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Jersey City Manifesto An Exercise In Magical Thinking Under the Guise of Leadership

Whitman & Dodge Foundation should dust off Professor Burchell’s 2001 Infrastucture Impact Assessment from the State Plan

Where Was Dodge 25 years ago when Gov. Florio issued Executive Order #114?

[Updated and corrected : 6/23/14 – NJ Spotlight reports today on their Friday panel discussion. I did not attend the event. I find it very interesting that today’s Spotlight story’s focus is on high costs and the need for significant rate increases is the exact opposite of the story below.  So I went back and re-read the Dodge/NJ Future Report (as I wrote below, I first read the report “quickly”) and discovered a serious error, which I correct below. I stand by the “green band-aid” and “regulatory driver” and Zimmer criticisms, but not the “no need for rate increase” claims.- end update].

Last week, I ridiculed NJ Environmental Infrastructure Trust Executive Director Zimmer’s testimony to the legislature for downplaying the need for major new revenue sources by implying that NJ’s $40+ billion water infrastructure deficit and crisis could be addressed by “efficiency” and cost cutting.

I wrote:

Amazingly, as the DEP panel gained momentum in their testimony, it all got so over the top that at one point, citing Camden County as a model, NJEIT Director Zimmer  suggested that infrastructure investments would LOWER user rates – he implied that lower interest payments on NJEIT loans, more efficient equipment (e.g. energy costs savings) and budget CUTS essentially would pay the debt service.

For a $40 billion deficit? Are you kidding me?

I wonder if that’s the kind of “financial” approach that Zimmer pursued in his private sector days as an investment banker working in “structured finance”.

Of course, Zimmer can crunch numbers and knows that “efficiency” and cuts can not possibly put even a minor dent in the deficit.

But politically, he has to say that because his boss, Gov. Christie, has flat out vetoed any new local or state revenues to pay for the huge deficit – things like water taxes or ratepayer increases in water user fees.

So, given the obvious political basis for Zimmer’s statement, I was rather surprised to learn that Zimmer’s spin was not unique, and seems to be coming from a larger, Foundation funded, playbook.

Specifically, in a set up piece for their Round Table panel on Friday, NJ Spotlight reported  (following a quote by Christie Whitman, of all people)

A proposed “agenda for change’’ laid out by policymakers who met in Jersey City last month suggested a number of steps, including working regionally, identifying a variety of funding sources, and implementing “green first’’ solutions wherever possible. That third recommendation involves using vegetation and soil to manage rainfall, rather than pipelines.

So, I hit the link and quickly read the Jersey City Manifesto (JCM): “An Agenda For Change for NJ’s Urban Water Infrastructure“.

Zimmer is not alone in his denial of the need to raise lots of new revenues and his delusions of “efficiency” and cost cutting.

The Jersey City Manifesto (JCM) – another Dodge Foundation product – shares those delusions, PLUS magical thinking about low or no cost “green” solutions:

Because green infrastructure solutions have the potential to control some of the flows that cause CSOs at the lowest cost with multiple benefits, municipalities should take a “green first” approach, including mapping strategic locations for green infrastructure projects, making local policy changes that facilitate implementation and building demonstration projects that make neighborhood benefits tangible.

[Correction – the Dodge/NJ Future Report does identify the need for rate increases, my initial “quick” read missed this:

In addition to the magical thinking about green band-aids, the JCM calls for bold leadership, but amazingly lays out an “Action Agenda” that shares Gov. Christie’s “no new tax” views on the need to generate new revenues to fund the deficit:

Before seeking ratepayer support for investment in major capital improvements, water utilities and departments should take aggressive action to optimize the efficiency and effectiveness of their existing systems and business practices. In addition, these entities should develop and implement asset management plans that sustain efficiency over time. Taking these foundational steps in a visible and transparent manner, and demonstrating the associated cost savings, will help utilities and departments build trust with ratepayers and establish credibility to pursue necessary but costly infrastructure upgrades. 

What kind of “leadership” is that?

Dodge thinks water utilities need to “build trust” and “establish credibility” – but they call for no new money and green band-aids as an “Action Agenda” to address a $40 billion infrastructure crisis? [see correction above]

Are you kidding me? You can’t tell people there’s a crisis, but tell them that if we could only cut the fat, they won’t have to pay for it. That’s snake oil, not leadership. [see correction above]

In my book, anyone who says that we face a $40+ billion crisis and in the same breath says we should approach it without new revenue and rate increases has no credibility whatsoever. [see correction above]

Worse, this kind of magical thinking reeks of hypocrisy and reinforces the Gov.’s premise that government and local authorities are at best bloated, wasteful, inefficient and incompetent bureaucracies, and at worst corrupt.

It reinforces transparently racist myths propagated in places like the Highlands that all those black folks in the cities are wasting “our water” that we have to surrender our development rights to provide (I’ve heard this almost verbatim at meetings in the Highlands).

And it will only generate further animosity towards those elite Foundation fed suburban “environmentalists” coming to preach to urban NJ about how to get their infrastructure house in order.

The most likely outcome is that CSO cities will use the low expectations – no new revenues and “low cost” “green infrastructure” – as cover for doing little or nothing.  Despite this lack of real action, the Foundations funded “advocates” will continue to be well fed. An agenda for the status quo.

Rather than “playing in traffic”, better that Christie Whitman, the Dodge Foundation, and NJ Future – strong historical backers of the State Plan – dust off Professor Burchell’s 2001 Infrastructure Impact Assessment from the State Plan.

Oh, but they can’t do that either, because – just like a call for new revenues and rate increases – that would embarrass Gov. Christie too. Christie has killed their much loved State Plan.

So, I’ll end on a delicious irony:

For many years, I and many others have criticized the State Plan as “toothless” and worked in vain to give it regulatory teeth in DEP programs. Dodge and State Plan proponents have opposed or not supported those efforts.

So, lets just say it  was a jaw dropping moment to read a Report where Dodge, NJ Future, and the State Plan crowd quietly admitted their decades long huge strategic error.

Specifically, the JCM expressly notes that DEP regulations were the “driver” and create an “opportunity”:

the most immediate driver for action is the federal and state regulatory requirement that 21 cities must control combined sewer overflows (CSOs) – a problem caused by aging combined (sanitary and stormwater) sewer systems and exacerbated by increasingly intense rainfall events. In late 2014, the New Jersey Department of Environmental Protection (NJDEP) is slated to issue final permits requiring the responsible cities and utility authorities to develop, adopt and initiate the implementation of CSO Long-Term Control Plans (LTCPs). 

Where was Chris Daggett and Dodge 25 years ago when Gov. Florio issued Executive Order #114 on integrating the State Plan in DEP regulations?

So wrong for so long and then they  pull the regulatory rabbit out of the hat! Now that’s one mean feat!

Monmouth County water main break after Hurricane Irene. Source: Star Ledger

Almost 10 years ago, back in 2005 testimony to the Clean Water Council, I emphasized the need for a public investment strategy and outlined a specific 23 point regulatory agenda and financial solutions.

• Bottom line: It remains to be seen whether today’s hearing was part of a process of building consensus and political will, or just another sham Dog & Pony.

Last week, a package of water infrastructure bills authorizing some $359 million were approved by the Senate Environment Committee with no testimony from DEP and virtually no debate, something I complained about in this post:

• Environmental Infrastructure Funding Bills Continue to Ignore Climate Risks and Adaptation

So I was pleased that yesterday, the Assembly Environment Committee conducted a special hearing on NJ’s crumbling water infrastructure and a huge deficit in financing some $40 billion in necessary upgrades.

DEP was invited and kicked off the testimony by touting their various efforts during and after Sandy, including a new permit program to control urban “combined sewer overflows” (CSO’s), their bridge loan program known as SAIL,  and new “Asset Management Guidance”.

NJ Spotlight covered the hearing, but their story left out context and many important issues, see:

NJ’S ARCHAIC WATER SYSTEM: THE $40B PROBLEM IN SEARCH OF A SOLUTION

Since good testimony was ignored in the Spotlight piece, I figured I’d cover it here.

• DEP comes out from hiding – spin is over the top

DEP and the NJ EIT testified. Let’ just say they were not in any way defensive about criticisms of their policy and performance.

Instead DEP went on offense and took credit for a suite of major new programs, including CSO controls, asset management, “resilience” (what ever that means), SAIL (bridge loan program), and Sandy rebuild.

But no one mentioned the inconvenient fact that only a lawsuit by NY/NJ Baykeeper forced them to take action on CSO’s after many years of foot dragging.

Amazingly, as the DEP panel gained momentum in their testimony, it all got so over the top that at one point, citing Camden County as a model, NJEIT Director Zimmer  suggested that infrastructure investments would LOWER user rates – he implied that lower interest payments on NJEIT loans, more efficient equipment (e.g. energy costs savings) and budget CUTS essentially would pay the debt service.

For a $40 billion deficit? Are you kidding me?

I wonder if that’s the kind of “financial” approach that Zimmer pursued in his private sector days as an investment banker working in “structured finance”.

Aside from the ludicrous nature of Zimmer’s claim (i.e. free lunch, something for nothing, just borrow your way out of the problem with no real cost), in Zimmer’s mention of CUTS, I sensed a bit of what the international lending agencies like the World Bank and IMF call “Structural Adjustment” – Neoliberal austerity where debt is used as an instrument of policy to force damaging concessions, like CUTS to social safety net programs.

This made me wonder if Zimmer’s NJEIT is doing quiet damage by imposing cost cutting conditions in NJEIT loans. We already know that DEP failed to comply with federal Buy American and prevailing wage requirements and that the Christie Administration is ant-union and anti-labor, so NJEIT imposed anti-labor cost cutting measures is not unthinkable.

In response to DEP’s self congratulatory testimony, they were unable to answer some very basic questions from Legislators to back up the rhetoric with facts.

I won’t go into all the details, but mention Assemblyman Benson’s question:

Q: How many of the over 500 wastewater and water facilities permitted by DEP have submitted asset management plans?

A: DEP reply: we don’t track that information, but none have. Actually, we are exploring what new legal authorities we may need to require asset management plans and have chosen to post Guidance on the website instead of enacting regulations.

So, the entire asset management initiative that DEP bragged about is non-existent: it is not being implemented and it is voluntary. The DEP doesn’t even track the information!

There were other embarrassing examples, my favorite was the pump station at Lake Como as 1 of just 2 minor SAIL post Sandy projects that have been accomplished – all this is too detailed to go into hear. Suggest you listen to the entire hearing (hit this link).

• Regulatory context ignored

The Association of Environmental Authorities and private water companies testified – much or their testimony praised DEP as a “partner”.

Absent from the Committee discussion was the reality that AEA’s members and private water companies are regulated by DEP, that there should be some tension if not an adversarial relationship between regulator (DEP) and the regulated; and that AEA members, for decades, have fought DEP efforts to enact tougher regulations on AEA members.

• Solutions Offered

Contrary to the impression created by the NJ Spotlight story, many specific and economically feasible solutions were presented to the Committee in testimony.

NY/NJ Baykeeper urged the Committee to restore and move prior bills on storm water utilities, green infrastructure, public disclosure of CSO discharges, and funding of natural oyster resilience projects.

I testified about DEP failure to use regulatory and planning powers under the Water Supply Management Act and the Clean Water Act as a means of driving investment and planning for climate change adaptation and asset management.

The DEP has abandoned and abdicated ints planning powers. The Water Supply master Plan is 25 years out of date and the Water Quality planning program has delegated DEP responsibilities to Counties and authorities. This is key failure, because DEP water permits must be consistent with these plans.

I also specifically recommended that DEP’s “asset management Guidance document” be incorporated in the the NJ EIT FY’15 legislative package released from the Senate Cmte last week – that package of bills has not yet been heard in the Assembly.

I testified about DEP’s failure to use inspection and enforcement powers to provide incentives (what Dan Van Abs referred to as “price signals”) to facilities to comply with current permit requirements regarding emergency planning, backup power, climate adaptation, etc.

I also cited specific economic methodologies that the legislature and DEP could include in asset management requirements, including lifecycle cost (and of course, external costs).

There is other recent legislation that has been killed by development interests, including:

1) expanded impact fees so that redevelopment becomes an opportunity to upgrade decrepit infrastructure;

2) Senator Smith’s water tax bill;

3) “flush” taxes on wastewater – (not yet introduced in NJ, but I think Maryland has enacted a fee on wastewater to fund Chesapeake Bay restoration work). and

4) stormwater or impervious surface fees (could be part of regional storm water utility legislation or statewide).

5) Almost 10 years ago, back in 2005 testimony to the Clean Water Council, I emphasized the need for a public investment strategy and outlined a specific 23 point regulatory agenda and financial solutions.

Unfortunately, despite all these good suggestions, at the close of the hearing, Committee Chairwoman Spencer made no summary statement that would suggest a going forward plan and no commitments for next steps or action items.

Bottom line: It remains to be seen whether today’s hearing was part of a process of building consensus and political will, or just another sham Dog & Pony.

But we will be back on this issues soon, when the FY 15 NJ Environmnetal Infrastructure package of bills is up before this committee. We’ll keep you posted

NJ Has Huge Climate Vulnerability, Crumbling Infrastructure, and Poorly Managed Assets

“The vague and unenforceable allusions in the legislation to an undefined goal of improving “resilience” is a total abdication of legislative policymaking powers.”

[Updates below]

A package of bills to finance water infrastructure, including drinking water and sewage treatment systems damaged by Sandy, is up today in the Senate Environment Committee, see this for links to the bills. (S2122 –S2123 – SCR 117)

As we recently noted, according to the US National Climate Assessment Report, NJ is the only northeastern state without a Climate Adaptation Plan.

The Christie Administration has no intention of developing one, so the Legislature must step up to the plate and mandate that this work get done. Infrastructure financing legislation is an appropriate place to do so.

The current bills fail to include such mandates – either by individual loan recipients or statewide by the DEP. The vague and unenforceable allusions in the legislation to an undefined goal  of improving “resilience” is a total abdication of legislative policymaking powers.

In addition, according to a recent Rutgers/NJ Future Report, NJ’s water infrastructure is in crisis. Assets are poorly managed and crumbling.

We’ve written about this issue numerous times and urged DEP to enforce their recent “Asset Management Guidance” document, most recently, see:

• CHRISTIE’S OTHER HIDDEN MULTI-BILLION DOLLAR DEFICIT – No Plan to Pay for Huge Water Infrastructure Shortfall Aggravated by Sandy.

I am unable to attend and testify at today’s hearing, so I fired off this note to Chairman Smith:

Mr. Chairman: I can’t make it to Sen. Env. Cmte hearing today to testify on the  infrastructure financing bills that are up.

I wanted to make these key points – please accept this note as testimony:

1. DEP recently released “Asset Management Guidance” – the DEP Guidance says that compliance with it will be required for projects that get Financed by NJEIT or SRF or Sandy money

Compliance with this Guidance is a very important issue to clarify in the bill and the water authorities are concerned about it

Links to DEP Guidance and details here:

http://www.peer.org/news/news-releases/2014/04/15/christie’s-other-hidden-multi-billion-dollar-deficit/

2. The bills do not require that recipients conduct vulnerability assessments for climate change impacts.

According to the recent US National Climate Assessment Report, NJ is the only northeastern state without an Adaptation plan.

“Of the 12 states in the Northeast, 11 have developed adaptation plans for several sectors and 10 have released, or plan to release, statewide adaptation plans. 139″

http://nca2014.globalchange.gov/report/regions/northeast

Conditions must be placed on the money by the Legislature, because the Christie Administration is not doing so.

3. The water and sewer facilities impacted by Sandy were not in compliance with their DEP permits – emergency plans, back up power, etc.

This new round of money should require compliance as a condition.

We have raised this issue with EPA as a potential violation of federal requirements.

4. Why is $70 million of the money going to “redevelopment projects”

http://www.njleg.state.nj.us/2014/Bills/S2500/2122_I1.PDF

We have HUGE existing deficits – all money should go to those deficits.

Redevelopment should pay its own way.

5. The bills provide loan forgiveness. Give multi-billion deficits, loan principal forgiveness is not a good idea –

Bill Wolfe, Director

NJ PEER

[Update #1 – NJ Environmental Infrastructure Trust Executive Director Zimmer – who, according to the Mastro Report is a personal friend of and was hired by DEP Commissioner Bob Martin –  testified in support of the package. He said nothing new or controversial, but came off as condescending and self congratulatory.

In 1983, Zimmer graduated from the University of Dayton with a degree in Civil Engineering. In 1984, Zimmer received his MBA from Notre Dame University. Thereafter, Zimmer spent twenty-two years in the private sector in positions at investment banks and commercial banks, working mainly in structured finance.

In 2010, Zimmer was approached by Robert Martin, Commissioner of the New Jersey Department of Environmental Protection (“DEP”) and a friend of Zimmer’s, about overseeing the New Jersey Environmental Infrastructure Trust (“EIT”). In late 2010, Zimmer joined the EIT as Executive Director.

Does that make Zimmer a “corporate crony”? “Structured finance” is the reckless and often fraudulent type of finance that took down the economy in the 2008 crash – how fitting, given Bob Martin’s career in privatization of public assets in Thatcher’s England. Neoliberal con men, both!

Jeff Tittel of Sierra then testified and raised many of the same points above. He was harsh in his criticism of multiple policy failures by the Christie Administration and DEP regarding climate and adaptation.

Chairman Smith asked in NJEIT had a response to Tittel’s criticism.

Executive Director Zimmer’s reply was totally lame and evasive – (he did not rebut and actually confirmed Tittel’s criticism. Zimmer said)::

1. NJEIT is DEP’s bank – Tittel raised policy issues. We don’t do policy.

2. Whether DEP has a resilience policy or not, the primary objective of spending the money is to improve water quality. Projects comply with federal laws. Resilience is objective.

But despite Zimmer’s total failure to defend the Christie Administration and DEP or in any way rebut Tittel’s criticism, there was NO DISCUSSION OR RESERVATIONS OR CONCERNS EXPRESSED BY ANY LEGISLATOR.

The package of bills and SCR were released by unanimous vote.

So much for legislative deliberation.  –

[Update #2 NJEIT’s Zimmer and his assistant Frank Scangerelle (sp?)  were asked 2 easy questions, to which they gave embarrassingly stupid answers:

1. Chairman Smith asked about specific Barnegat Bay projects. Zimmer and Scangerlle both emphasized BBay projects in their testimony. Remarkably, neither could mention specific projects. Smith asked for a followup letter with details.

2. Senator Thompson asked “what is the difference between 100% principal forgiveness and a grant?”

NJEIT replied: “That’s our legalese with EPA”.

Federal law prohibits grants. NJEIT just admitted to evading federal law via “legalese” DUMB. I think I make inquiry to EPA Region 2 about that right now.

[Update # 3 – 6/9/14 – NJ Spotlight did an uncharacteristic superficial and misleading story on this package of bills today, see:

• State will ante up $1.25 billion for cleaner drinking water, better wastewater control

First of all, the state isn’t “anteing up” anything – these are authorizations to issue loans to local governments. I felt obligated to set the record straight with this harsh comment:

Readers:

1) The plants lacked backup power and were knocked out of service because they were in violation of their DEP issued permit, which mandate emergency plans and things like back up power and fuel.

DEP never monitored compliance with those permits or enforced violations.

The Lessons” of Sandy were not new – there had been multiple warnings, reports, and storm events like Irene.

2) This is not State budget money – this is authorization to issue debt by the NJ Environmental Infrastructure Trust and loans to authorities, private water purveyors, and local governments.

3) This year, the bills provide for “principal forgiveness” a legal game for grants. NJEIT representatives were dumb enough to openly testify that it was “legalese with EPA”. Grants are not allowed under federal law, so we’ve gone to EPA about that.

4) The DEP just released “asset management Guidance”. According to DEP Guidance, compliance will be required as a condition of a NJEIT loan or federal money. I tried to get that language in the bill but was rebuffed. It is a very big deal

5) Neither DEP nor the NJEIT have specific policies or standards or a PLAN for what defines “resilience”.

The word is a slogan not a policy.

6) NJ is the only state in the northeast without a climate adaptation plan – infrastructure “resilience” is a key component of these plans. CHrisite DEP is not serious nor is the legislature.

7) Rutgers and NJ Future just issued a MAJOR report on NJ’s crumbling water infrastructure.

Where were they at the hearing? Hiding under their desks?

The annual NJEIT financial cycle is an appropriate place to inject the findings from that Study. But the authors were AWL.

8) The coastal groups, who are funded to advocate for “resilience” and adaptation planning were present at the hearing but neither ALS of COA testified – why not?

9) The planning groups and those that work on climate change were present at the hearing but said nothing. Why was RPA not prepared onto talk about the investment of almost $359 million dollars in infrastructure?

No other news outlets covered the hearing so I had to supplement this story with some hard facts and a different perspective

Wolfe

end updates.]

NJEIT Office – new office looks rather upscale and corporate, in keeping with the Christie Adminisitration’s values

EPA Asked To Oversee Enforcement of Permits To Prevent Sandy Failures

Gov. Christie’s Austerity Approach Accelerates Crumbling Infrastructure

A photo from Monmouth County of the affected pipe (source: Star Ledger) (June 2012)

In another example of hiding controversial and important policy decisions under obscure DEP website links, the Christie DEP recently posted a new “Asset Management” Guidance document.

The DEP is posting documents in dribs and drabs as part of the long delayed Water Supply Master Plan Update.

DEP apparently thinks this voluntary Guidance developed  “by invitation only” friends behind closed doors can substitute for a robust public planning process, backed by enforceable regulations and real funding mechanisms.

But buried in the weeds of that Guidance is a huge admission by DEP – Sandy exposed the fact that water and sewer facilities violated the terms of their permits and that DEP failed to monitor, inspect and enforce these permit requirements.

According to NJ’s “Sandy Recovery Plan”

“At the height of the storm, 94 wastewater treatment systems suffered failures or disruptions, including inadequate treatment, broken sewer mains, and other operational issues. The loss of electrical power rendered many water systems unable to maintain service. Even at plants where backup generation was available, the disruption of the petroleum production and delivery system caused generator fuel supplies to be limited.

The vast majority of New Jersey’s community water supply systems were impacted: 427 of 604 community water systems experienced power loss during the event. As a direct result of the service interruptions, 362,334 New Jersey residents were placed under a boil water advisory. One month after Superstorm Sandy made landfall, eight drinking water systems in Ocean County, serving approximately 10,000 households, were still subject to a boil water advisory. ”

Those severe failures were predicted and preventable.

Based on those failures, PEER requested that EPA conduct oversight and condition any future federal funding on compliance.

Get the full story, with links to the documents, from our friends at PEER:

For Immediate Release:  Tuesday, April 15, 2014
Contact:  Kirsten Stade (202) 265-7337

CHRISTIE’S OTHER HIDDEN MULTI-BILLION DOLLAR DEFICIT
No Plan to Pay for Huge Water Infrastructure Shortfall Aggravated by Sandy  

Trenton — New Jersey is facing a massive and growing financial gap in its ability to protect water supplies and infrastructure but has no plan to pay for needed improvements or prevent coming water emergencies, according to documents posted today by Public Employees for Environmental Responsibility (PEER). A water infrastructure deficit pegged at nearly $13 billion several years ago has now ballooned by impacts and implications of Super-Storm Sandy, sea level rise and expected extreme weather events.

An “Asset Management” Guidance document quietly posted earlier this month on the state Department of Environmental Protection (DEP) website is the latest placeholder for the long overdue Update of the State Water Supply Management Plan.  In this Guidance, the state acknowledges that in order to safeguard drinking water supplies it must invest heavily in upgrading sewage treatment plants, controlling sewer overflows, installing backup generators and shielding other waterworks.  Yet, it has no plan for doing so:

• The Statewide Water Supply Management Plan has not been updated in nearly 20 years and is based upon hydrological data from the 1980’s;
• The state admits its legal duty to “require drinking water and wastewater utilities to demonstrate that they have adequate facilities, and equipment, and that they regularly perform operation and maintenance to meet the conditions in their permits,” according to the Guidance document but has no timetable for enforcing these requirements; and
• Governor Chris Christie does not want to discuss how to pay for these heavy investments, given the tough choice of impinging on private water company profits or raising customers’ utility rates.

“Our water infrastructure deficit is a yawning fiscal sinkhole which the Christie administration wants to treat like it is merely a decorative koi pond,” stated New Jersey PEER Director Bill Wolfe, a former long-time DEP analyst.  “The post-Sandy factors now in play make our already huge water infrastructure needs both more expensive and urgent – they will not go away.”

The state’s failure to enforce “resilience” and “asset management” requirements in DEP permits is not merely academic – it could jeopardize federal Clean Water Act funding tied to these same requirements.

Today, PEER wrote to U.S. Environmental Protection Agency Regional Administrator Judith Enck to inquire when resilience and asset management requirements for water infrastructure would be invoked.

The state’s continuing malaise was underlined in the April 3rd transmittal email from DEP’s Water Supply Modeling & Planning chief, Jeffrey Hoffman, on the release of its Asset Management Guidance:

“I checked and am told that it is DEP’s goal to eventually incorporate these guidelines into regulations. DEP is open to suggestions on how to improve the guidelines in order to create more effective regulations.  I am not aware of any formal review process or meetings but comments are welcomed.”

“Unfortunately, our water infrastructure deficit is compounded by a leadership deficit,” added Wolfe. Pointing out that since the notoriously anti-regulatory Gov. Christie has no schedule for converting these thorny and costly voluntary standards into mandatory regulations, it is likely the problem will be left to his successor.  “Ensuring healthful water supplies for New Jersey should not be just another political can kicked down the road.”

###

Read the PEER letter

Examine New Jersey’s vague new Guidance on Asset Management

Revisit water emergency in immediate wake of Sandy

Look at historic $12.8 billion water infrastructure deficit

See how Sandy multiplied water infrastructure needs

New Jersey PEER is a state chapter of a national alliance of state and federal agency resource professionals working to ensure environmental ethics and government accountability

Sea Level Rise and More Severe Coastal Storm Surge Wipe Out Both

I am working on something else today, so will keep this note brief.

I just read another Scott Gurian NJ Spotlight story on Sandy recovery, this one emphasizing the relative allocation of Sandy recovery funds between housing versus infrastructure, see:

•  NJ’S PLAN FOR NEXT BATCH OF SANDY AID KEEPS FOCUS ON HOMEOWNERS, RENTERS

The story’s focus is misplaced (again) and it manufactures a false conflict between planning, environmental, and housing advocates.

The fundamental flaw that unites the housing and infrastructure programs is the Christie Administration’s failure to plan.

There is no plan – and no vision – for the coast as a whole, especially in light of rising sea levels and more intense coastal storms as a result of climate change.

Shockingly, the NGO’s are not providing that criticism or that vision.

The failure by the Christie Administration to plan and seriously engage climate change risks are far more significant than the relative allocation issue between housing and infrastructure.

Housing and roads and water and sewer and energy infrastructure are equally vulnerable to climate change impacts. And they all must be integrated in a land use plan that works – otherwise we simply rebuild the failed status quo and highly vulnerable development pattern.

Buying vulnerable properties without an overall land use and development plan is a fool’s errand.

In fact, President Obama issued an Executive Order on exactly this issue: adaptation to climate change – and HUD revised their CDBG funding rules along similar lines.

No time to rehash all this right now – readers may be interested in this analysis:

• CHRISTIE CLIMATE DENIAL IMPERILS SANDY RECOVERY FUNDS

• NEW CHRISTIE SANDY SPENDING PLAN HAS GAPING HOLES