Archive for October, 2022

Sandy’s Greatest Hits

October 31st, 2022 No comments

Tales Gone Down The Memory Hole

A (True) Homage To Sandy

King Canute holds back the sea! (and without a sea wall!)

King Canute holds back the sea! (and without a sea wall!)

Since the NJ media is doing Sandy nostalgia and revanchism and all the important climate science, land use planning, DEP regulation, and public policy issues are either being ignored or shoved down Orwell’s Memory Hole, we thought we’d reprise “Sandy’s Greatest Hits” (TM) (not the crap you’re reading in NJ media):.

We begin with a post I wrote as Sandy was making landfall to remind people that we’ve been here before:


(Update: wow, I just realized that 3 days BEFORE Sandy made landfall, I wrote this:

From there, we wrote about NJ DEP lack of preparation despite decades of warnings, lack of land use planning and lax regulations that compounded the disaster, lack of legislative oversight, and Gov. Christie’ “Rebuild Madness”:


I cheated - this shot is from Massachusetts.

I cheated – this shot is from Massachusetts.

I posed the essential – and existential – question (and exposed Gov. Christie’s “Rebuild Madness”):

But Christie was not alone in ignoring scientific warnings and making the problems worse:

We suggested humorous ways out:

King Canute rebukes his Courtiers (coastal planners!)

King Canute rebukes his Courtiers (coastal planners!)

We held Gov. Christie accountable when the NJ media was promoting and making Christie a hero:

And, when few people were talking about the climate science of extreme weather, in another policy debate still alive and relevant, we exposed the King with no clothes:


There was absolutely no media coverage of this taboo – despite the introduction and movement of Legislation in Trenton:


Ah, it hurt when we outed that Achilles heel of the Rebuild Madness resilience crowd:

We were the primary source in a killer national story by Huffington Post: (followed by a TV discussion)

“[Christie has] done the exact opposite of what’s needed to be done,” said Bill Wolfe, a former Department of Environmental Protection planner and policy analyst who now leads the watchdog group New Jersey Public Employees for Environmental Responsibility. “He has been affirmatively promoting regulatory relief and taking away any development, land use planning and infrastructure expertise at the department.”

And we were an expert source in an award winning documentary – (interview by NY Times journals Mark Bittman)


Still crazy, after all these years – and Still Lurching From Drought To Flood. Happy Halloween!


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Murphy DEP Finally Proposes Inland Flood Rules – Current Rainfall, Stormwater Volumes, & Flood Elevations Already Exceed DEP’s New Standards

October 30th, 2022 No comments

Rule Based On The 100 Year Storm Event, Despite Suffering Several 500 Year Storms

DEP Rule Is Obsolete Before It Is Adopted 

DEP Ignores Land Use Planning And Instead Relies On The Myth of “Resilience”

Lambertville, NJ. Along Swan Creek – Irene flooding (8/28/11) (Bill Wolfe)

Lambertville, NJ. Along Swan Creek – Irene flooding (8/28/11) (Bill Wolfe)

[Update: 1/15/22 – Even NPR gets it and is more critical than NJ environmentalists – billions of dollars of infrastructure money is being wasted by under-designed systems and lax regulatory standards, just like we noted in US Army Corps of Engineers New Orleans $14 billion under-design boondoggle. DEP is repeating the same errors:

After five years (second term), numerous self promotional press releases and toothless Executive orders, and several massive deadly floods, on Thursday October 27 the Murphy Administration finally proposed new rules to update decades old inland flood maps and recognize significant increases in rainfall and stormwater runoff that have exacerbated NJ’s vulnerability to flooding.

Even larger storms and floods are projected due to the climate emergency. This science is not new and has been clear for a long time – e.g. I wrote this 12 years ago:

The University of New Hampshire (UNH) just issued an important and amazingly timely Report: Trends in Extreme Precipitation Events for the Northeastern United States 1948-2007 […]

Why is no one analyzing the same rainfall and flooding data and correlating it with land use changes here in NJ? (hint: it’s not due any to lack of hydrology data or land use/land cover data or precipitation data)

Why is the relationship between global warming and increased storm frequency/intensity/pattern rarely if ever made by the same tired meteorologists quoted in the NJ news stories?

Of course, the liars and deniers at NJ BIA shamefully dispute the science:

NJBIA Deputy Chief of Government Affairs Ray Cantor said that’s good news, but the science behind the establishment of new standards is still questionable. 

(read the DEP press release  and read the “formal” DEP rule proposal – which will appear in the December 5, 2022 NJ Register).

Before we analyze the merits of the complex 117 page DEP proposal, we must note that DEP disingenuously continued their manipulation by issuing the Press Release under a “ICYMI” lede and inserted a new “courtesy copy” link to the rule proposal on the original October 13 press release (the text of the rule proposal was NOT included in the original), a track covering slight of hand that would make Orwell blush.

No Commissioner LaTourette, we didn’t “miss it” – we saw exactly what you did in duping the public on October 13 by creating a false impression that a Stakeholder outline was a rule proposal and then allowing the news media to print a false story, without making any effort to correct it.

NJ Spotlight also has egg on their face, because we told them that two prior false news stories stated as fact that DEP had proposed the rule already! and they did not correct their false reporting. Now that that is obvious, it will be interesting to see how they navigate those errors when they write about the actual “formal” proposal, see:

We need a few days to read and digest the entire rule, but we can make a few big picture observations today:

1. Just as we predicted, DEP based the rule on the 100 year storm event, despite the fact that NJ already has experienced several far more severe 500 year storm events.

We predicted DEP would do that back in February, when DEP released their Cornell rainfall study, see:

I explained the significance of the flawed 100 year storm in this September 4, 2021 post:

The US Army Corps of Engineers recently were forced to admit a similar huge engineering blunder in New Orleans, due to reliance on flawed design standards, a $14 billion mistake: (Federal Register Notice, 4/2/19)

Even NJ Spotlight understands the 500 year storm see:

DEP’s proposal documents the fact that NJ has suffered 500 year (or more) Storm events and flooding (@ page 10):

Specifically, the remnants of Tropical Storm Ida resulted in flooding significantly more severe than FEMA’s published 100-year flood at various locations in New Jersey:

Raritan River at Bound Brook:

  • Flooding during Tropical Storm Ida equaled 1999’s Hurricane Floyd, which was the highest elevation ever recorded at Bound Brook.
  • Including Floyd, flooding at this location in the past 23 years has equaled or exceeded FEMA’s 500-year flood elevation three times.
  • The Raritan River during Tropical Storm Ida peaked at 42.13 ft NGVD (41.21 ft NAVD) which is 3.01 feet above FEMA’s 100-year elevation (38.2 ft NAVD) and 0.21 ft above FEMA’s 500-year flood elevation (41.0 ft NAVD).

Raritan River at Bridgewater

  • Flooding during Tropical Storm Ida peaked at roughly FEMA’s 500-year flood elevation (41.0 ft NAVD) which is 2.8 ft above FEMA’s 100-year flood elevation (38.2 ft NAVD)

Millstone River at Manville:

  • Flooding during Tropical Storm Ida peaked at roughly one foot above FEMA’s 500-year flood elevation (43.5 ft NAVD) which is 2.5 ft above FEMA’s 100-year flood elevation (41.0 ft NAVD). Thus, flooding at this location peaked at approximately 3.5 feet above FEMA’s 100-year flood elevation.

DEP then explains the significance of the 500 year flood event: (@page 11)

These examples illustrate not only that Ida was a significant flood event that exceeded the anticipated flooding depicted on available flood mapping products, upon which many roads and buildings were financed, constructed, and insured in the impacted communities, but also that there is an upward trend in the number and severity of flood events in the State. As noted above, flooding in Bound Brook has exceeded FEMA’s 100-year flood elevation four times and FEMA’s 500-year flood elevation three times since 1999, which leads to the conclusion that we are already experiencing increased flooding as compared with past recurrence interval calculations.

Despite the facts that NJ is already experiencing 500 year floods and that climate science projects that extreme storms will significantly increase in rainfall amount, rainfall intensity (short severe bursts of rainfall that create floods), and extreme rainfall frequency, the DEP did not even use the 500 year storm.

Instead, DEP merely added a 25% “safety factor” addition to the current 100 year storm event they’ve been using for decades.

And look how they then falsely stated that it would be adequate – a statement made before the facts on 500 year storms are summarized on page 10-11: (@page 5):

This rulemaking incorporates anticipated greater depths of precipitation for the two, 10, and 100-year storm events for the purposes of stormwater management. These proposed amendments are necessary to ensure that buildings, roads, stormwater management features and other structures are designed and constructed to manage and be protective for today’s flood conditions and precipitation as well as anticipated future conditions and precipitation. […]

Specifically, the flood hazard area design flood elevation is based on a flood that is 25 percent greater than the 100-year peak flow rate in the stream or river being analyzed and mapped.

The technical regulatory fine print for this standard is on page 102:

6. Table 3.6B below sets forth the change factors to be used in determining the projected 100-year storm event for use in this chapter,

The 100 year storm – even with an additional 25% “safety factor” increment – can not “ensure that buildings, roads, stormwater management features and other structures are designed and constructed to manage and be protective for today’s flood conditions and precipitation as well as anticipated future conditions and precipitation.”

That proposed new standard is already exceeded now, never mind projected climate driven increases.

DEP admits this multiple times in the proposal:

“More than 12 rivers exceeded their 100-year flood levels”

“On August 27 and 28, 2011, Hurricane Irene resulted in record breaking floods on many New Jersey streams, with 33 USGS stream gauges recording peak flows equal to or greater than the 100-year recurrence interval (USGS, 2011).”

DEP exposed the inadequacy of the 100 year design storm for the purpose of justifying their new 25% “safety factor”.

But, ironically, in doing so, DEP also exposed the flaws in relying on the 100 year flood.

2. DEP Ignores Land Use Increases In Development. DEP’s proposed new standards are obsolete for the same reasons that DEP correctly rejects current rainfall methods

Just some basic observations make it obvious that, in addition to underestimating extreme rainfall amounts and flood elevations, DEP is failing to consider a basic driver of increased flood impacts.

Flooding is a combination of the amount and timing of rainfall and the ability of the landscape to absorb that rainfall.

NJ is a highly developed state.

Development destroyed forests, wetlands, and natural landscapes that absorb rainfall and dampen flooding. It also puts people and property at risk when located in areas prone or vulnerable to flooding.

Development also increases impervious surfaces that dramatically increase the generate stormwater runoff volumes.

Yet the DEP proposal ignores the changes in land use and impervious surfaces that generated huge volumes of stormwater that contribute to bad land use decisions that result in devastating deadly flooding.

The proposal ignores existing development, it will influence new development at the margin, and it therefore depends on market forces, not any overarching State Land use and climate plan or infrastructure investment program.

A critical Star ledger editorial got that:

“A lot of New Jersey was developed prior to the stormwater regulations,” Obropta said. “The state needs to require municipalities to begin retrofitting existing development with stormwater management if we have any hope to reduce flooding.”

There is “no hope”. The proposal ignores existing development.

The proposal does very little to cap or reduce impervious surfaces or stop the loss of natural lands like forests, wetlands and stream buffers. It guarantees that the flooding problems will get worse.

3. DEP Rejected A Land Use Planning Approach And Policy Of “Strategic Adjustment” And Relies Primarily On Engineered “Resilience”.

The most cost effective and environmentally sound approach to stormwater management and flooding – particularly in light of projected climate driven more extreme weather events – is land use planning backed by regulation. That approach would include putting teeth in DEP’s current scattershot reactive reliance on voluntary “willing sellers” in the “Blue Acres” land acquisition program and restrictions on NJ’s “right to rebuild” storm damaged properties.

DEP has land use planning and regulatory powers that can be deployed to promote “strategic retreat” from flood prone lands, restrict rebuilding of flooded structures, and stop building in flood prone places or places that destroy forests, stream buffers, and wetlands. see:

Assertion of State and DEP land use planning powers is such a taboo topic, DEP doesn’t even talk about it anymore. Not even in the narrative description, never mind the regulatory text of the proposal. see:

But DEP effectively abandoned land use planning in favor of the slogan “resilience”, and they openly admit it:

As the State repairs the damage from these devastating impacts, it is in the interest of the public’s health and safety that future development of public and private  structures is as resilient as possible to withstand the increasing frequency and intensity of precipitation events, such as Ida.

And even highly technical details – and there are a lot of them that I have not considered today – like the groundwater recharge requirements retain the 2 year storm volume and flawed average annual recharge approach – which are overwhelmed by extreme weather – do little to nothing to reduce flooding.

In addition to getting the science and regulatory details wrong, the entire DEP approach is fatally flawed and based on the myth of “resilience”.

Resilience is much like flawed coastal engineering (sea walls, beach replenishment, etc) and hard engineered flood control projects. They give a false sense of security, cost a ton of money to build and maintain, and don’t work.

We can’t engineer and build our way out of this mess. And it will only get worse.

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Exxon Mobil Joins NJ Audubon’s “Corporate Stewardship Council” – After Audubon Hires Former Exxon Mobil Scientist As CEO

October 29th, 2022 No comments

Corporate Greenwash Leveraged By The Revolving Door

Trump, Billionaire Peter Kellogg, & Now Exxon Mobil Are Major Donors

Source: NJ Audubon website ( see links below)

Source: NJ Audubon website ( see links below)

“How do we do it, How do we do it? How do we do it? How do we do it?” ~~ “Step Right Up”, Tom Waits

Whether you’re pissed off about the climate catastrophe or sick of the corporate windfall profits from being ripped off at the gas pumps, I though people would be shocked to learn that NJ Audubon’s “Corporate Stewardship Council” has a new member – climate criminal Exxon-Mobil.

Presumably, that means that NJ Audubon also has a new corporate major donor.

Exxon Mobil became one of NJ Audubon’s corporate friends – close friends – after NJ Audubon hired a former Exxon Mobil scientist as their CEO. How cozy a relationship, see:

Exxon Mobil now joins such major corporate polluters and climate criminals as Dupont (Chemours), Pfizer, Covanta, JCP&L, PSE&G, Atlantic City Electric, Eastern Propane, and Donald Trump’s National Golf Course.

The NJ Audubon’s map of corporate greenwashing reads like a who’s who of Big Oil, Big Pharma, Big Chemicals, and major developers and pollution sites – take a look:

Screen Shot 2022-10-25 at 9.46.25 PM

 Apparently, the NJ environmental community has no problems with NJ Audubon’s corporate greenwashing – even for fossil criminal Exxon Mobil – one of the Big Oil climate criminals that NJ DEP just announced a lawsuit against for climate fraud.

Take a look at all those smiling faces: (listen!)


The members and donors of NJ environmental groups and NJ media have to ask these folks the question Tom Waits asked, in Step Right Up:

How do we do it?, How do we do it? How do we do it? How do we do it?

PS – In terms of leveraging the revolving door, let’s not forget that NJ Audubon’s former head of Corporate Stewardship (and forestry/logging) John Cecil, is now Assistant Commissioner For Parks And Forests at the Murphy DEP, where he’s championing “thinning” of Pinelands State forests, the same “active management” approach he presented to the Pinelands Commission last spring just before joining DEP.

But that’s not all: former DEP head of Science and Research, Eileen Murphy is now NJ Audubon’s chief Trenton lobbyist.

You really can’t make this stuff up (which is awful, even by NJ standards).

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What The Hell Is Going On At NJ Chapter Of Sierra Club?

October 28th, 2022 No comments

Current Chapter Director Not Even Trying To Fill Jeff Tittel’s Big Shoes

Lack of Engagement On DEP Pinelands Logging Plan Exposes Compromised Activism


Frankly, I expected all the frantic behind the scenes efforts to suppress criticism of DEP’s Pinelands Forestry Plan from the usual compromised and conflicted suspects, i.e. NJ Audubon, Pinelands Preservation Alliance (PPA), and NJ Conservation Foundation (NJCF), all of whom have longstanding economic and personal relationships with DEP and the Pinelands Commission, particularly on forestry and fire management (e.g. NJCF Annual report, 2021:

In our role as co-chair of the Natural and Working Lands group of the New Jersey Climate Change Alliance, we are partnering with Rutgers University and various stakeholder groups. We provided data and analysis to inform the New Jersey Department of Environmental Protection’s development of strategies to defend and enhance carbon stored in forests and other lands. The DEP is developing a statewide carbon sequestration strategy under the Global Warming Response Act. […]

[Co-Executive Director] Jay Watson, who heads our land protection program following a long career at the New Jersey Department of Environmental Protection.

Since I wrote about that behind the scenes pressure campaign, it’s only gotten worse – much worse – see:

Several other people have objected to the behind the scenes pressures being asserted on them to not publicly oppose this plan. PPA and NJCF have even been flat out misleading people about crucial issues (e.g. see this and this and and this, which included Commission Lohbauer’s detailed criticism). At the same time, several people are supporting me privately in confidence, but are doing nothing publicly.

But I did not expect that from Sierra Club, NJ Chapter, where I worked for almost 7 years as Policy Director and maintain a friendship with retired Director Jeff Tittel (who I have not spoken to about this).

So, to smoke them out, below is an email I just fired off to current Sierra Director, Anjuli Ramos-Busot (she/her/hers), followed by (she/her/hers) empty reply:

Hi Anjuli – I was just searching for Sierra Club’s formal position on forestry and wildfire on public lands and came across this 1989 policy:

I assume it’s been updated? If so, can you provide a copy or link to it?

Please correct me if I’m wrong, but I am concerned by the NJ Chapter’s failure to engage the debate on DEP’s wildfire management plan in the Pinelands, which conflicts with several elements of the above 1989 policy.

DEP’s Pinelands plan also contradicts recent science (Chad Hanson) about forest “thinning” and wildfire (glad to provide links, but assume you are aware of all that, given your position as Co-Chair of Senator Smith’s Forestry Task Force.)

There are many other flaws in the DEP plan, which were raised by Pinelands Commissioners Lohbauer, Wallner (a retired *National Park Service wildfire expert) and Lloyd, including a lack of justification in protecting people and property from wildfire risks.

The DEP plan also fails to protect natural resources, e.g. only 80 foot buffers for T&E habitat, wetlands and vernal ponds, when NJ regulatory buffers are 300-1,0000 feet; no monitoring for ecological and water quality impacts, including herbicide treatments on over 1,000 acres; and a seriously flawed “carbon” analysis.

I’ve documented and made you aware of all of these issues in detailed prior emails, yet you have not responded at all.

I find this unprofessional and astonishing, given that I previously served as NJ Chapter Policy Director for almost 7 years.

Please be advised that I’m prepared to contact Sierra National and file some form of complaint (I assume NJ Chapter must honor National’s policies), should you not reply to this email and provide some explanation of the Chapter’s position on the DEP’s Pinelands plan.

Bill Wolfe

“She/Her” reply:

Hi Bill,

Thank you for your email. NJ Sierra Club will take a position when we think it is adequate to do so.

In regards to your threat of reporting me to National, please go ahead. Report me. NJ Sierra Club will not engage in your inflammatory and disrespectful messaging and approach to others.


Anjuli Ramos

*corrected 12/13/22

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DEP’s Carbon Analysis Of Their Pinelands Logging Scheme Is A Sham

October 27th, 2022 No comments

Must Not Become Model For DEP, Pinelands, & Highlands Approach To Carbon In Forests

DEP Already Has A Slogan Teed Up: “Carbon Defense”

“The proposed project will significantly reduce the forest carbon pools throughout the site overall due to the removal of forest overstory.” ~~~ NJ DEP Forestry Plan

I initially wrote that the DEP’s Forest Management Plan for the Pinelands failed to consider carbon storage and sequestration. That statement was based on information available to me at the time, which was the Pinelands approval document (which does not address the carbon issues) and the Commission’s brief deliberation on it before voting to approve it.

I just received the DEP plan via an OPRA to DEP (my prior OPRA request was denied by the Pinelands Commission). Upon reading the DEP Plan, I must correct the record and say that I was wrong.

Unfortunately DEP does consider carbon and it is such a flawed, biased, and superficial analysis that it would have been better if DEP completely ignored the issue than to allow this to become what passes for a carbon analysis of forestry management.

There is no scientific basis or support provided. There is a dubious and vague summary attempt at quantification. There is no site specific analysis. There are no binding commitments. There are no enforceable permit conditions. There is no lifecycle carbon analysis. There is no linkage to a Statewide plan or goal. Carbon storage and carbon sequestration are not even distinguished. Claims of “avoided emissions” and “carbon defense” conflict with science. There is no official methodology to conduct this analysis and no regulatory standards or policies in place to govern.

Remarkably, in an email to me urging me not to oppose the plan, despite his full awareness of the contents of the DEP plan, Emile DeVito of NJCF minimized the carbon impacts with this total fabrication – the DEP Plan does not make a commitment to “leaving all the mulch in the forest” and the the Pinelands Commission’s approval does not include an enforceable condition to require it. Emile wrote:

“The logging is nearly all “thinning from the ground up” to remove lower levels of fuel load, and leaving all the mulch in the forest to decompose, very little wood removal

Just the opposite – DEP lists several options for utilization of the logged trees, including “converted to energy” (cord wood, wood pellets, etc) and as lumber or other wood products.

Here is DEP’s carbon analysis, – read it for yourself and then consider that DEP relied on that to support a table which showed a minuscule carbon impact!

“The proposed project will significantly reduce the forest carbon pools throughout the site overall due to the removal of forest overstory. In particular, the flux in carbon before and after each of the treatments will change primarily from live aboveground carbon (removal of trees) to the dead wood pool (increase in slash, tops, etc.) due to harvesting activities. In addition, removed carbon may be utilized and stored by long -term forest products, stored within landfills, converted to energy, or may be left on site to be recycled back to the system depending on the implementation contractor and method of harvesting used to carry out the treatments.

The Pinelands Commission’s approval document DOES NOT REQUIRE THAT THE CARBON:

“be left on site to be recycled back to the system”

If DEP were serious they would commit to this in their Plan.

If the Pinelands Commission were serious, they would have made this a condition of the approval of the DEP Plan. But no only did the Commission fail to include a permit condition that would mandate that cut trees be “left on site to be recycled back into the system“, the approval explicitly says the opposite: that trees are to be “cut and removed”.


The DEP Plan then goes further to attempt to justify the fact that logging will “significantly reduce the forest carbon pools throughout the site”. 

DEP makes unsubstantiated assertions that would not pass muster in a high school science class:

DEP manufactures, with no scientific support, no site specific analysis, or even an attempt at quantification, the following justification:

However, despite some carbon pool losses, this project will provide significant carbon defense to the surrounding forest through avoided emissions by reducing the risk of a rapid release of carbon to the atmosphere through catastrophic wildfire, including multiple Atlantic white-cedar stands and restored sites located along Bartlett’s Branch which contain significant carbon stores. This project will also allow for a break-up of the fuel ladder and will reduce the risk or likelihood of wildfire spread. Added benefits include making these stands more resilient under pressure from climate stressors such as drought or insect pest activity.

Some DEP claims not only lack scientific support, but conflict with science, e.g. logging creates more GHG emissions than wildfires, so the “avoided” emissions argument is flawed and the term “carbon defense” is a slogan .

There is no consideration or analysis of non-logging alternatives (the “no action” alternative and alternatives analysis of alternative management approaches are fundamental elements of NEPA EIS, but DEP is not subject to NEPA!).

Some DEP claims are far too broad and based on dubious science, e.g. wildfire can be ecologically beneficial so reducing likelihood is not always good (and the driving factors are temperature, humidity, drought, and wind conditions that have nothing to do with or are exacerbated by logging.) Insects like pine bark beetle are driven by warming,  not tree density, etc.

If so many young trees (2.4 million) are cut, how could this not significantly impact future carbon sequestration?

How can DEP generate numerical estimates of carbon, when they made no commitments to how the forest will be harvested and the cut trees managed? (i.e chipped and recycled, or burned as cordwood or fuel? See DEP’s options above)

Here are the summary tables DEP included, which raise a host of questions:

Screen Shot 2022-10-27 at 10.04.29 AM

Screen Shot 2022-10-27 at 10.06.14 AM

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The focus on “Merchantable cord wood” gives up the game, no?

(like how is it possible to cut and remove 2.4 million trees, reduce tree density from 2,173 trees per acre to 34 – 226 trees per acre, but only reduce forest carbon by 3.8% – 9% (is this a “net” analysis, i.e. is DEP assuming that all cut trees are not removed but left to be recycled? If so, that’s not what their application says or the Pinelands Commission approved. Is this carbon storage? or is it carbon sequestration? or is it combined storage and sequestration? Is it sequestration on an annual basis? Or over what timeframe?):

Why does the clearcut “firebreak” forest have a 24.7 tons per acre of carbon, the “feathered” forest have 36.6 tons per acre (50% more), and the “thinned” forest has 34.2 tons per acre?

DEP’s flawed carbon analysis can not be accepted – especially the concept of “forest defense”, i.e. log a forest to prevent a future wildfire in an adjacent forest.

It must not become the model for forestry management or analysis of carbon storage and sequestration.

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