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Greenhouse Gas Emissions From Fracked LNG Scheme Ignore Climate Emergency

Would Wipe Out Benefits Of Billions of Dollars In Renewable Energy Investments 

I modified original photo by Catskill Mountainkeeper

The first task is to put the economy at the service of peoples. Human beings and nature must not be at the service of money. Let us say NO to an economy of exclusion and inequality, where money rules, rather than service. That economy kills. That economy excludes. That economy destroys Mother Earth.

The economy should not be a mechanism for accumulating goods, but rather the proper administration of our common home. ~~~ Pope Francis

A coalition of environmental groups from the four States that comprise the Delaware River Basin (NY, NJ, PA, DE) today begin a week long targeted coordinated campaign to pressure their State Governor’s to oppose a proposed Liquified Natural Gas (LNG) plant on the Delaware River.

The campaign is in advance of the Delaware River Basin Commission (DRBC) public meeting on December 9, 2020, where the agenda for the meeting vaguely alludes to possible “action” on the LNG scheme (see item #6 on the DRBC agenda).

That bureaucratic ambiguity is in keeping with a pattern of obfuscation and misleading claims on this project, by DRBC and the NJ DEP, (remarkably, the Murphy DEP already quietly issued various permit approvals) see:

• Murphy DEP LNG Permit Approval & Suspension Exposes A Rigged And Corrupt DEP Permit System
• Did Senate President Sweeney and/or NJ Gov. Murphy Pressure Regulators To Keep Delaware LNG Export Terminal Under The Radar?

The environmental groups have far more resources than I, so I’ll just provide some background and make a few political and policy points that their public action alerts have either ignored or not adequately focused on.

1. We are in a climate emergency and have just a decade to phase out fossil fuels to avoid catastrophe

The climate emergency demands a moratorium on new fossil infrastructure and a rapid phase out of existing fossil fuels. (See: IPCC Report on Global Warming of 1.5 degrees C)

It is literally insane to be building more fossil infrastructure and increasing fossil fuel production.

2. Approval of this LNG fossil fueled scheme would make a mockery of State climate and energy plans

The Governors of NY (Cuomo) and NJ (Murphy) have made climate and renewable energy a major policy focus. The both have signed so called “nationally leading” climate and energy legislation, made regulatory commitments, killed proposed fossil infrastructure projects, and enacted Energy Master Plans that call for transition to 100% renewable energy and billions of dollars of public investment in renewables.

The LNG fracked fossil fuel scheme not only directly contradicts those policies and commitments, it would wipe out any greenhouse gas emission reductions that could result from billions of dollars of public investments in renewable energy.

3. The NJ DEP and the DRBC reviews are fatally flawed because they completely failed to consider greenhouse gas emissions, climate impacts, or energy policy

As we’ve written, DEP permit regulations ignore climate change, see:

• NJ Environmental Regulations Ignore Climate Change

The DRBC regulations and review procedures are similarly flawed.

How can regulatory agencies, tasked to serve the public interest, review and approve fossil infrastructure without even considering climate science and energy policy during a climate emergency?

4. Why are some NJ “environmental” groups undermining this targeted campaign and providing green cover for DRBC?

I just learned that NJ League of Conservation Voters, NJ Audubon, and NJ Conservation Foundation (they are pathetic cheerleaders, along with their $100 million Wm. Penn Foundation created faux grassroots fundraising focused front group The Coalition for the Delaware Watershed) are doing a public event with the DRBC.

Of course, these corporate foundation funded groups are not part of the coalition targeting the Governors and DRBC to fight the LNG scheme.

Instead, these groups are diverting the public from the climate emergency and DRBC role in the LNG scheme, thereby providing green cover for the DRBC via a “meet the DRBC” event, just 6 days after the December 9 meeting:

The Delaware River provides drinking water to more than 13 million people and supports an outdoor recreation industry of over 20 million dollars each year. It’s managed and protected by the Delaware River Basin Commission (DRBC), the only agency of its kind in the U.S. The DRBC holds official public meetings but rarely gets the opportunity to less formally interact with the public.

That’s why I hope you make time to join us for our virtual meeting on Tuesday, December 15 with Delaware River Basin Commission deputy executive director, Kristen Bowman-Kavanagh. This is a rare opportunity to engage directly with the Commission about its priorities, the establishment of its new Advisory Committee on Climate Committee, and the environmental issues that you care about most.

This is not the first time these groups have done very, very similar diversion and political cover schemes.

It’s happened far too many times to be coincidental.

Shame on these corrupt self serving bastards. (my guess is that this event was created and funded by Wm Penn)

“Don’t Frack NY” Protest – Albany, NY – (9/1/12)

Third in our series.

The photos can’t begin to convey the awesome colors (or the stillness – or the yipping of the coyotes!)

Yesterday, I posted some photos of sunset.

So, today, we post some photos of sunrise, just down the trail.

We understand the significance of the day, and support our neighbors, see:

• Trump Border Wall Construction Blasting Sacred Sites
• They Policed Paradise and Put Up An AeroStat
• Rio Grande – Off The Wall
• Ajo Murals
• How The West Was Won? Threats To Democratic Liberal Traditions Explored At The Tucson Book Festival

I see my light come shining
From the west down to the east
Any day now, any day now
I shall be released.  ~~~ Bob Dylan (The Last Waltz version)

We’re encamped and wintering in the Sonoran desert, an extraordinarily beautiful but harsh place.

We’re in or on the edge of Cabeza Prieta National Wildlife Refuge.

We’re headed to Organ Pipe Cactus National Monument and the border wall – we’ll be posting photos from there in the next weeks.

Hope you enjoy the photos. We’ve got new gear!

If you look closely, you can see the cross on the top of the mountain. That man made symbol is about 2,000 years old, a tiny fraction of the age of the mountain upon which it rests. It’s pretty obvious which will last longer.

We Urge Radical Reforms And A New Framework

Abandon Individual Chemical Specific Risk Assessment Based Standards

Embrace The “Precautionary Principle” And Transition To A “Treatment Based Approach”

The NJ Drinking Water Quality Institute (DWQI) is seeking public input on which chemicals and how to regulate to protect your drinking water:

The Drinking Water Quality Institute (DWQI) will be holding a meeting on Thursday, December 3^rd, from 1:00 PM to 4:00 PM. Due to concerns around COVID-19, this meeting will be held remotely, using Microsoft Teams. If you would like to attend, please contact watersupply@dep.nj.gov, and include “December 2020 DWQI Meeting Invitation” in the subject line.

… the DWQI will be giving considerations to the next contaminants it will address. Therefore, if you have any input regarding the next topic of research for the DWQI, please include the name(s) of any contaminants of concern you may have in the body of your RSVP email.

We are urging the DWQI to dust off an April 2010 DEP policy paper titled: (my emphases)

• Investigations Related to a “Treatment-Based” Regulatory Approach to Address Unregulated Contaminants in Drinking Water

The New Jersey Department of Environmental Protection (Department) is focusing on new approaches to address the occurrence of unregulated contaminants found in drinking water throughout the State. These chemicals may be present individually or as mixtures, they are present at low concentrations, and little if any toxicity information is available for most of them. Discussions on possible new approaches for addressing their occurrence began in the 1990s when synthetic organic contaminants were discovered in a water system supplied by groundwater. Subsequently, many additional studies in the State have been conducted, and the Department is currently investigating the possibility of a “treatment technique” approach to regulating mixtures of organic chemicals in drinking water, as summarized below

The DEP solicited formal public comments on this new regulatory strategy and approach back in 2004 (see NJ Register Public Notice), but never followed through on it.

That DEP policy paper is based on several prior and ongoing DEP research projects, most of which focused on important questions, including:

The overall objective of this project is to investigate the effectiveness of conventional and advanced water treatment processes for the removal of unregulated organic chemicals (UOCs) such as pharmaceuticals and personal care products and industrial and household use organic chemicals from surface water systems. Specifically, this research is designed to answer several questions including: 1) What UOCs are removed by conventional water treatment processes? 2) What additional UOCs are removed with advanced processes such as GAC and ozone? 3) What per cent removal can be achieved with conventional and conventional plus advanced processes? 4) What process design parameters and operating conditions are associated with these removals? 5) How effective are current analytical methods in quantifying low levels of UOCs? 6) Is it plausible for NJ to consider a “treatment-based” regulatory approach for managing UOCs in drinking water in the state?

DEP found that there are over 500 unregulated toxic chemicals in NJ drinking water and “little if any toxicity information is available for most of them.”

DEP and the DWQI are flying blind. The public has no idea if their drinking water is “safe”.

[***Note: If you think I exaggerate, keep in mind that the Tom’s River, NJ childhood cancer cluster was caused by an unregulated chemical (according to NJ Dept. of Health): (emphasis mine)

A previously unknown chemical contaminant related to the Reich Farm site – styrene-acrylonitrile trimer — was identified in the Parkway well field (one of the supply’s eight well fields), resulting in the closure of two wells and an expanded water treatment system. …

The [epidemiological] study found that prenatal exposure to two environmental factors in the past were associated with increased risk of leukemia in female children. These exposures were: 1) access to drinking water from the Parkway well field after the time that the well field was most likely to be contaminated, and 2) air pollutant emissions from the Ciba-Geigy chemical manufacturing plant. ~~~ end Note]

DEP found that the current chemical specific risk assessment based approach conducted by the DWQI and the DEP to set chemical specific “maximum contaminant levels” (MCLs) as drinking water standards was not “feasible”:

That DEP paper also found that there were available treatment technologies that could remove virtually all these chemicals to very low levels and that these technologies were not expensive (particularly in light of the enormous public health benefits that would result from avoiding adverse health effects of contaminated drinking water.

DEP did not quantify these benefits, nor should a traditional ethically repulsive “cost-benefit analysis” be used to guide these public health decisions. (see also: “The Rights of Statistical People“

In light of these incredibly important DEP findings, we are urging the DWQI to abandon the current scientific and regulatory approach to recommending drinking water standards (MCLs) to DEP.

We did this almost a decade ago in a formal “petition for rule making” which DEP denied (for details, see: Filter the Chemical Soup in New Jersey’s Drinking Water).

Instead of the current chemical specific risk assessment based approach to MCLs that DEP found “not feasible”, we urge the DWQI to research and make recommendations to the Governor, the DEP and the Legislature regarding adoption of an entirely new policy, scientific and regulatory framework too regulating drinking water quality, as follows:

1. Embrace the “Precautionary Principle”:

The precautionary principle asserts that the burden of proof for potentially harmful actions by industry or government rests on the assurance of safety and that when there are threats of serious damage, scientific uncertainty must be resolved in favor of prevention.

The precautionary principle has a number of dimensions and benefits that make it superior to a risk assessment based framework:

Environmental scientists play a key role in society’s responses to environmental problems, and many of the studies they perform are intended ultimately to affect policy. The precautionary principle, proposed as a new guideline in environmental decision making, has four central components: taking preventive action in the face of uncertainty; shifting the burden of proof to the proponents of an activity; exploring a wide range of alternatives to possibly harmful actions; and increasing public participation in decision making.

2. Adopt a “Treatment Based Approach”

(see the above linked DEP policy paper, which would need to be updated and expanded upon to form the basis for recommendations by the DWQI to the Gov., DEP Commissioner, and Legislature.

While a treatment based approach could be implemented under current law, the precautionary principle would likely need new legislation.

3. Phase out the current chemical specific risk assessment based approach

The current scientifically flawed and ethically challenged risk assessment based framework has outlived its’ useful life. There are diminishing returns. It is slow, costly, not transparent, and does not adequately protect public health. There are scientific and ethical problems with risk assessment. It is ripe for complete overhaul.

This long known set of flaws are particularly relevant in light of NJ’s new “environmental justice” legislation that directs DEP to consider vulnerability of poor and minority people: (Heinzerling, p. 202)

I urge readers and the public to make this case to the DWQI as they requested.

It makes no sense to continue on the individual chemical specific risk assessment based approach, if for no other reason than it would take hundreds of years to get around to regulating all the chemicals we now know are present in drinking water.

This is a heavy lift, scientifically and politically. It will be strongly opposed by the private water companies, because it will increase their costs, reduce their profits, and require capital investment.

It won’t happen without strong public support, backing by the scientific and public health communities, and political demands by environmental groups.

Now is a good time to make it happen – the old regulatory framework is exhausted and discredited.