Archive for April, 2022

They Finally Really Did It

April 30th, 2022 No comments

You Maniacs! – You Blew It up!

Damn You! – Damn You All To Hell!

Screen Shot 2022-04-30 at 7.06.08 PM

Planet of the Apes (1967, final scene)

Joe Biden is riding Dr. Zaius’ pony.

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NJ Gov. Murphy’s Connections To Germany Warrant Scrutiny

April 29th, 2022 No comments

NJ Spotlight Stumbles On A Potentially Huge Story

Germany Is Desperate For LNG Imports

Murphy Has German & Wall Street Connections With Fortress LNG Export Project

In an incredible irony, today, in a story that was abject cheerleading for Gov. Murphy’s off shore wind program, NJ Spotlight reporter Jon Hurdle stumbled upon a potentially explosive story: (Spotlight)

Lee Laurendeau, chief executive of EEW’s American Offshore Structures, said his company’s interest in the Paulsboro site began with a conversation with Gov. Phil Murphy, who had once been the U.S. ambassador to Germany. Murphy urged EEW to consider setting up in Paulsboro, Laurendeau said.”

This is the first time I’ve seen a source quoted directly linking a NJ energy issue to Gov. Murphy’s prior role as Ambassador to Germany.

Gov. Murphy himself highlighted the dynamics and huge implications:

“I know we all desperately want to see an end to the war in Ukraine. But I know that we also want to see an energy future where no dictator can hold the world hostage over its energy supply, and I want New Jersey to be one of the places where we make this stand in no uncertain terms,” Murphy said.

Russia just terminated gas supplies to Poland and Bulgaria.

Germany could be next.

Germany relies on Russian gas imports for 40% of its energy. If Russia cut off that gas supply, the German economy would collapse and there would be political and social chaos. Germany is now in emergency mode, desperately seeking alternative gas, primarily via LNG imports. But they lack import terminals and the world supply of gas and LNG shipping tankers are not adequate to serve that demand.

In response, the Biden administration has pledged to rapidly expand US LNG exports to Europe (Germany).

Relatedly, a huge proposed new LNG export project on the Delaware River, known as Fortress Energy, is planned and was permitted by the Murphy DEP.

The current Murphy DEP Commissioner Shawn LaTourette was the lawyer for the Fortress Energy project that secured the DEP permits (how convenient! The Fox is now supervising the hen house architects!)

Which all takes me back to the NJ Spotlight story which casually noted Gov. Murphy’s prior role as ambassador to Germany and NJ energy policy and finance.

I previously documented and connected dots on Gov. Murphy’s German connections, including his prior role at Goldman Sachs, Wall Street finance, and the Fortress  Energy LNG project.

I wrote:

II.  Twisted Tales Of Wall Street Finance Could Link Gov. Murphy to the Project

Before the 2016 Philadelphia Inquirer story, back on 3/20/15, NJ.Com wrote a story with Sweeney praising Fortress Investment Group:

“State Sen. President Steve Sweeney led a press conference in Greenwich Township to announce the sale of the township’s former DuPont Repauno plant to Fortress Investment Group, which aims to turn the dormant 1,800-acre property into a port-related industrial park for imports and exports.

Sweeney goes out of his way to praise Fortress:

“That’s what they do, and they do it with private sector capital, not government money, which is the win-win-win for everybody,” said Sweeney, who declined to divulge the total value of the sale besides to say “It’s a lot of land.”

But Fortress did not provide a “win-win-win for everybody”. 

Fortress isa failed hedge fund – see:

  • The Fall of Fortress  – The asset manager is selling itself at a premium, but it’s still trading at a fraction of its IPO price. The big losers? Us.

“Fortress Investment Group, the struggling alternative-­investment firm that went public to great fanfare ten years ago but whose shares have since lost 74 percent of their market value.

Kaplan says Fortress has been “terrible” for public investors.”

They’ve ripped off public investors, including – as Sweeney might appreciate, given his political battles with NJ Teachers Unions – the Ohio Teacher’s Pension Fund:

“Fortress was the first U.S. alternatives firm to go public, in 2007, starting a trend that burned red-hot, then quickly flamed out, proving over the past ten years that these deals have been a disaster for public shareholders, which include big mutual funds catering to both retail and institutional investors. Among Fortress’s shareholders: Allianz Asset Management, Fidelity Investments, Wellington Management Co., and even the State Teachers Retirement System of Ohio.”

Now here’s where the links between Fortress and Gov. Murphy get murky and hypothetical, but good investigative journalism could connect these dots:

1. Veteran NJ environmental reporter Kirk Moore confirmed the story on the stealth LNG aspect of this project, where he also noted:

“Delaware River Partners LLC, a subsidiary of New York City-based Fortress Investment Group.”

2. Who is Fortress Investment GroupWikipedia reports that they have strong links to Goldman Sachs:

“When Fortress launched on the NYSE on February 9, 2007 with Goldman Sachs and Lehman Brothers underwriting the IPO.”

3. More recently, Fortress was acquired by a politically wired firm called SoftBank Group Corp, asreported by Institutional Investor:

“Last December business executives from around the globe made their way to Manhattan’s Trump Tower to meet with president-­elect Donald Trump. But few made as big of a splash as Masayoshi Son, head of SoftBank Group Corp., who had Trump crowing on Twitter about the Japanese mogul’s pledge to invest $50 billion in the U.S. and create 50,000 American jobs.

… on February 14 [2017], SoftBank agreed to pay $3.3 billion to buy Fortress Investment Group, the struggling alternative-­investment firm that went public to great fanfare ten years ago but whose shares have since lost 74 percent of their market value.”

4. SoftBank has some interesting relationships:

Fortress’s $3.3 billion deal with SoftBank was driven by Rajeev Misra, a former Deutsche Bank derivatives expert who is now in charge of investment strategy.

Gov. Murphy was former US Ambassador to Germany, where, particularly given his Goldman Sachs finance background, one assumes he had relationships with Deutsche Bank “experts” on investment strategy.

5. Now look who Mr. Misra, who drove the Fortress deal, formed a relationship with and where that individual previously worked:

A few years ago Misra worked briefly at Fortress, where he developed a relationship with Edens and Peter Briger Jr., who cochair the board of directors. (Briger also has ties to Japan, where he previously worked for Goldman Sachs Group.)

6. Briger and Phil Murphy are both Goldman Sachs diaspora, see NY Times.

So, a few questions emerge:

Did Phil Murphy have any involvement with the Fortress deal when he was at Goldman?

Did Phil Murphy have any relationship with SoftBank or Peter Briger?

Was Gov. Phil Murphy aware of the Fortress role?

As Gov. of NJ, Murphy sits on the DRBC Board and has executive control over DEP.

Did Murphy  in any way intervene in DRBC and/or DEP regulatory review processes?

Who were the players behind the scenes that pushed this project through DRBC and DEP reviews, without disclosing the LNG aspects?

It’s now time for some real investigative reporting and legislative oversight of what might be going on behind the scenes regarding Gov. Murphy’s German connections, which are openly documented on wind, and very troubling on LNG export.

If the Fortress LNG Export project re-emerges, it will be too late.

Is the legacy of IF Stone or William Greider out there?

Who will tell the people this story?

[Important End Notes:

1. Gov. Murphy’s personal dealings with his German friends, in the absence of real planning, could explain why the Port Paulsboro project was so flawed. Few recall (and NJ Spotlight fails to report) that the wind manufacturing at the Paulsboro Port location failed to consider the height limitations of bridges across the Delaware River, an elementary and huge error, see:

2. People also forget, and the supreme irony is lost, that the Paulsboro port’s first business, cheered by sponsors Senate President Sweeney and Assemblyman Burzichelli, was RUSSIAN STEEL IMPORTS!, see:

3. Gov. Murphy linked his off shore wind program to climate change. NJ Spotlight reported this claim as a fact. So again, we must warn that wind does not reduce or displace fossil fueled power and is in no way technical or legally linked to greenhouse gas emissions reductions. Just the opposite, see:

4. Finally, we got a belly laugh on this:

A German corporation is receiving hundreds of millions of NJ taxpayer subsidies, and here’s the local economic development plan – reported by Spotlight:

“We have a bulletin board with all the restaurants in Paulsboro, and we encourage everyone to use them”

Guess I’ll have the Paulsboro $6.99 breakfast special: eggs over easy with hash browns and rye toast!

NJ Making the right moves! That’s one hell of a headline, Spotlight!

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Forestry Task Force Kicks Off Deliberations

April 28th, 2022 No comments

Approximately 250 people participate in 4 hour Zoom call

Opening DEP Presentation Sparks Sharp Rebuttals 

Participants Call For DEP Moratorium Pending Reforms

Source: NJ DEP, John Cecil (4/28/22)

Source: NJ DEP, John Cecil (4/28/22)

Today, almost 3 months after Senator Smith announced his plans to create a forestry task force, the Task Force conducted its first meeting on an almost 4 hour zoom call.

The 4 Co-Chairs did a good job in setting the tone. It sounds like the process will be well managed, participatory, transparent, and science based.

The call was well attended by about 250 people. I wasn’t counting, but many spoke and most had very positive things to say.

Senator Smith began the call with his charge to the Task Force, which emphasized the climate emergency. Smith urged participants to be civil and respectful.

The goodwill almost was destroyed a moment later when DEP Assistant Commission John Cecil (controversial former pro-logging “active management” forester at NJ Audubon) proceeded to not just make brief introductory remarks, but launch into a 25 minute power point!

Very bad idea to put him up like that.

I’m a Luddite when it comes to Zoom (my first!) but I was able to use the chat box to call Cecil out on a few of his false and misleading statements.

Specifically, Cecil presented a data chart of the age-class diversity of NJ’s forests. He even noted that it illustrated a classic bell curve distribution, by age class. (unfortunately, I didn’t screen shoot that slide – update – here it is).


Yet, in his very next slide, the first conclusion was that “northern forests lack age class diversity” (see above). That so called lack of diversity is a major justification DEP uses to log to create “young forests” and improve “forest health”.

So, I took to the chat box and asked: how could that perfect bell curve distribution support a conclusion that forests lack age class diversity?

Cecil was dumfounded and unable to even try to answer the question! hahahha!

The next slide in Cecil’s spin box claimed that DEP Forest Management Plans followed various environmental laws and regulations. This is a flat out lie, because DEP forestry work is exempt.

Myself and other participants called Cecil out on that lie, which warmed my heart!

(thank you Co-Chair Eileen Murphy for posing 2 questions I asked, but you failed to ask several more questions I submitted on Cecil’s presentation!:

  • What does “management of timber likely to remain low” mean, quantitatively?
  • Do DEP’s forest planning and management programs have formal public participation, i.e. public notice, public hearings, public comment and response to comments?
  • What methods does DEP use to quantify “carbon trade-offs”?
  • What are the methods and metrics for “forest restoration”?
  • National priorities do not include forest preservation. Where does preservation fit in?
  • What are DEP’s density findings? Are NJ’s forests too dense? What is the natural background “density” assumed?
  • Is storm blowdown quantified as “damage”? What do those data say?
  • One climate objective should be maximization of carbon sequestration. To “enhance” sequestration is not an adequate goal.

A while later, I was called up for comments. I had forgotten I registered to provide comments and was not prepared. So, I just made 2 quick remarks:

1) Cecil’s slide claims on regulations were in error and must be corrected; and

2) the Task Force schedule is very long (Report by end of year) and reform legislation will take at least another year or 2. Given that DEP continues to engage in forestry projects (logging) and to adopt various new damaging forestry policies, plans, and programs, the Task Force should immediately call for an administrative moratorium by DEP until reforms can be enacted (laws passed and regulations adopted).

I was pleased when my friend Mark Lohbauer later supported me (I think he called me a colleague) and the moratorium proposal, as did several following commenters.

Lohbauer also criticized Cecil for promoting forest “harvest” and not mentioning the most important policy reform: proforestation!

Also joining the call was former DEP Commissioner and BPU Commissioner Jeanne Fox. I like Jeanne and have worked with her. Because she is a trusted and loyal Democrat, she can be an important political liaison to the Murphy Administration.

Perhaps Jeanne can be the ambassador to current DEP Commissioner LaTourette and ask him to make a good faith pledge to impose a “pause” during the reform process (and not use Cecil as the public face of the Department).

Even former DEP Commissioner McCabe imposed a “pause” during her incoming policy review of the Sparta Mt. WMA logging program.

Several other commenters were scientifically credentialed, passionate, and well informed advocates and lovers of forest ecosystems.

Tom Gilbert, a man who I have long criticized, made an important recommendation I agree with. Tom suggested that “consensus” might include a 2/3 majority vote, thereby eliminating a major flaw I wrote about in the consensus based approach, which provides veto power to a single selfish interest.

One criticism: the Co-Chairs did not do a good job summarizing the issue poll/survey they took. Basically, they claimed that everything was important, and, despite noting huge overlaps, then tried to ram them into 2 working groups: 1) climate and 2) ecological health. They also appeared to not understand conflicts of interest/ethics/dislcosure and scientific bias issues. And there is a built in flaw in their approach regarding representation, because the voice of one south jersey mill owner will have the same “power” as the leader of a group with 25,000 members. Perhaps a weighted voting scheme might help.

At the outset, I was skeptical and highly critical of this Task Force, but, by listening to the thoughtful and caring people on the call, I’ll admit that I see a possibility for improvements in how DEP “manages” our forests.

The keys will be to 1) accelerate the schedule, 2) nail down a DEP moratorium, 3) keep the discussion going in the public arena and media, and 4) not get co-opted by the inside game or false notions of “political feasibility”.

We’ll keep you posted.

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Solartopia – or Griftopia?

April 27th, 2022 No comments

NJ Local Government “Ratables Chase” Is Becoming A Shakedown Chase

State Legislators Abdicate Land Use And Public Interest Role

Where the hell are the environmental groups?

Farmland exempt from siting restrictions and sacrificed to industrial solar (Source: NJ BPU)

Farmland exempt from siting restrictions and sacrificed to industrial solar (Source: NJ BPU)

Open land in New jersey is like a gold mine,” he said. “There’s money out there that wants to come after the whole state.”  (Spotlight)

State Senate President Nicholas Scutari, meanwhile, indicated he had no plans to move the legislation and top Republicans said warehouse decisions were better left to local officials. (Bergen Record)

Between the explosion of warehouses and industrial solar, much of the little that is left of NJ’s rural character is being destroyed – and with little opposition by NJ environmental groups and the support of the Murphy administration and Legislators. [Update: check out the slick corporate marketing pitch, distributed at Warren County Agriculture Board:


NJ’s longstanding land use corruption and abuse – masked by slogans known as the “ratables chase” under “local home rule” – has now become a “shakedown chase”, as illustrated by the recent deal in Harmony Township.

In that case, an industrial solar developer basically flat out bought a local government land use approval of a 70MW industrial solar facility on 600 acres of prime farmland.

But Harmony Township is not unique – similar abuses are happening all across rural NJ – both southern and northwestern.

I)  State Legislative and Regulatory Abdication on Warehouse And Solar Development

State lawmakers are abdicating their responsibility to restrict these land use and financial abuses.

For example, I reached out to Senate Environment Committee Chairman Bob Smith and requested he review and respond to the industrial solar abuse in Harmony Township:

I urge you to revisit the land use issues in light of this decision and consider legislation to address the issues of “host community benefits”.

It is an invitation to corruption to continue the current practice of allowing municipalities to negotiate these huge economic, energy, and land use issues in the absence of State policies and standards and a transparent and participatory public process.

I was not optimistic about the prospects of legislative reforms:

Given Smith’s strong support of industrial scale solar, his recent flawed legislation which actually promotes solar on farmland, and his dead-set opposition to more land use controls, there is zero chance of success.

So, I was quite surprised to receive a reply from Senator Smith yesterday. Smith forwarded the Office of Legislative Services (OLS) non-partisan professional staff’s response to my concerns.

I won’t share that correspondence, but simply note that both Smith and OLS completely missed both the land use and ethics issues (as I predicted).

But Harmony Township is not a unique case – there are several large scale industrial solar development and warehouses that have either recently received local and DEP approvals or are undergoing review right now.

Approvals of NJ warehouse developments are being quietly rubber stamped by the Murphy DEP – who have gotten a pass by environmental groups and media – while State legislators have not only failed to respond, but supported the explosion of warehouse developments.

Recent amendments of NJ solar incentive laws also are pouring gasoline on the fire.

I’m not aware of any environmental groups or State agencies that are monitoring the statewide situation or considering the cumulative impacts of warehouse, solar and even new residential development (State Planning Commission and Rutgers land use data generally lags years behind the land loss).

II)  Fake Solar Siting Restrictions

Under NJ’s recent solar incentive law revisions (P.L 2021, c. 169), in a move to create the appearance of State land use policy, the legislature established some restrictions on where solar facilities could be developed (e.g. not in the preservation area of the Pinelands or Highlands, forests, wetlands, prime agricultural soils, or on preserved lands).

(under prior law, solar can even be sited on preserved farmlands).

The solar siting law did not amend the Municipal Land Use Law or NJ’s other land use, climate, or environmental laws.

Instead, it structured what should be a land use planning, climate, and environmental program in the domain of energy promotion law and put the BPU – not the DEP – in charge.

As a result, the reality is a market driven and economically based (“cost effective“) siting program whose primary objective is to promote solar – not reduce greenhouse gas emissions (ostensibly the goal of solar), protect natural resources or plan for or regulate land use.

BPU recently released a “straw proposal” to implement the law. The public comment period on that closed on April 22 (I didn’t see any press reports on that proposal or warnings or ACTION ALERTS by environmental groups).

With the exception of preserved lands, the alleged siting restrictions are lax and really meaningless because the law provides for a waiver: (BPU straw proposal)

Section 6(c) of the Act lists a series of land uses that are not authorized for solar project siting unless the applicant, in accordance with Section 6(f) of the Act, files a waiver petition with, and receives approval from, the Board to proceed. 

The implications of the waiver can be seen most obviously in the BPU staff recommendation that solar be prohibited from siting on forested lands. After explaining what it would be counter-productive to site a solar facility on forested lands, BPU blows a huge loophole in the “prohibition:

In general, Staff recommends that the Board establish rules that prohibit the siting of solar facilities on forested lands. Forested land acts as a carbon dioxide sink that helps to sequester CO2 emissions. Destruction of high- quality forested areas for the sole purpose of installing solar projects undermines many of the principal goals encouraging the construction of additional solar facilities, and goes contrary to the desire to ensure that carbon dioxide already sequestered in forests continues to remain sequestered. […]

Staff proposes that solar projects seeking to be located on forested lands as defined above would be required to file a petition for waiver, pursuant to Section 6(f) of the Solar Act,

BPU staff do not recommend any public notice and comment or other form of public participation in waiver reviews and approvals.

There are no substantive standards in the waiver provision to limit the vague phrase “the public interest“.

Worse, BPU staff are openly recommending corrupt “mitigation” deals:

Staff proposes that the Board and its sister agencies consider any mitigation measures project proponents suggested in determining whether a particular solar project is in the public interest, such as proposals that include preservation of other lands (e.g., donating substantial desirable land into permanent conservation), and or the like.

Siting solar on agricultural (farmland) is even worse than forested lands.

In addition to the waiver, there is a flat out exemption of 2.5% of agricultural land:

Staff interprets the Act as allowing solar development on the first 2.5% of Prime Agricultural Soils/Soils of Statewide Importance that are in ADAs statewide (“2.5% Statewide Threshold”), subject to the limitations found in Section 6(f) that limit total development within a given county. This first 2.5% would therefore be exempt from the general prohibition on siting on Prime Agricultural Soils/Soils of Statewide Importance contained in Section 6(c). Any development on these farmlands above the 2.5% Statewide Threshold would only be allowed if the solar developer seeks and receives a waiver under Section 6(f), as discussed below.

Some might think that 2.5% is a small amount of farmland that would be lost to industrial solar – but it represents 8,500 acres! That’ over 13 square miles. (see page 20)

And the remaining 97.5% (331,000) can be developed under the site specific waiver!

Thus, effectively, the siting of solar facilities is delegated to local governments and local land use zoning and the profit seeking of private corporate developers. BPU explicitly states that site selection is made by solar developers, base primarily on economic considerations (and local land use zoning): (BPU straw proposal):

to keep project costs reasonable, developers generally need to evaluate a number of potential parcels, and select the most cost effective location. Thus, the universe of land potentially available for development is expected to be greater than the number of acres that will actually be used for solar development.

As I recently concluded, all this is:

That is a formula for rapid destruction of what’s left of NJ’s forests and farms and rural character. Period.

[Update: A knowledgeable reader takes me to task (to which I reply I specifically mentioned “residential development” by that was not the focus of this post):

You missing the biggest sprawl issue out there – its the courts , Fairshair (SIC) and the builders – it is system run amok – christie got rid of Coah – the courts stepped in with builders and fairshare – and pro development mayors – all the bad projects we stopped over the years are back – Westside of Scotch Rd-Pointview Reservoir Wayne ,Pigeon Swamp in East Brunswick – Golf course in Hillsborough – plus dozens of others – plus toxic sites GM  Hyatt bearing site Westfield  – GM in Ewing – Chromium sites in JC – plus massive up zoning –

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Will “Degraded Forests” And Carbon Sequestration Become The New Cover For DEP Logging Projects?

April 25th, 2022 No comments

Murphy DEP Tries To Take Credit For RGGI Funding For Carbon Sequestration

DEP’s “Active Forest Management” And “Forest Stewardship” Programs Do No Inspire Confidence

Prior Billionaire Funding To DEP & NJ Audubon Creates Huge Conflicts Of Interest

As part of their Earth Week media blitz, last week, DEP issued the following press release:

As Earth Week is celebrated this year with the theme of Invest in Our Planet, the Murphy Administration is launching a new blue and green carbon grant program that will invest $15 million in projects across New Jersey that create, restore and enhance salt marshes, sea grass beds, forests and urban parks that sequester atmospheric carbon in the fight against climate change.

The DEP called this a “new program” and created the impression that this is new money.

The “new program” claim is flat out false and the implied new funding claim is highly misleading.

The source of the funding is the Regional Greenhouse Gas Initiative (RGGI) carbon sequestration program.

That program and funding are not new.

They were created by the 2007 legislation – See DEP’s “RGGI Strategic Funding Plan”, specifically P.L. 2008, c. 340, commonly referred to as the Global Warming Solutions Fund Act. The Act allocates 10% of the total revenues from the RGGI allowance sales to DEP for, among other things, “forest stewardship” and “carbon sequestration”:

Ten percent [of RGGI revenues] shall be allocated to the department to support programs that enhance the stewardship and restoration of the State’s forests and tidal marshes that provide important opportunities to sequester or reduce greenhouse gases.

DEP adopted/updated regulations to implement the law in 2019 Global Warming Solutions Fund rules.

This is another example of how “good news” grant funding is used by DEP to divert from real climate problems, feed the media stenographers and manage the news, while marginalizing critics .


In addition to these climate and RGGI diversions, three potentially problematic things in that press release caught my eye:

1) John Cecil, former head of NJ Audubon’s “Corporate Stewardship” program and champion of controversial logging projects has been promoted to Assistant Commissioner. Cecil has been an aggressive advocate of “active forestry management” (logging). That means he has even more influence on DEP land management and forestry programs.

2)  Private landowners, like billionaire Peter Kellogg – a friend of Gov. Murphy – who owns elite Hudson Farm hunting club and who funded $330,000 to NJ Audubon’s “active forest management” and “Stewardship” programs run by DEP’s Assistant Commissioner Cecil – are eligible for funding:

  • Private landowners owning property in New Jersey (note: private property project applicants must provide matching funds)

Kellogg’s Hudson Farm has not only funded NJ Audubon logging projects, but Kellogg also funded a DEP staff junket. Those DEP staffers will make grant funding decisions.

Even more troubling, he is invested in and using Hudson Farm to generate revenues from private market based carbon trading schemes. Fake credits, double dipping, and all sorts of abuses and manipulation opportunities – like DEP allowed to occur in the “Open Market Emissions Trading Program” (OMET) – are likely.

Obviously, both DEP and Mr. Cecil have huge potential conflicts of interest, should Hudson Farm apply for DEP grant funds.

3) The DEP press release used a new and vague term for projects eligible for funding:

Eligible projects include those that:

  • […] Restore degraded forests or former agricultural areas with resilient native vegetation

I’ve asked DEP press office how DEP defines a “degraded forest”. That vague term is not used in the 2007 enabling law, DEP’s RGGI regulations, or DEP’s strategic funding plan. I’ve not seen it used in various DEP “Forest Stewardship” plans.

After several days of getting the runaround, I sent DEP press officer Larry Hjana this note:

Are you aware that DEP has found lack of “age class diversity” to be a condition that requires “active management” and “treatments” (logging) to restore forest health and ecological diversity?Is DEP taking a similar approach to carbon sequestration?

Then you wonder why DEP gets questions about what they consider a “degraded forest”?

I’ve never seen that term used before in various DEP forestry documents. Yet DEP is offering millions of dollars in grant money to address the condition. 

How can DEP evaluate grant proposals without a technical definition and performance metrics?

Sensing a new sham basis for more “active management” and “forest treatments”, I then filed this OPRA request:

I request the following public documents:

1. the grant application definition, application evaluation guidelines, and performance metrics for the field, forest, and ecological conditions that would constitute a “degraded forest”;

2. DEP regulations, technical manuals, guidelines, policies, plans, projects, standards, metrics, or other materials that define a “degraded forest”;

3. the scientific basis to support DEP classification or determination of the existence of a “degraded forest”

We’ll keep you posted. This smells like the same old sham and spin.

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