[Important Update below]
The Assembly Telecommunications and Utilities Committee will hold a hearing today on the Christie Administration’s efforts to implement the greenhouse gas emission reduction goals of the Global Warming Response Act (see NJ Spotlight set up story: ASSEMBLY PANEL TO TAKE CLOSER LOOK AT GREENHOUSE GAS EMISSIONS.
We were highly critical at the outset of the Administration, see:
It’s only gotten worse since then.
The Obama Administration’s recently proposed rule for GHG emissions from new power plants will have no impact on NJ (see:
- Don’t Get Spun On EPA’s Proposed Greenhouse Gas Emission Rule
- Obama Weakens EPA Proposed Rule In Order To Promote New Coal Plants – Gets Praise From Enviro’s and Favorable Press
However in making that announcement on that proposed rule, the EPA stated the the upcoming proposed rule for existing power plants would rely on State primacy in setting emission reduction standards and regulatory requirements through the SIP process under the CAA.
Given EPA’s deference to State’s in regulating GHG emissions, it is critical that NJ get ahead of the curve and pursue strong and enforceable standards that can meet GWRA goals. A phase out of fossil fuel plants would be the way to do that.
The Christie Administration has shown no willingness or interest in such a policy. They remain in denial.
That means the Legislature will need to lead and do so aggressively.
I had planned to testify, but am under the weather, so I wrote a quick note this morning to the Chairman (see below).
We’ll listen to the hearing and let readers know what went on in a future post.
I really hope the environmental community turns out and testifies about the Christie Administration’s across the board failures in making climate change and greenhouse gas emission reductions a priority.
And that the NJ media covers the hearing.
Otherwise, this could become just another dog and pony show – weeks before an election – limited in scope to criticism of the Gov. exit from RGGI, with no real commitment by Democrats or ENGO’s to serious efforts to reduce GHG emissions.
This hearing could lay the groundwork for legislative initiatives in the next Administration, which must include far more than simply rejoining RGGI and reducing the RGGI cap.
Mr. Chairman – I had planned to testify at your hearing today, but unfortunately am unable to attend.
I’d like to submit written testimony for the record and ask that you hold the record open until early next week in order for me to do so.
In the meantime, allow me to make just a few points of emphasis here:
1. I hope you can focus today on the Administration’s record in implementing the emission reduction goals of the GWRA and the recommendations in DEP’s 2009 Report to the legislature.
This would include Commissioner Martin’s abolition of the DEP’s Office of Policy and Planning, which housed those scientific, policy, planning, and regulatory efforts. That Office’s responsibilities included the Coastal Management Program and climate change adaptation efforts along the shore, such as the Coastal Community Vulnerability Assessment Protocol, a pilot program DEP implemented in 3 shore towns.
Additionally, DEP has excised prior climate change vulnerability findings and recommendations from the Coastal Hazard Assessment in what is known as the “309 Report”.
2. I am not a fan of cost benefit analysis, but realize that NJ laws include important economic cost tests and that Gov. Christie’s Executive Order #2 requires CBA in regulatory initiatives.
In that regard, Senator Gordon recently held hearings on oversight of the Administration’s off shore wind program – one issue he flagged was the “cost test” and the methodology for meeting that test. That methodology ignores quantification of the environmental benefits of wind. In fact, the consultant’s Report the BPU relies on in this regard explicitly rejected consideration of the EPA’s “social cost of carbon”.
This serious flaw must be addressed legislatively.
3. NJ is now making making huge economic investments in fossil fuel power and infrastructure. I would hope your hearing explores the implications of these projects with respect to meeting the GWRA goals, renewable energy goals, and cumulative economic impacts on ratepayers.
Given the imperative of making reductions to avoid climate catastrophe and – literally – the collapse of industrial civilization, we must terminate these projects and instead invest exclusively in efficiency and renewables.
4. As you know, in 2005, DEP adopted regulations that define greenhouse gases as “air contaminants” under State law (NJ Air Pollution Control Act). In that rule proposal and adoption documents, DEP pledged a phased regulatory approach to implementing the deep emission reduction goals of the GWRA. However, DEP has not followed through on that pledge to regulate, and instead relied almost exclusively on the RGGI program.
Going forward, because RGGI is limited in scope to the electric sector and has other regulatory flaws and limitations, I would hope the Legislature would pursue a comprehensive and regulatory approach to GHG emissions reductions.
To send the correct market signals and provide incentives to shift to a renewable energy economy, this comprehensive regulatory approach must include a price on carbon.
As you know, in addition to a carbon tax, one approach would include application of US EPA’s “social cost of carbon” in various relevant state policies and programs.
5. Last, the Obama Administration’s recently proposed rule for GHG emissions from new energy sources will have no impact on NJ. In making that announcement, the EPA stated the the upcoming proposed rule for existing GHG emissions sources would rely on State primacy in setting emission reduction standards and regulatory requirements through the SIP process under the CAA.
Given EPA’s deference to State’s in regulating GHG emissions, it is critical that NJ get ahead of the curve and pursue strong and enforceable standards that can meet GWRA goals.
As you know, the Christie Administration has shown no willingness or interest in such a policy.
That means the Legislature will need to lead and do so aggressively.
I would be pleased to work with you on such a legislative initiative.
Sincerely,
[Update: 12:45 pm – The Committee hearing just adjourned.
At the end, there was no discussion among members; no summing up of the hearing; no vision or sense of future direction; no plan for followup; no going forward commitments; and no outrage or criticism over Gov. Christie’s Administration’s continuing refusal to appear.
Do they even know they have subpoena power? Why are Dems afraid to use it?
The testimony, aside from Lyle Rawlings of behalf of solar industry and Jim Walsh of Food & Water Watch and some of Tim Dillingham’s, was weak, vague, and not tied to specific policies, regulations, or laws, so as to be effectively useless.
The Democrats obviously are not serious and this was just a political stunt to whack the Gov. a few weeks before an election.
It was a classic dog & pony show, not worth the time to write about.
Ironically, adding insult to that injury, during the hearing I did get an email from NJ Audubon (AWOL at hearing) about Red Knot ESA, as if Red Knot habitat is not threatened by climate change.
I also got an email from NY/NJ Baykeeper (also AWOL at hearing) inviting me to a wine tasting event – shocking given the destruction of NY/NJ bays from climate change.
And, we saw an Op-Ed from the Keep It Green Coalition (also AWOL at hearing) – also shocking given their appeal for funding purportedly to protect lands vulnerable to climate change.
Such is the pathetic state of affairs in Trenton and the ENGO community.