WolfeNotes.com

Murphy Administration Retains Christie Administration Pro-Energy Industry Policy

No Public Involvement In “By Invitation Only” Industry Dominated Stakeholders

McCabe claims 71 industry reps to Zero public is a “broad range of stakeholders”

As I recently wrote, NJ DEP does not consider the impacts from the emission of greenhouse gases or climate change during environmental reviews and permit approvals of, among other things, major fossil infrastructure including oil and gas pipelines and compressor stations.

But flaws in DEP regulations and review processes are perhaps even worse than that.

Specifically, DEP’s own documents reveal that representatives of the oil and gas industries jointly wrote a major DEP pipeline regulatory review guidance document designed to protect public health, safety, and the environment.

Several of the gas companies seeking DEP approvals literally wrote their own regulatory requirements.

Industry representatives did that without any public involvement or awareness, during an industry dominated “by invitation only” Stakeholder process begun and conducted by the Christie administration under Commissioner Martin’s “Transformation” initiative.

Take a look at all the technical guidance documents written, and that list is just for the site remediation program.

Take a look at the industry dominated groups that wrote them. I counted 71 representatives of regulated industry or paid industry consultants – and not one public member, environmental group member, local government representative, or independent scientific or academic expert.

That Sham Stakeholder process is still part of the Murphy Administration’s DEP and still part of the DEP website (see this link for documents). Note that it is prominently displayed on the DEP website, just under the photo of Commissioner McCabe.

In fact, the McCabe DEP has expressly supported that Sham – the DEP website states (my emphasis):

Site Remediation Program
Stakeholder Process

Acting Commissioner McCabe and Assistant Commissioner Pedersen believe that working with a broad range of stakeholders is essential to continuing the growth and success of the Licensed Site Remediation Professional (LSRP) program. To this end, the Department continues to implement an extensive stakeholder process to address general program issues, rules, and guidance. 

How can 71 industry representatives and zero public, environmental or academic represeantives possibly constitute a “broad range of stakeholders”? Echoes of George Orwell!

[Also recall that “Candide” McCabe praised this industry dominated, privatized site remediation program with this fact free spin: from a McCabe statement)

Contaminated sites are getting cleaned up thoroughly and in a timely manner.

So, several weeks ago, I reached out to Tanya Oznowich, the DEP Stakeholder contact to ask specifically if current DEP Commissioner McCabe had provided any policy guidance regarding revisions to the Christie DEP initiative, including: 1. whether  the “by invitation only” practice would continue; 2. whether additional public stakeholders would be named to the industry dominated groups; and 3. whether the current  and “recurring meetings” would continue; and 4. whether McCabe would continue to implement it.

In a June 5, 2018 email, I wrote:

Has Acting Commissioner McCabe provided guidance on the Stakeholder process?

Will it continue? Will the “by invitation only” policy continue? Are there new issue groups being formed? Will all current Stakeholder be retained? Will new Stakeholders be named?

Shortly thereafter, in a June 5, 2018 email, Larry Hajna, a DEP press office flack replied:

Bill – I’m a bit backed up right now but will look into this.

Hajna never got back to me, nor did Tanya Oznowich.

So either McCabe is continuing the Christie/Martin Stakeholder policy and practice or she is avoiding the issue.

I do know that McCabe is secretly meeting with various Stakeholders on an ad hoc basis, however, and that no records are being maintained regarding these meetings. So, in some ways, this is actually worse than Christie/Martin structured and policy driven Stakeholder rollback practices. At least public records of those meetings were maintained and meeting participants were disclosed.

McCabe doesn’t disclose who she is meeting with or what she is meeting about – and McCabe even denied my OPRA request that she disclose these meetings.

Here’s how I came across the fact that the pipeline review guidance was co-written by oil and gas industry representatives.

I recently filed an Open Public Records Act (OPRA) request for public documents related to NJ DEP’s environmental review of the proposed Transco pipeline (known as the “Northeast Supply and Enhancement Project”) and came across the following reference to a “Linear Construction Technical Guidance” document DEP cited in a January 10, 2017 letter to Transco and FERC:

A review of the Linear Construction Technical Guidance document revealed the following:

Here is how DEP describes the use of the pipeline review document:

Here is how DEP describes the 71-0 industry dominated stakeholder process (note that Transco had two representatives involved):

DEP air, water, & land use permits do not consider greenhouse gas emissions or climate impacts

Massive Regulatory Failure Ignored By Gov. Murphy

NJ Gov. Murphy has repeatedly claimed to place a high priority on a science based approach to reducing greenhouse gas emissions and responding to the huge challenges of climate change.

So has his DEP Commissioner McCabe.

But when the NJ Department of environmental protection issues any permit or approval – including for oil and gas pipelines, for fossil fueled power plants, or for any form of development, including coastal or riverfront development that would be inundated by climate driven flooding, storm surge, or sea level rise – the applicant is not required to provide data on greenhouse gas emissions and NJ DEP experts do not review or consider greenhouse gas emissions or climate change impacts.

NJ DEP regulations do not authorize the DEP to condition or deny a permit based on potential greenhouse gas emissions of potential climate impacts.

No NJ DEP regulatory standard is is based on climate science – NONE – including air quality permit standards that govern air permits for major sources of greenhouse gas emissions.

Does Gov. Murphy even know this?

So, I find it remarkable that Murphy Administration officials – including Attorney General Grewal and NJ DEP Commissioner McCabe – have the chutzpah to criticize the Federal Energy Regulatory Commission (FERC) for failing to consider climate change in FERC reviews.

NJ Spotlight reported today:

Not only does FERC ignore climate-change implications, the Attorney General argued the agency fails to consider the full range of environmental impacts. “As the Attorney General for a state impacted by natural gas pipeline approvals, I know that FERC needs to be much more careful in its overall approach to pipelines,’’ he said.

New Jersey Department of Environmental Protection Commissioner Catherine McCabe agreed, saying “now is the time for the agency to analyze and reduce environmental harms. “Reducing and responding to climate change is a priority for the DEP,’’ McCabe said, “and there is an urgent need for FERC to improve its review process to account for all environmental harms.’’

DEP Commissioner McCabe ignores the fatally flawed regulatory standards and review processes of her own agency, while blasting FERC.

That is gross hypocrisy and I call bullshit on it.

Governor Murphy – or his Co-Governor wife Tammy – should pick up the phone and call DEP Commissioner McCabe and ask her how DEP considers greenhouse gas emissions and climate  change impacts in permit decisions, particularly given the McCabe DEP’s recent permits issued to almost 2,000 MW of new fossil fueled power plants and the extension of the Pinelands gas pipeline and BL England power plant permits (which all failed to consider climate change).

And why aren’t NJ environmental groups flagging this issue?

Why do NJ press outlets give NJ DEP and Gov. Murphy a pass on this remarkable hypocrisy?

NJ environmental groups should get to work immediately on drafting a petition for rule making and organizing a Trenton Statehouse press conference to demand that Gov. Murphy direct NJ DEP Commissioner McCabe to promulgate comprehensive regulations to mandate consideration of greenhouse gas emissions and climate change risks and impacts in all DEP regulatory decisions.

This would provide a legal basis for DEP to deny permits or require off-sets and/or mitigation for GHG emissions and climate impacts.

As I’ve previously written, former Gov. Florio’s Executive Order #8 provides a model and strategy for how to do this, see:

• Florio Administration’s Policy on Energy and Environment Still Relevant Today
• Memo To Gov. Murphy – The “Green” Honeymoon Is Over

[End Note: NJ DEP air regulations require some GHG emissions sources to report emissions and some DEP regulations are indirectly based in part on projected climate impacts, e.g. coastal rules consider sea level rise and storm surge, and some infrastructure is subject to 500 year storm frequency purportedly to incorporate climate impacts.

But these are indirect surrogates, i.e. window dressing and do not provide DEP a basis to condition or deny a permit based on GHG emissions or climate impacts.

Demolition and new construction is not “reconstruction”

DEP playing a dangerous game by relying on WQMP consistency

What happened to the “moral imperative” to avoid fossil infrastructure?

The Murphy DEP just issued approval of an exemption under DEP’s Highlands rules for a proposed new 700 megawatt fossil fueled natural gas power plant in Holland Township along the Musconetcong River in the Highlands Preservation Area (read the news coverage).

So much for Gov. Murphy’s “moral imperative” to invest in energy infrastucture “that does not produce greenhouse gases.”

In issuing the exemption the DEP did not issue all final DEP permits and approvals. The DEP found the project “inconsistent” with the *Upper Delaware Water Quality Management Plan (WQMP). But that WQMP can be amended to incorporate the project and simultaneously the project can seek other DEP permits while the WQMP amendment process is underway.

Instead of playing regulatory games, DEP had the chance interpret the exemption rules to deny the exemption request and send a clear message that a horrible fossil fueled project in the Highlands Preservation Area that threatens a premier trout river is just not acceptable.

They failed to do that.

The DEP’s “Highlands Applicability Determination” found that the project was exempt from the DEP’s strict Highlands regulations because it was “reconstruction” of an existing building and met the standards  on new impervious surface.

But the demolition of a building and construction of a new power plant is not “reconstruction” of an existing building.

It is demolition. It is knock down and rebuild.

The DEP should have distinguished “demolition” and “new construction” from “reconstruction”.

By failing to do so and instead issuing a green light, the Murphy DEP set a terrible precedent which invites abuse.

It will open the door for this project to abuse other loopholes in DEP permit rules and invite many other projects to exploit this Highlands exemption loophole, which was intended to be a narrow exemption for legitimate redevelopment of existing structures, e.g. conversion of an old industrial building to new commercial or loft residential uses, or historic preservation projects that retain the existing structure.

The “reconstruction” exemption was narrow because it’s sole focus and only restriction was on the amount of impervious surface created by the new development.

In contrast, reflecting the Act’s multiple objectives, the DEP Highlands rules apply to a broad set of environmental conditions, and set significant restrictions on new development in order to discourage development and protect water resources and preserve the natural landscape and natural resources.

But the impervious cover restriction is limited to generation of stormwater runoff, which involves protection of water quality and reduced risks of flooding.

In constrast, the proposed new power plant will have huge impacts completely unrelated to the amount of impervious surfaces, such as withdrawal and discharge of millions of gallons of hot water into one of NJ’s finest trout streams, the Musconetcong River.

And tons of carbon from fossil fuel natural gas (along with fine particulates and other air pollutants).

The Musky is a DEP designated “Category One” (C1) Trout Production (TP) water. DEP regulations protect the river from “any change in existing water quality“, including temperature changes.

Trout require cold water and high levels of dissolved oxygen.

The power plant will discharge hot water contaminated by various pollutants.

The most restrictive water quality standard likely is the temperature criteria.

But DEP surface water quality standards and temperature criteria contain loopholes that the power plant will seek to exploit – including “mixing zones” and “regulatory heat dissipation areas””

The DEP’s temperature criteria conflict with the DEP’s Category One anti degradation policy which prohibits “any measurable change in existing water quality”:

But the loophole is created by how changes are “measurable”, e.g. temperature or water quality are measured after a “mixing zone or “heat dissipation area”.

The fact that the Murphy DEP folded on the “reconstruction” exemption does not inspire confidence that they will enforce the C1 water quality standards or other regulations that could block the project.

Those regulations include the Water Quality Management Planning rules and WQMP for the Upper Raritan and the Water Allocation rules.

I could conduct a similar exercise to show loopholes and technical discretion in those rules.

And history has shown that those rules also have loopholes and require the exercise of discretion by DEP. 

The Murphy DEP – like every DEP – has not shown the will the exercise discretion to protect the environment when powerful economic and political forces are involved.

Be warned – if I can think of these loopholes, lobbyists and lawyers and consultants for power companies can too.

Amazingly, there was no public comment on the DEP Highlands Applicability Determination – what the hell are those Wm Penn Foundation funded folks at the Highlands Coalition doing?

[* Correction. Original was based on error in DEP’s letter. DEP wrote “Raritan” instead of Delaware. I transcribed their error. I was thinking 3 paragraphs ahead on regulatory issues as I transcribed the DEP error. Embarrassing mistake. But far worse for DEP to have made it.]

A First Step on A Path Forward To Implement Your Climate Promises

Gov. Florio’s Executive Order No. 8 Provides A Model

Not 6 months into his tenure, Gov. Murphy’s energy, climate and environmental policy agenda he campaigned on is in disarray and the Legislature has seized control.

I won’t rehash all the details in this post, but the Bergen Record’s recent scathing editorial “A string of losses for the environment” pretty much summed things up:

Big Corporate Polluters 2 — New Jersey, its people and its environment 0.

This is the score we might have expected were Gov. Chris Christie still in office.

On the environmental front, Gov. Murphy has yet to revoke Gov. Christie’s rollback Executive Orders #1 – 4 and Christie appointments still serve as Executive Directors of the Pinelands Commission and Highlands Council.

Murphy’s DEP Commissioner Catherine McCabe took 6 months to get confirmed. As we’ve been noting here, McCabe retained many Christie DEP managers and continuity with Christie DEP policies, and has done virtually nothing during her tenuous tenure other than issue press releases and PR stunts that echo Gov. Christie’s initiatives.

On energy policy, Senator Sweeney rammed a nuclear bailout bill through the legislature that seriously compromised the Gov.’s commitment to a 100% renewable energy pledge.

On climate policy, the Gov.’s policy agenda is limited to rejoining the Regional Greenhouse Gas Initiative (more on that soon) and directing BPU to revise the Christie Energy Master Plan to promote 3,500 MW of off shore wind.

Murphy has no governing experience and has surrounded himself with either recycled Corzine hacks or young staffers with no Trenton or regulatory experience. Instituitionalizing legislative control over Murphy’s DEP, Senate President Sweeney’s Legislative aide Eric Wachter was installed as DEP Chief Of Staff and Assemblyman McKeon’s legislative aide was installed as Director of DEP’s Office of Government Relations. (see DEP Org Chart)

In that leadership vacuum, the Pinelands pipeline is seeking DEP permit extensions, DEP decisions on controversial pipelines under Raritan Bay (Williams) and the Delaware watershed (PennEast) are pending, and a proposed new fossil fueled power plant on the banks of NJ’s finest trout stream in the heart of the NJ Highlands has emerged.

Given these awful developments, we thought this brief note on the mechanics of exercising Gubernatorial leadership might help.

Gov. Murphy probably does not know – and lame NJ environmental groups are certainly not letting him know – that former Gov. Florio, among others, provides stunning parallels and a directly relevant model to address the situation he faces right now.

Politically, like Gov. Murphy now faces on pipelines, energy, and climate, upon assuming office in 1990, Florio was faced with stiff environmental and public opposition to garbage incinerators.

On reversing prior policy, like Murphy inherited bad policies from Gov. Christie, Florio’s predecessor, the Kean Administration had promoted a pro-incineration policy. To implement that Kean policy,  DEP approved 21 County Solid Waste plans and incinerator permits for more than $3 billion of new incineration projects. These were all bond financed and/or approved by DEP and/or BPU. Worse, the legislature had effectively deregulated BPU economic review of incinerator procurement contracts to promote the industry (i.e the “McEnroe” law).

In terms of commitments, like Murphy, Florio had made promises to environmental groups – who had endorsed him in the campaign – to develop an aggressive solid waste policy that promoted recycling and discouraged incineration.

Florio not only had to reverse the Kean policy and use DEP power to over-rule and embarrass 21 County Freeholder boards, he had to claw back prior DEP planning, permitting and financing approvals – for $3 BILLION in investment.

This is actually MORE difficult to do than for Murphy to kill pending fossil infrastructure projects.

Here’s how Florio did that – and how Murphy can tackle very similar problems on energy infrastructure and climate policy.

On April 6, 1990 (well before Earth Day and in his administration’s “first 100 days”), Gov. Florio issued Executive Order #8, which established a “Emergency Solid Waste Task Force” and laid out a public planning process going forward. PLEASE READ THE WHOLE THING!

Here’s the core provision that put teeth in the policy:

4. During the Task Force’s deliberations over the next 120 days, the following shall apply:

a. The Department of Environmental Protection shall not issue a final approval of any solid waste management plan that sites increases the capacity of or approves financing for waste-to-energy resource recovery facilities;

b. The Department of Environmental Protection shall not issue a approval of Preliminary or Final Environmental and Health Impact Statements for any waste-to-energy resource recovery site or facility;

c. The Department of Environmental Protection shall not issue tentative or final approval of any solid waste facility engineering design now pending or hereafter submitted for any waste-to-energy resource recovery facilities;

d. The Department of Environmental Protection, the Board of Public Utilities and the Division of Local Government Services within the Department of Community Affairs shall not, pursuant to N.J.S.A. 13:1E-136 et seq., issue any approval or conditional approval of any previously submitted proposed contract for the design, financing, construction, operation or maintenance of a waste-to-energy resource recovery facility; and

e. No State agency, commission or organization shall approve the issuance of debt or extend financing to any person or entity for use in planning, designing, acquiring, constructing, operating or maintaining a waste-to-energy resource recovery facility.

Gov. Murphy could issue a similar Executive Order establishing an Emergency Climate Change and Energy Task Force tied to the BPU Energy Master Plan revision process and the DEP Climate mitigation and adaptation planning & regulatory process (including RGGI).

The Order could impose a moratorium on any DEP and BPU approvals of any fossil  energy infrastructure approvals, such as the Pinelands, PennEast and Williams pipeline and the recently proposed new gas plant in the Highlands.

Problem solved.

So why aren’t NJ’e environmental groups advocating this aggressive approach?

That is more than ironic, as they celebrate Gov. Byrne’s Pinelands legacy. Byrne used Executive power to force the Legislature to pass the Pinelands Act. Similarly, Gov. Kean used Exetuvie power to force passage of the Freshwater Wetlands Act. And Gov. McGreevey created a Highlands Task Force that was used to forge the Highlands Act.

The climate crisis if far more serious than the solid waste crisis that Florio inherited.

We call  on Gov. Murphy to step up and follow the path of his predecessors.

[Full disclosure: as a disloyal whistleblowing DEP bureaucrat, I was directly involved in the development of the Floio EO #8. Despite being requested to staff the Taskforce effort by the Gov.’s Office, I was blocked from participating by my DEP managers. Regardless, I was insubordinate and provided much of the technical analysis and backup data the Taskforce relied on and that formed future DEP Solid Waste Plan. As they say that all good deeds go unpunished, I receive formal discipline by DEP managers (a 1 week suspension) for that work.]

First major test of Gov. Murphy’s Climate Leadership

SJG requests DEP permit extensions

Get a competent lawyer and immediately petition DEP to deny the extension request. This must happen before June 23

[Update: 6/29/18 – Murphy DEP ignored public comments and rubber stamped the extension requests, see Press of Atlantic City story:  South Jersey Gas gets permit extensions for pipeline

The pipeline, called the Cape Atlantic Reliability Project, continues to meet Coastal Zone Management and Freshwater Wetlands Protection Act rules, said the letter from Division of Land Use Regulation Manager Ryan J. Andersen.

The Christie DEP approved pipeline never complied with those permit regulations and their biased permit approvals should have been re-opened.

The Murphy Administration now owns the Pinelands pipeline.

In an attempt to downplay the issue and dodge any responsibility, the approval was issued by a lowly Bureau Chief. Shame on them.~~~ end update]

To avoid expiration, South Jersey Gas (SJG) recently quietly requested that the Murphy DEP extend permits issued for the controversial Pinelands pipeline, which was strongly backed by the Christie administration.

The extensions are requested for a freshwater wetlands “General Permit” (GP) and an individual Waterfront Development permit (IP). The Christie DEP issued these permits in July 2013.

These extension requests are not automatically granted by DEP, but are subject to review. DEP has adequate discretion for denial of the extension requests under DEP rules (e.g. for waterfront development IP extension, see: NJAC 7:7-27.3). DEP denial would force SJG to apply for new permits and begin the permit process all over again, under presumably more aggressive Murphy DEP oversight and purportedly strict climate and energy policies.

After SJG benefitted from green lighting numerous regulatory approvals by the Christie administration, the ball is now in the Murphy DEP’s court.

How DEP handles these SJG requests will be the first major test for Gov. Murphy’s claim to climate leadership. If the Murphy DEP rubber stamps the SJG extension request, they own this project.

Murphy recently signed Legislation (the PSEG nuke bailout bill) that declared a “moral imperative” that the State pursue infrastructure that “does not not produce greenhouse gases“:

Given the overwhelming scientific consensus that fossil-fuel use is causing potentially irreversible global climate change and the attendant environmental catastrophes, it is a moral imperative that the State invest in energy infrastructure within and outside the State that does not produce greenhouse gases. ~~~ Nuke bailout law, P.L. 2018, c.16

The SJG fossil fueled gas pipeline not only “produces” huge quantities of greenhouse gases via methane leaks (methane is a potent GHG: it has 80 – 100 times more warming potential than CO2 in the short run), it also is part of a huge fossil energy infrastructure, which includes re-powering the BL England fossil fueled power plant, which also is a huge emitter off greenhouse gases.

During the original regulatory review of the pipeline by the Board of Public Utilities, DEP, and the Pinelands Commission, SJG made claims that the pipeline was critically needed to avoid catastrophic loss of electric power and gas service to the region. They made claims that the lights would go off and people would freeze in the dark without gas or electric power (i.e. the sham vulnerability and reliability argument). BPU Order summarized as follows:

To avoid these alleged critical energy infrastructure vulnerabilities –“including the potential for blackouts” (see p. 31) – SJG pressured BPU, DEP and the Pinelands Commission to expedite approvals for the pipeline. BL England made the same arguments about the power plant.

While completely ignoring the science and risks of climate change, the Christie BPU agreed with these SJG scare tactics and concluded (see p. 42)

Amazingly, the Christie DEP press office openly revealed bias in this incredibly unprofessional false statement in support of the SJG scare tactics:

Considine also defended the project on grounds that closing the plant, which sits on Little Egg Harbor in Upper Township, would increase the risk of brownouts in South Jersey. (Philadelphia Inquirer, 8/8/16)

For SJG to now request extension to avoid expiration of DEP permits – after 2 Christie DEP extensions of air pollution compliance deadlines and 5 years of construction delays – exposes the lies they told about the critical and pressing nature of the energy infrastructure vulnerability. 

On that basis alone, DEP should deny the extension requests and force SJG through a new permit review process under the Murphy administration’s “moral imperative” energy infrastructure and climate policy.

But there are additional grounds for DEP to deny the extension requests for failure to comply with DEP regulations.

Specifically:

1) the pipeline and BL England projects have changed;

2) important facts and environmental conditions have changed;

3) DEP regulations have changed. Under DEP permit extension rules, if the rules change, then DEP must DENY the extension request. No wiggle room. They must deny. The wetlands rules have changed regarding: a) GP #2; b) HDD under streams; and c) the definition of water quality certificate changed, a change that effects both the waterfront development and wetlands permit regulations); and,

[CLARIFICATION – rule change is not an automatic basis for denial. The applicant must demonstrate compliance with rule changes. Review and rejection of that demonstration is how the Murphy DEP could reverse Christie DEP regulatory policy.]

4) the original DEP permits were deficient and fatally flawed.

Specifically, neither the applicant SJG nor DEP ever conducted a water quality analysis to demonstrate compliance with NJ surface water quality standards. DEP therefore lacks any factual basis to issue the permit approvals or the water quality certification mandated by law.

Regulatory approvals that lack any factual basis in the administrative record are routinely rejected by courts as “arbitrary and capricious”. Courts do no defer to agency expertise when there is no factual basis in the record to support the agency’s decision.

The SJG extension request now provides the opportunity to re-litigate these issues with the more receptive Murphy DEP.

In addition to the rules governing permit extensions, other DEP regulations specifically include authority to re-open and/or amend or revoke permits if mistakes were made or if material facts were ignored or if material facts have changed.

Pipeline activists must put a full court press on Gov. Murphy and Acting DEP Commissioner McCabe and demand that they deny the SJG extension requests and force SJG back through a de novo permit review process.

DEP has just 15 days – the clock started ticking on June 8, 2018 – to make a decision so advocates must work very quickly and aggressively. Get out a letter to the Gov., issue a press release, and hold an event at the DEP building.

Get a competent lawyer and immediately petition DEP to deny the extension request. This must happen before June 23.

[Update: I just sent this Hail Mary letter requesting legislative oversight:

Dear Chairman Smith:

On June 8, 2018, South Jersey Gas (SJG) requested that DEP extend freshwater wetlands and waterfront development permits issued by the Christie Administration’s DEP to the controversial Pinelands pipeline.

DEP has just 15 days to make a decision under applicable DEP regulations. DEP has adequate authority to deny the SJG request as it does not comply with DEP regulations governing permit extension.

Briefly, the project has changed, material facts have changed, applicable regulations have changed, and the underlying permits were defective for failure to conduct required water quality analysis to demonstrate compliance with NJ surface water quality standards and provide a basis to issue the water quality certification required under DEP’s own regulations.

The Legislature recently found:

“Given the overwhelming scientific consensus that fossil-fuel use is causing potentially irreversible global climate change and the attendant environmental catastrophes, it is a moral imperative that the State invest in energy infrastructure within and outside the State that does not produce greenhouse gases. ~~~ Nuke bailout law, P.L. 2018, c.16

Given this “moral imperative” to avoid investments in fossil infrastructure and the biased regulatory process under which the Christie administration issued DEP, BPU and Pinelands Commission approvals, I urge you to conduct legislative oversight of DEP’s review of the SJG extension request.

Time is of the essence.

I discuss this issue in more detail in the article below.

I appreciate your timely support.

Respectfully,

Bill Wolfe

Murphy DEP Given Chance To Kill South Jersey Gas Pinelands Pipeline

http://www.wolfenotes.com/2018/06/murphy-dep-given-chance-to-kill-south-jersey-gas-pinelands-pipeline/