks:

(b)  To facilitate the Nation’s economic recovery, the heads of all agencies are directed to use, to the fullest extent possible and consistent with applicable law, emergency procedures, statutory exemptions, categorical exclusions, analyses that have already been completed, and concise and focused analyses, consistent with NEPA, CEQ’s NEPA regulations, and agencies’ NEPA procedures.

The scope of the Trump Order is broader than specifically attacking these 3 core environmental laws.

It broadly seeks to waive virtually all regulatory requirements. Section 9 directs that the “heads of all agencies”:

shall review all statutes, regulations, and guidance documents that may provide for emergency or expedited treatment (including waivers, exemptions, or other streamlining) with regard to agency actions pertinent to infrastructure, energy, environmental, or natural resources matters;

But what you won’t read or hear from NJ media – or from NJ environmental groups who cheerlead for Gov. Murphy and generally defer to PSEG money and power – are two things:

1) NJ Gov. Murphy has used the same cynical COVID pretext as Trump to suspend NJ DEP enforcement of environmental regulations, something that has not been reported by the NJ press corps, see:

2) NJ’s hometown corporate utility PSE&G – frequently portrayed in media as environmentally friendly and progressive on public policy and regulatory issues – is seeking the exactly same regulatory rollbacks by the NJ DEP as President Trump just enacted.

The NJ DEP is currently developing regulations to address climate change (here is DEP’s PACT website – more to follow on that).

PSE&G has weighed into the DEP PACT regulatory process to request regulatory relief for what they call “public interest”.

PSE&G hypocritically likes to portray themselves publicly as pro-environment and a responsible corporation, but behind the scenes they are as rabidly anti-environmental regulation as the most polluting chemical industry.

PSE&G wrote this to DEP:

“Particular attention should be focused on the potential to include a Public Interest Provision that would give NJDEP the ability to expedite approvals and provide certain exceptions for projects that support the broader goals of the Administration’s Climate Adaptation and Clean Energy goals. Energy infrastructure and offshore wind development onshore are examples of the types of projects that should be included.

To further this process and provide a foundation for the discussions in future meetings, PSEG proposes the follow language for consideration by the Department for inclusion as necessary, in the regulations under review.

“New Jersey is implementing a range of policies that will lead to infrastructure projects that would otherwise be subject to restrictions under these regulations. Based on a determination of public benefit/ societal need, in alignment with the policies put forth in the EMP, RGGI regulation and the provisions of the GWRA, the Department shall retain the flexibility to approve these projects and/or limit regulatory requirements.”

Will the Murphy DEP fold and accommodate PSEG profits?

Will PSEG be held accountable by NJ environmental groups and media for their Trump like attack on environmental laws?

We’ll keep you posted, but we’re not holding our breath.

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Trump EPA Attack On State’s Clean Water Protections Reveals Major Failures In New Jersey

June 3rd, 2020 No comments

NJ DEP Does Not Even Have a Section 401 Water Quality Certification Program

While Trump directs regulatory rollbacks via Executive Order, Gov. Murphy is silent

[Update below]

Yesterday, the Trump EPA issued a final rule that attacks the power of States to protect water quality, known as the Clean Water Act’s Section 410 Water Quality Certification (WQC) (see NY Times story:

Back on April 10, 2019, President Trump issued an Executive Order that directed EPA to roll back the State’s power under the Clean Water Act Section 401 WQC.

The Trump administration’s motives and policy to promote fossil energy development are openly admitted by EPA: (see page 8)

B. Executive Order 13868: Promoting Energy Infrastructure and Economic Growth

The policy objective of the Executive Order is to encourage greater investment in energy infrastructure in the United States by promoting efficient federal licensing and permitting processes and reducing regulatory uncertainty. The Executive Order identified the EPA’s outdated section 401 federal guidance and regulations as one source of confusion and uncertainty hindering the development of energy infrastructure. […]

The Executive Order directed the EPA to review CWA section 401 and the EPA’s 1971 certification regulations and interim guidance, issue new guidance to States, Tribes, and federal agencies within 60 days of the Order, and propose (as appropriate and consistent with law) new section 401 regulations within 120 days of the Order.

While Trump aggressively uses Executive Authority to direct EPA to roll back regulations, NJ Governor Murphy is silent and sitting on the sidelines.

The Trump EPA gave Gov. Murphy and DEP Commissioner McCabe a heads up and plenty of advance notice and time to act to avoid damage to state powers:

On August 6, 2018, the Agency sent a letter to the Environmental Council of the States, the Association of Clean Water Administrators, the Association of State Wetland Managers, the National Tribal Water Council, and the National Tribal Caucus identifying the Agency’s interest in engaging in potential clarifications to the section 401 process. (at page 11) … 

During the consultation period, the EPA participated in phone calls and in-person meetings with inter-governmental and Tribal associations, including the National Governors Association and National Tribal Water Council. […]

By promulgating these long-overdue regulations, it is not the EPA’s intent that States or Tribes violate either federal, State, or Tribal law pending completion of updates to applicable State or Tribal law. The Agency is aware that most if not all States have emergency rulemaking authorities that may help avoid such outcomes.

It is shocking that the NJ DEP – and NJ environmental groups and media – have done so little on the 401 WQC issue. Now, their power may be limited (I am reading the EPA rule now to fully understand this issue).

We’ve been writing about the Section 401 WQC for 8 years now, urging NJ environmental groups to focus on this powerful tool, urging the media to report on it, and documenting NJ DEP’s failure to implement a 401 WQC program (most recently in the DEP’s NESE Raritan Bay pipeline fake “denial”), so we’ll be brief today.

While other states – like New York and Connecticut – have aggressively used the State Section 401 WQC power to kill several pipelines (that’s why the Trump administration and their energy industry friends are seeking to kill it), the NJ DEP has done nothing with this power and does not even conduct a review of water quality impacts when they issue a WQC.

Under NJ DEP’s Freshwater Wetlands regulations, the WQC is merely an administrative appendage to a wetlands permit for projects subject to the 401 WQC requirements, (see NJAC 7:7A-2.1

(d) A permit issued under this chapter shall constitute the water quality certificate required under the Federal Act at 33 U.S.C. § 1341 for any activity covered by this chapter. … the Department shall use the standards and procedures in this chapter to determine whether to issue the water quality certificate

But there are no “standards” “in this chapter” (i.e. the wetlands rules) that apply to the water quality impacts or whether a project’s impacts would comply with NJ DEP’s surface water quality standards, including the anti-degradation policies, protection of existing and designated use mandates, and numeric and narrative standards designed to assure protection of the physical, chemical, and biological characteristics of water quality.

[Update: the failure to include enforceable SWQS standards is not an oversight or a gap. It is an intentional policy NOT to enforce SWQS.

Instead, under NJ DEP regulations, the DEP relies exclusively on BMP’s and mitigation to satisfy compliance with surface water quality standards.

If a project installs BMP’s – which DEP presumes protect water quality and comply with standards, even with no site specific scientific evidence or demonstration that this is true –  (and the project mitigates or compensates for unavoidable adverse impacts) it’s good to go and is approved.

Because DEP’s rules lack SWQS or other standards, they can not be enforced and DEP has no authority to deny a permit or WQC and they never have. The best example of this is I’ve written about is the DEP’s Forestry Wetlands BMP Manual. But here is that policy, explicitly included in the definition of BMP under the wetlands rules:

“Best Management Practices” or “BMPs” means methods, measures, designs, performance standards, maintenance procedures, and other management practices which prevent or reduce adverse impacts upon or pollution of freshwater wetlands, State open waters, and adjacent aquatic habitats, which facilitate compliance with the Federal Section 404(b)(1) guidelines (40 CFR Part 230), New Jersey Department of Environmental Protection Flood Hazard Area Control Act Rules, N.J.A.C. 7:13; the Department’s Storm Water Management Regulations, N.J.A.C. 7:8; the Standards for Soil Erosion and Sediment Control in New Jersey, promulgated by the New Jersey State Soil Conservation Committee at N.J.A.C. 2:90; and effluent limitations or prohibitions under Section 307(a) of the Federal Act and the Department’s Surface Water Quality Standards, N.J.A.C. 7:9B. Examples include practices found at 33 CFR 330.6, 40 CFR 233.35(a)6, the Department’s Flood Hazard Area Technical Manual, and “A Manual of Freshwater Wetland Management Practices for Mosquito Control in New Jersey.” The manuals included in this definition are only a partial listing, and interested persons should contact the Department for the most up to date list.

That vague phrase “facilitate compliance with” is intentionally written that way, to dodge a frontal legal challenge and to provide a plausible deniability for failure to enforce the SWQS. DEP can always claim that in theory they reserve the right to enforce the SWQS, but in practice they NEVER DO SO. In practice, DEP has no 401 WQC review process (policies, standards, criteria, methods, procedures) so they never could do so. ~~~ end update]

To understand this NJ DEP failure to implement a 401 WQC program, just compare the DEP’s Raritan “denial” with the New York DEC’s denial (as I did in this post) (or any of the hundreds of prior WQCs issued by DEP).

In response to the Raritan post, I got a detailed set of questions from a local watershed group. Here is my reply:

I’ll try to reply to your good questions – sorry, my RSS/blog does not allow comments because my site has been hacked so many times I had to shut it down with software by my ISP.

NJ DEP literally has no 401 WQC program. The WQC is an administrative appendage to a wetlands permit under NJ DEP’s freshwater wetlands rules. The DEP does not conduct any kind of technical review regarding water quality impacts of pipelines (or any other project subject to the WQC requirements) with respect to whether they comply with NJ’s water quality standards. That’s why I included a link to the NY DEC WQC denial so people could see what a real WQC review and certification looks like  (BTW, while I was at DEP, I wrote the SWQS anti degradation provisions with respect to Category One designations and later the 300 foot buffers in the stormwater rules. I designed and lead that program backing 2002).

In order to actually implement the 401 WQC program, NJ DEP would have to propose/adopt new rules. About 7 years ago, and at least 10 times since then, I’ve written detailed posts about how to do this and what a WQC review would look like under NJ DEP’s. Surface Water Quality Standards. I’ve also written posts about “a citizens guide to WQC”. I’ve sent these posts as emails to NJ environmental groups and urged them to format them into a petition for rule making and design a public campaign to pressure DEP and the Gov. to develop a 401 WQC program. So, groups like NJCF INTENTIONALLY are not doing the right thing.

NJ DEP does implement and apply surface water quality standards in the NJPDES point source discharge to surface water permit program (NJPDES DSW). That is THE ONLY DEP permit program that applies the water quality standards. That NJPDES DSW review process is a complex technical exercise involving wastewater characterization, “background” water quality, “reasonable potential” to exceed water quality standards, dilution modeling, stream flows, mixing zones, etc. There are many highly technical loopholes in this review, but at least DEP conducts it.

In contrast, when DEP issues stormwater permits, stream encroachment permits, wetlands permits, water allocation permits – ALL of which have water quality impacts – THEY DO NOT CONSIDER OR APPLY THE SWQS! DEP’s legal position is that non-point source pollution is not subject to the SWQS.

The WQC strategy should be:

1) get a WQ consultant (Princeton Hydro?) to draft a Report on how to design/implement a 401 WQC program – simply requiring permit applicants to demonstrate 4 quarters of site specific statistically representative sampling of “existing water quality” in order to enforce the anti-degradation requirements would be a huge step forward. This would also include site specific stream flows, rainfall/runoff, and water quality modeling of the impacts of the disturbance required for the pipeline construction and how the impacts would comply with numeric and narrative SWQS.

2) make this Report the technical basis for a petition for rule making. Submit that petition to DEP under the rule-making petition provisions of NJ Administrative Procedures Act.

3) hold a press conference announcing the petition and explain the implications to the press and public. Inform the public that while other states are using the WQC to kill pipelines (NY is not the only state doing this, as I’ve written many times), NJ DEP is doing literally NOTHING with their WQC power. This is now a problem, due to the new EPA WQC rule, which I am now reading to fully understand how it will limit state WQC programs.

4) demand a moratorium on any DEP WQC review/certification pending DEP’s adoption of new WQC program rules. This moratorium would have to be issued by the Gov. via Executive Order (there are many precedents for this. In fact, this is how NJ got the freshwater wetlands Act and Pinelands Protection Act passed!)

5) focus on DEP and the Governor.

I’ve laid this all out many, many times to NJ environmental leaders, yet they continue to ignore it. Maya at Delaware Riverkeeper fully understands all this, but they have focused only on litigation, not calling out NJ DEP’s regulatory failures. Jeff Tittel at Sierra Club gets it too, but he lacks capacity and support.

NJCF, the watershed groups, and others simply don’t get it and don’t want to flag weaknesses in DEP regulations or politically pressure the Gov. They have conflicts of interest and should not be relied on. Plus, they have chosen a very different strategy to fight pipelines and going full on the WQC issue would be an admission of failure for YEARS to focus on this key regulatory tool.

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