Biden Administration Promoting Failed Voluntary Carbon Market Trading Schemes

May 28th, 2024 No comments

Market Price Just Collapsed – Price Less Than 0.5% Of True Social Cost Of Carbon

Scientific Reports Document Major Flaws

Murphy DEP Urged To Not Go There

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The Biden Administration just issued policy guidelines to promote voluntary carbon market trading schemes, see:

[Red Flags:

  • Land management agencies are making significant investments in improved soils, grassland, and forest data at home and abroad that will reduce measurement uncertainty and support the integrity of VCMs.
  • Expanding market opportunities for credible credit providers is an important component of the United States’ climate strategy. Addressing the barriers (e.g., high transaction costs) facing credit generating suppliers—including farmers, ranchers, forest owners, small businesses, developing country jurisdictions, and others—can improve the overall ability of VCMs to produce high integrity credits that advance decarbonization and generate economic opportunity.

The ill-timed and ill-conceived move comes in the wake of several scientific reports that found major flaws with the current voluntary market program and the collapse of the price in 2023.

Even the pro-Biden and pro-market Neoliberal NY Times reported that today:

Yet a growing number of studies and reports have found that many carbon offsets simply don’t work. Some offsets help fund wind or solar projects that likely would have been built anyway. And it’s often extremely difficult to measure the effectiveness of offsets intended to protect forests.

I’ve long been an opponent of all forms of market based pollution trading schemes.

Recall this 2001 Trenton press conference (I did the analysis and presented it as NJ Sierra Club Policy Director). (from the Bergen Record)

EMISSIONS TRADING PROGRAM CRITICIZED AS BOON TO POLLUTERS
By ALEX NUSSBAUM, Staff Writer
Date: 02-15-2001, Thursday

The state’s industries may be taking advantage of a law that allows them to buy or sell the right to pollute, environmentalists said Wednesday.

The five-year-old system that allows companies to trade air pollution credits has loopholes that make it impossible to tell if factories or power plants are really reducing emissions, critics said at a Trenton news conference.

That work led directly to – and I can take credit for killing the Whitman Administration’s voluntary “Open Market Emissions Trading” (OMET) program.

For an in depth blow by blow analysis of that, see:

the main problem with market-based systems concerned the big picture of emissions trading and its relation to existing policy — the fundamental change of approach to regulating air pollution. Federal officials were concerned with the transition from a regulatory style rooted in command-and-control thinking to one further complicated by a new incentive framework and whether or not it could be administered effectively. […]

The proposed federal [OMET] rule also stipulated that any state seeking to incorporate OMT programs had to comply with federal guidance for all EIPs and this stipulation required incentive programs to be “designed to benefit both the environment and the regulated entity” (EPA, 1995). The OMET program clearly violated this condition. New Jersey’s own SIP submission clearly stated “no VOC or NOx emissions reductions were projected to be associated with the implementation of the NJ OMET program(Wolfe, 2001). […]

The public comment period required by the conditional approval prompted joint written comments from the New Jersey Chapter of the Sierra Club and PEER to EPA’s IG.

Those formal written comments itemized the two group’s concerns regarding EPA’s proposed approval despite “numerous cautionary findings by the Inspector General that such programs may be deeply flawed and would pose a hazard to public health.” In addition, the groups collectively claimed that facilities “used this never-approved program both to generate credits and use them to demonstrate ‘compliance’ with the Clean Air Act’s requirements” (Ruch and Wolfe, 2001).

The IG responded to the concerns of PEER and New Jersey’s Sierra Club by initiating an investigation in 2001 that focused on the emissions trading programs launched in New Jersey and Michigan.

(Source: Ruch, J. and Wolfe, B. (2001). Letter to Nikki Tinsley, Office of Inspector General, US Environmental Protection Agency. Public Employees for Environmental Responsibility, Washington, DC and New Jersey Chapter of the Sierra Club, Princeton, NJ).

More recently, just 3 weeks ago I wrote to get the word out that the Murphy DEP was developing a carbon trading program for NJ, including for forest management, see:

So, given the Biden Administration’s new push (and likely funding for), there is likely to be additional pressure on DEP to move forward with an expanded carbon trading scheme (beyond the RGGI cap and trade program, which provides several million dollars for carbon sequestration in forests).

To try to nip this in the bud, I sent another warning letter to legislative and Murphy DEP policymakers and environmental and climate activists:

———- Original Message ———-

From: Bill WOLFE <b>

To: “shawn.latourette@dep.nj.gov” <shawn.latourette@dep.nj.gov>, “john.cecil@dep.nj.gov” <john.cecil@dep.nj.gov>, senbsmith <SenBSmith@njleg.org>, sengreenstein <sengreenstein@njleg.org>, “senmckeon@njleg.org” <senmckeon@njleg.org>, “asmScharfenberger@njleg.org” <asmScharfenberger@njleg.org>

Cc: “jonhurdle@gmail.com” <jonhurdle@gmail.com>, “ferencem@njspotlightnews.org” <ferencem@njspotlightnews.org>, “wparry@ap.org” <wparry@ap.org>, “fkummer@inquirer.com” <fkummer@inquirer.com>, “O’Neill, James” <ONeillJ@northjersey.com>

Date: 05/28/2024 8:28 AM EDT

Subject: Biden – Forestry carbon markets

Friends – The Biden administration just issued policy guidance on voluntary carbon market trading, see today’s NY Times story which was surprisingly critical:

Carbon Offsets, a Much-Criticized Climate Tool, Get Federal Guidelines

https://www.nytimes.com/2024/05/28/climate/yellen-carbon-offset-market.html

I’ve previously criticized carbon markets, most recently in response to the Murphy DEP’s development of a offset/trading program, particularly for forest management, see:

Scientists Report: Market Based Carbon Trading Scheme Fails To Protect Forests Or Reduce Poverty

http://www.wolfenotes.com/2024/05/scientists-report-market-based-carbon-trading-scheme-fails-to-protect-forests-or-reduce-poverty/

So, I thought I’d share this additional relevant scientific study, which found:

“Our analysis identifies important areas where the protocols deviate from scientific understanding related to baselines, leakage, risk of reversal, and the accounting of carbon in forests and harvested wood products, risking significant over-estimation of carbon offset credits.”

Comprehensive review of carbon quantification by improved forest management offset protocol

https://www.frontiersin.org/articles/10.3389/ffgc.2023.958879/full

Those flaws possibly explain why the market has collapsed: (see attached graph)

https://www.spglobal.com/commodityinsights/en/market-insights/latest-news/energy-transition/010524-price-slump-in-2023-clouds-outlook-for-voluntary-carbon-market

I urge NJ policymakers in the Legislature and at DEP to just say no to trading and offset programs, particularly for forest management.

Any market based incentives should be based on the EPA Social Cost of Carbon (with the most conservative assumptions) and implemented via regulations.

Wolfe

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Wissahickon Valley Park (Philadelphia)

May 25th, 2024 No comments

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We found a fairly secluded beach along Wissahickon Creek.

The creek flows through Wissahickon Valley Park.

Lots of good trails, with interesting history.

Charlie loved it too.

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Murphy DEP Misleading The Public About The Declining Health Of The Ocean

May 24th, 2024 No comments

Annual Shore Tourism Public Relations Campaign Is Based On Lies By Omission

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The ocean is in very, very bad shape.

A range of severe and unprecedented problems – from record high water temperatures, to increasing acidification, to over-fishing, to toxic chemical and nutrient overloads – threaten the collapse of ocean ecosystems.

For the latest science see, e.g. NOAA’s Climate Program Office.

None of that science was even mentioned in the Murphy DEP’s shameless shore tourism promotion.

You would never know about any of that based on reading the Murphy DEP’s annual Memorial Day shore tourism event, see:

Lies come in two forms: omission and commission. Intentionally withholding material facts with the intent to mislead is a lie. DEP is lying to the public by presenting only the “good news”.

And you would never know that based on the lame and corrupted “advocacy” efforts of shore focused environmental groups, including Clean Ocean Action, American Littoral Society, and Save Barnegat Bay Partnership.

Those groups have one important thing in common: they receive DEP grant money, see:

They all sold out their mission long ago in exchange for  the DEP grant money.

It’s called “co-optation”.

So, as you get outside over the Memorial Day Weekend, please think about the health of the ocean.

I just wrote to Murphy DEP Commissioner Latourette and asked him to stop the “good news” spin, see:

———- Original Message ———-

From: Bill WOLFE

To: “shawn.latourette@dep.nj.gov” <shawn.latourette@dep.nj.gov>

Cc: Benson Chiles <bensonchiles@gmail.com>, “zipf@cleanoceanaction.org” <zipf@cleanoceanaction.org>, “tim@littoralsociety.org” <tim@littoralsociety.org>, senbsmith <SenBSmith@njleg.org>, sengreenstein <sengreenstein@njleg.org>, “senmckeon@njleg.org” <senmckeon@njleg.org>, “wparry@ap.org” <wparry@ap.org>, “fkummer@inquirer.com” <fkummer@inquirer.com>, “ferencem@njspotlightnews.org” <ferencem@njspotlightnews.org>, “jonhurdle@gmail.com” <jonhurdle@gmail.com>

Date: 05/23/2024 4:34 PM EDT

Subject: State of the ocean

Dear Commissioner LaTourette:

Today, the Department released the annual Memorial Day tourism promotion, see:

https://nj.gov/dep/newsrel/2024/24_0020.htm

Once again, the Department misled the public about the health of the ocean, by focusing exclusively on a scientifically invalid indicator: bacteria, and single human use of the ocean and shoreline: swimming and beaches.

I take strong issue with the omissions of science regarding the real ecological health of the ocean.

The tourism promotional event provides a teachable moment. See NASA’s SOTO:

https://www.earthdata.nasa.gov/technology/state-ocean-soto

So, we look forward to an honest press release that mentions, among other things, record high ocean temperatures, acidification, overfishing, fish and  shellfish consumption advisories, ecological collapse, and NOAA’s projected 85% likelihood of a more intensive Hurricane season.

And what ever became of the Coastal and Ocean Protection Council established by the legislature as an “in but not of” DEP Council? I wrote the bill for Senator Smith and it was signed into law as P.L. 2007, CHAPTER 288, approved January 13, 2008, see:

  • What Ever Happened To The NJ Coastal And Ocean Protection Council?

http://www.wolfenotes.com/2021/11/what-ever-happened-to-the-nj-coastal-and-ocean-protection-council/

Wolfe

c: Chairman Smith

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Polluters’ Lobbying Conference Stacked With Former DEP Officials

May 23rd, 2024 No comments

This Is What Revolving Door Corruption Looks Like

Murphy DEP Sends An Assistant Commissioner

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[Update below – Amended Ethics Complaint]

The NJ Business and Industry Association (NJ BIA) is holding an “Environmental Regulatory Conference” on June 4. The public Registration fee is a cheap lunch, only $185.

You can register and see the mug shots of all the hired guns and former DEP officials at this link.

The speakers include 9 former high level DEP officials, one current, and one Governor’s Office legal counsel:

Chris Daggett (Commissioner); Ray Cantor (Deputy Commissioner); Irene Kropp (Deputy Commissioner); Michele Siekerka (Deputy Commissioner); Dennis Hart (Assistant Commissioner); Dan Kennedy (Assistant Commissioner); Sean Moriarty (Deputy Commissioner); Gary Sondermeyer (Chief of Staff); Ray Bukowski (Assistant Commissioner) and John Valeri (Christie Gov.’s Office). Current Assistant Commissioner Haymes is speaking on site remediation (I’m sure that’s just fine with current Commissioner Shawn LaTourette, who himself is a former corporate lawyer who worked for some of NJ’s largest corporate polluters to defeat DEP enforcement, including site remediation and recovery of natural resource damages).

(I worked with many of these people and could dish a lot of dirt, but for now, will mention only one: Mr. Ray Bukowski was directly involved in a very dirty deal directly involving Donald Trump and he lied about it. He also served as a political hack to defend DEP logging on Sparta Mountain.)

I recently filed an ethics complaint against former Murphy DEP Deputy Commissioner Sean Moriarty for potential violation of post employment restrictions, see:

Ironically, that complaint focuses on ethics restrictions on post employment regarding actions to “provide information not generally available to members of the public” – or inside information.

NJ BIA’s priority regulatory agenda includes land use, site remediation, implementation of the environmental justice regulations, and – my favorite: (emphases mine):

How to Improve DEP Regulatory Programs: Lessons Learned from the Inside and Outside

There have only been a few professionals who both led major regulatory reform efforts while a leader at the DEP, and then left the department for a career in the private sector. What did they learn from their unique experiences and what advice would they offer future department leaders on how to create efficient and effective regulatory programs.

Did you catch that?

NJ BIA is openly celebrating the revolving door.

They are touting the corporate benefits of former DEP officials who “provide information not generally available to members of the public.”

Meanwhile, while the corporate community is hiring former DEP regulators and making significant investments in regulatory policy, the NJ Environmental Community has virtually disappeared from substantive engagement on the regulatory policy scene and devolved to a state of cheerleading the DEP Commissioner.

Seated (L-R) 1) Anjuli Ramos (Sierra Club NJ Chapter) 3) DEP Commissioner LaTourette) 4) Doug O'Mallley (Environment NJ)

Seated (L-R) 1) Anjuli Ramos (Sierra Club NJ Chapter) 3) DEP Commissioner LaTourette) 4) Doug O’Mallley (Environment NJ)

The NJ BIA conference is an egregious illustration of revolving door abuse of the public interest.

The fact that they openly brag about that pretty much sums up the current state of corruption of government we are now witnessing.

Not much else I can say right now.

[Full Disclosure: I am a former (for 14 years) DEP professional that “led major regulatory reform efforts while a leader at the DEP”.]

[Update: Amended Ethics Complaint

I just sent this note to the State Ethics Commission:

Dear Ethics Commission – I would like to amend my May 10 complaint below with the following information, which provides additional evidence of potential violations of post employment restrictions.

Former DEP Deputy Commissioner Sean Moriarty is speaking at the June 4 NJ Business and Industry Association conference on “regulatory policy”, see:

https://njbia.org/events/erc2024/

The agenda for that conference includes at least 3 major regulations recently adopted by DEP that Moriarty participated in and directly managed in his portfolio as Deputy Commissioner: 1) environmental justice regulations; and 2) land use regulations, including the flood hazard (inland and coastal) regulations.

He also participated in confidential legal policy deliberations on Natural Resource Damage lawsuits that are currently active and will have prospective effects.

In those capacities, Moriarty obtained sensitive “information not generally available to the public”, and is now selling that information to corporate clients.

I appreciate your prompt and favorable consideration.

Bill Wolfe ~~~ end update]

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An Open Letter To Gov. Murphy’s Environmental Lapdogs

May 21st, 2024 No comments

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This is a deplorable record that you should be denouncing, not praising.

You are a corrupt and cowardly crowd that should be ashamed of yourselves.

My letter below is a reply to an Open Letter from “environmental” groups thanking and praising NJ Gov. Murphy. It has all the signs and smells of a political sham led by Ed Potasnak of NJ LCV, Gov. Murphy’s biggest “green” cheerleader, see:

Former Friends and Colleagues:

I was appalled – but not surprised – by your most recent effort to praise Gov. Murphy and DEP Commissioner LaTourette, and again mislead the public about numerous State Parks related issues.

Let’s begin with some context and important facts you left out of your letter:

1. According to DEP Commissioner LaTourette’s testimony to the legislature on DEP’s budget, there is a $720 million unfunded deficit in State Parks maintenance.

2. The Murphy administration’s non-response to this deficit is privatization via EXACTLY the SAME private Parks Foundation institution and non-transparent process that has been deployed in the Liberty State Park “debate”, an initiative you absurdly praise.

3. This deficit was greatly exacerbated by your own “Keep It Green” campaign, which stripped the CBT Constitutional dedication of $32 million per year to Parks (approximately $250 million since passage) and greatly reduced historic annual Green Acres funding (some of which funds parks). Since 2016, that deficit has grown from $400 million to $720 million – a HUGE backlog.

https://www.northjersey.com/story/news/environment/2017/06/28/archive-budget-cuts-doom-state-parks-disrepair/400817001/

4. Gov. Murphy killed the CBT surcharge, which reduced Open Space (and parks) funding by over $60 million so far and will continue to do so.

5. The Murphy DEP’s failure to enforce current land use and water resource regulatory authority to reduce development and land conversion has led to the loss of thousands of acres of farms and forests and wetlands and an explosion of hundreds of millions of square feet of new warehouse development.

Instead of enforcing existing law and regulation to slow that development, the administration now supports expensive buyouts, see the most recent $27 million deal:

https://www.njspotlightnews.org/video/residents-rejoice-after-preservation-plan-prevents-warehouse-development/

6. The Murphy Administration supported the siting of solar on farmlands, thus leading to hundreds of acres more losses.

7. The Murphy administration blocked the Highlands Council from pursuing more stringent forest protections, leading to the loss of more forest resources.

8. The Murphy DEP continues to pursue scientifically sham forestry management projects and has failed to close current regulatory and statutory loopholes, thereby needlessly logging and burning hundreds of acres of forests.

9. The Murphy administration has been abysmally slow and lax in addressing the destruction of Pinelands forests and wetlands by off road vehicles.

10. The Murphy administration has interfered with and undermined the independence and strength of the Pinelands Commission, just as bad as Gov. Christie did.

11. The Murphy DEP denied a petition for rulemaking to strengthen policies to reduce risks from development in high wildfire hazard locations. Yet DEP logs Pinelands forests allegedly to reduce these risks.

12. The proposed DEP “REAL” coastal sea level rise flooding regulatory initiative is based on the failed engineering approach of the past (e.g. elevated buildings and structural remedies, including beach replenishment). The proposal rejects a DEP role in saying “NO” to development proposals and it ignores real solutions like “strategic retreat’. The Murphy administration has failed to request legislative amendment to eliminate the “right to rebuild” storm damaged properties, which is a major source of the problem and driver of NJ’s nation leading repetitive flooding FEMA claims.

13. The DEP’s inland Flood hazard regulations are deeply flawed and are based on a scientifically obsolete and unreliable 100 year storm frequency statistic.

14. The DEP has not kept pace with proposal of Category One waters designation, which is allowing sensitive stream buffers to be destroyed and water quality to degrade.

15. The Murphy DEP has failed to repeal and strengthen several land use and water resource regulatory rollbacks by the Whitman and Christie DEPs.

16. There were numerous stealth efforts by the Murphy administration to privatize Liberty State Park. The examples are too detailed to mention here, but Sam Pesin is fully aware of them and can brief you. The Gov. did not support legislation to block privatization.

17. The final plans for “redevelopment” of Liberty State Park will be made in Trenton by the Legislature, not DEP. So, DEP is not in control of the final disposition of their plans at this point in time.

18. The Murphy administration has turned the State Plan from a land use plan to an economic development and business promotion platform (worse than Gov. Christie’s “Red Tape” Commission).

19. Finally, the Murphy Administration is the first Democratic administration in my career horizon (40 years) that I recall has no land use protection or environmental legacy.

And this list is just off the top of my head – I missed several others.

This is a deplorable record that you should be denouncing, not praising.

You are a corrupt and cowardly crowd that should be ashamed of yourselves.

[PS – instead of kissing the Gov.’s ass, right now you should be conducting a full court press to demand a veto of the bill to gut the Open Public Records Act. DEP already abuses that law to suppress science and operate in secrecy.] 

Bill Wolfe

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