Review of Pinelands Gas Pipeline And New Power Plant Fails to Consider Climate Change Impacts

$500 Million Fossil Fuel Infrastructure Project Would Promote Massive New Greenhouse Gas Emissions

Over the past decade an overwhelming body of scientific evidence has emerged linking anthropogenic emissions of CO2 to climate change and sea level rise. The projected climate impacts and related impacts on ecosystems and society related to increasing concentrations of CO2 in the atmosphere due to anthropogenic emissions supports the conclusion that CO2 should no longer be disregarded in the formation of environmental policy. […]

2.3 New Jersey-Specific Impacts

Climate change resulting from anthropogenic emissions of CO2 and other greenhouse gases is expected to have significant negative impacts on New Jersey ecosystems, coastal property, air quality, and human health. As a result, CO2 emissions can no longer be considered benign and would clearly meet the Department’s definition of air pollution at N.J.A.C. 7:27-5.1.   

~~~ NJ DEP – Oct. 18, 2004 –  basis for rule to define greenhouse gases as regulated  air pollutants.

Almost a decade ago, the NJ Department of Environmental Protection (DEP) defined greenhouse gases as “air pollutants” under State law, emphasizing that those emissions “should no longer be disregarded in the formation of environmental policy.”

A few years later, in 2007, the Legislature enacted the Global Warming Response Act establishing aggressive greenhouse gas emissions reductions – roughly 20% lower emissions by the year 2020, and 80% reduction below 2006 levels by 2050.

Yet almost a decade later, the environmental review and approvals for a proposed $500 million regional fossil fuel infrastructure project does not consider – at all – the air pollution and greenhouse gas emissions from the pipeline itself, or the power plant it is designed to serve.

The South Jersey Gas Co. (SJG) has proposed 22 mile 24 inch wide gas pipeline through the Pinelands National Reserve, designed to re-power the B.L. England power plant, would provide enough gas to power 267,000 homes.

Let me repeat that; neither the Pinelands commission staff review or the applicant (South Jersey Gas Co.)  presentation to the Commission even mentions air pollution, greenhouse gas emissions, or climate change impacts.

[The Clean Air Act permit issued to the B.L. England plant by DEP also did not regulate GHG emissions. Long story on why that is the case, beyond the scope of this post. Long story short: DEP failed to follow through and adopt permit regulations, while the Legislature backed a market based cap/trade scheme known as RGGI, instead of DEP regulatory controls.]

Despite extensive public testimony to the Pinelands Commission on the climate change issues and impacts of the project – including my specific recommendation that the Commission task staff with examining this issue – no member of the Commission has uttered one word on the topic.

How can that be possible?

This is a remarkable failure, in and of itself, given the significance of the climate change issue.

But it is bizarre and inexcusable given that Pinelands Forests are now being devastated by climate change impacts – the impacts on Pines forests are so severe and the link to climate change so clear, that the Pinelands have become a case study in the ecological effects of climate change on forests.

Here is what the US Forest Service research says about climate change impacts on forest resources: USFS stresses that “sufficient scientific information is available to begin taking action now.”

This report is a scientific assessment of the current condition and likely future condition of forest resources in the United States relative to climatic variability and change. It serves as the U.S. Forest Service forest sector technical report for the National Climate Assessment and includes descriptions of key regional issues and examples of a risk-based framework for assessing climate-change effects.

By the end of the 21st century, forest ecosystems in the United States will differ from those of today as a result of changing climate. Although increases in temperature, changes in precipitation, higher atmospheric concentrations of carbon dioxide (CO2), and higher nitrogen (N) deposition may change ecosystem structure and function, the most rapidly visible and most significant short-term effects on forest ecosystems will be caused by altered disturbance regimes. For example, wildfires, insect infestations, pulses of erosion and flooding, and drought-induced tree mortality are all expected to increase during the 21st century.  […]

Significant progress has been made in developing scientific principles and tools for adapting to climate change through science-management partnerships focused on education, assessment of vulnerability of natural resources, and development of adaptation strategies and tactics. In addition, climate change has motivated increased use of bioenergy and carbon (C) sequestration policy options as mitigation strategies, emphasizing the effects of climate change-human interactions on forests, as well as the role of forests in mitigating climate change. Forest growth and afforestation in the United States currently account for a net gain in C storage and offset approximately 13 percent of the Nation’s fossil fuel CO2 production. Climate change mitigation through forest C management focuses on (1) land use change to increase forest area (afforestation) and avoid deforestation, (2) C management in existing forests, and (3) use of wood as biomass energy, in place of fossil fuel or in wood products for C storage and in place of other building materials. Although climate change is an important issue for management and policy, the interaction of changes in biophysical environments (e.g., climate, disturbance, and invasive species) and human responses to those changes (management and policy) will ultimately determine outcomes for ecosystem services and people.

Although uncertainty exists about the magnitude and timing of climate-change effects on forest ecosystems, sufficient scientific information is available to begin taking action now. Building on practices compatible with adapting to climate change provides a good starting point for land managers who may want to begin the adaptation process. Establishing a foundation for managing forest ecosystems in the context of climate change as soon as possible will ensure that a broad range of options will be available for managing forest resources sustainably.

The Pinelands have become a case study on forest ecosystem impacts of climate change, see: Effects of Climatic Variability and Change on Forest Ecosystems: A Comprehensive Science Synthesis for the U.S. Forest Sector –

In that assessment, the Pinelands impacts are presented as a case study, see: The Southern Pine Beetle Reaches New Jersey Pinelands – Box 2.3 – p.19).

The US Forest Service is working on and will soon release more research on climate change impacts on pines forests.   US Forest Service is about to release this research report:

Title:  Climate Change and Carbon and Nitrogen Dynamics in the NJ Pine Barrens

We are assessing the interactive effects of fire management and insect defoliation on tree species composition, carbon, and nitrogen dynamics in the New Jersey Pine Barrens. We are determininghow interactions among these disturbances affect management goals. Our goal is to create a framework for understanding landscape to regional management scenarios in areas with multiple, interacting management priorities that can be applied across the US.  We use then use this framework to project future changes and may be caused by climate change or changes in fire management policy.

Given prior and ongoing research, it is simply inexcusable for the Pinelands Commission to stick its head in the sand and ignore all these climate change driven ecological impact issues during the review of a fossil pipeline.

In a subsequent post, we will connect the dots between scientific research and the Commission’s jurisdiction and legal authority to regulate the proposed pipeline with respect to greenhouse gas emissions and impacts of climate change on Pinelands forest, ecological, and water resources.

[Update: Thought I’d provide a table to show that DEP regulators don’t even look at carbon/greenhouse gas emissions – see this side by side comparison of emissions from a coal versus new gas plant in Vineland:

Source: NJ DEP (hit link above for document)