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Archive for March, 2021

Hoover Dam – Ring Around The Canyon

March 20th, 2021 No comments

Severe Drought, Climate Emergency, & Growing Water Demand

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We’re in the heart of Cadillac Desert! (see prior post on Glen Canyon dam)

While the media continues to be consumed by identity politics and Democrats continue to pursue Progressive Neoliberalism, President Biden’s new Secretary of Interior sure has her hands full.

AP News reports: August 4, 2020

CARSON CITY, Nev. (AP) — The white rings that wrap around two massive lakes in the U.S. West are a stark reminder of how water levels are dropping and a warning that the 40 million people who rely on the Colorado River face a much drier future.

Amid prolonged drought and climate change in a region that’s only getting thirstier, when that reckoning will arrive — and how much time remains to prepare for it — is still a guess.

The U.S. Bureau of Reclamation released projections Friday that suggest Lake Powell and Lake Mead will dip 16 feet (5 meters) and 5 feet (1.5 meters), respectively, in January from levels recorded a year earlier. Despite the dip, Lake Mead would stay above the threshold that triggers severe water cuts to cities and farms, giving officials throughout the Southwest more time to prepare for the future when the flow will slow.

“It’s at least a couple of decades until we’re saying, ‘We don’t have one more drop for the next person that comes here,’” said Ted Cooke, general manager of Central Arizona Project, the canal system that delivers river water. “But people certainly ought to be aware that water — the importation of a scarce commodity into a desert environment — is expensive and, with climate change, going to get even more expensive.”

The reckoning has arrived – it’s no longer “a guess”.

Despite the insanity from Mr. Cooke of the CAP – who is promoting growth in demand at a time when deep cuts to current users are about to be invoked –  the reckoning has arrived.

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Even the Wall Street money men are getting nervous:

A 2017 paper in the journal Water Resources Research, by Bradley Udall of Colorado State University and Jonathan Overpeck of the Colorado River Research Group, found that “As temperatures increase in the 21st century due to continued human emissions of greenhouse gasses, additional temperature‐induced flow losses [in the Colorado River] will occur.” Those losses could exceed 20% below the 20th-century average flow by mid‐century and 35% by 2100.

And they could be devastating to the region’s economy. According to a 2014 study that was produced by Arizona State University’s Seidman Research Institute and commissioned by Business for Water Stewardship, a non-profit organization, the Colorado River supports $1.4 trillion in annual economic activity and 16 million jobs across the seven states of the basin.

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Way back in 2007, the US Department of Interior found:

The Colorado River Basin (Basin) is in the eighth year of drought – the worst eight year period in over a century of continuous recordkeeping. Reservoir elevations have declined over this period and the duration of this ongoing, historic drought is unknown. This is the first long-term drought in the modern history of the Colorado River, although climate experts and scientists suggest droughts of this severity have occurred in the past and are likely to occur in the future. The Colorado River provides water to two nations, and to users within seven western states. With over 27 million people relying on the Colorado River for drinking water in the United States, and over 3.5 million acres of farmland in production in the Basin, the Colorado River is the single most important natural resource in the Southwest. […]

Under these conditions, conflict over water is unsurprising and anticipated. Declining reservoir levels in the Basin led to interstate and inter-basin tensions. As the agency charged with management of the Colorado River, the Department of the Interior (Department) had not yet developed operational rules for the full range of operations at Lake Powell and Lake Mead because these types of low-reservoir conditions had simply not yet occurred.

Against this background, at the direction of the Secretary, the Department initiated a public process in May of 2005 to develop additional operational guidelines and tools to meet the challenges of the drought in the Basin. While water storage in the massive reservoirs afforded great protection against the drought, the Department set a goal to have detailed, objective operational tools in place by the end of 2007 in order to be ready to make informed operational decisions if the reservoirs continued to decline.

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That led to the following plans and governing documents, for policy wonks only:

Severe drought conditions have triggered:

More specifically:

6. Based on the actual operating experience gained after the adoption of the 2007 Interim Guidelines and emerging scientific information regarding the increasing variability and anticipated decline in Colorado River flow volumes, the Parties recognize and acknowledge that those relying on water from the Colorado River System face increased individual and collective risk of temporary or prolonged interruptions in water supplies, with associated adverse impacts on the society, environment, and economy of the Colorado River Basin.Therefore, the Parties have agreed that it is necessary and beneficial to pursue additional actions beyond those contemplated in the 2007 Interim Guidelines to reduce the likelihood of reaching critical elevation levels in Lake Powell and Lake Mead through the Interim Period.

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Biden PennEast Pipeline Betrayal Tests NJ Gov. Murphy’s Climate Commitments

March 16th, 2021 No comments

Will Murphy’s DEP Kill Pipeline By Denying Water Quality Certificate?

Will NJ’s Green Mafia and Media Call Out the Biden Betrayal?

Biden’s Lawyers Actually Tout US History of Plantations and Indian Reservations

Last week, the Biden Administration’s Acting Solicitor General filed a brief to the US Supreme Court in support of the PennEast pipeline and against the State of New Jersey.

The Biden brief argues that the Federal Energy Regulatory Commission (FERC) may delegate power to a private corporation to condemn and take State owned preserved public land by eminent domain to build a fossil pipeline.

This amounts to the radical right wing corporatism FDR warned about:

“The liberty of a democracy is not safe if the people tolerated the growth of private power to a point where it becomes stronger than the democratic state itself. That in its essence is fascism: ownership of government by an individual, by a group, or any controlling private power.”

(NJ folks should know that the NJ Business and Industry Association (NJBIA) also filed a brief in support of PennEast.)

Here’s the national story (it’s tough to keep abreast of the news while on the road):

In the likely event that the 6-3 right wing Supreme Court agrees, the implications are nation-wide and a disaster for climate and anti-pipeline activists. The NJ BIA brief makes those implications very clear (if PennEast loses):

First, it will severely impede the continued orderly development of critically needed natural gas infrastructure. Second, it will render large reserves of natural gas in states like Pennsylvania unavailable to meet the growing energy needs of states like New Jersey. Third, by slowing or potentially halting interstate pipeline development, it will deprive the nation of the substantial economic activity associated with both the construction of the pipelines themselves, and the upstream and downstream users of the natural gas they transport. Finally, by introducing delay and uncertainty into the approval process, and casting into doubt the utility of a FERC-issued certificate of public convenience, it will make pipelines more difficult to finance and more expensive to build.

The implications are made even worse given the Biden Administration’s upcoming “infrastructure plan”, which certainly will include corporate subsidies, privatization, and deregulation – under the guise of “public private partnerships” – for fossil pipelines (remember, it was Obama who bragged about overseeing record US oil and gas production as well as miles of pipelines installed. Surely Joe Biden remembers that. Take a look!)

obama-pipes1

Under my administration, America is producing more oil than at any time in the last eight years. We’ve opened up new areas for exploration. We’ve quadrupled the number of operating rigs to a record high. We’ve added enough new oil and gas pipeline to circle the Earth and then some,” Obama said (source)

The Biden brief contradicts Biden’s climate commitments and can only accelerate and expand construction of fossil pipelines and fossil infrastructure (amidst all the climate talk, see huge growth of US oil production, and US gas production, and US coal production). 

The Biden brief completely destroys the legal strategy of Gov. Murphy and NJ Attorney General Grewal.

The Biden brief tramples on NJ’s legal, political, and environmental interests, as well as Gov. Murphy’s Energy Master Plan and DEP’s upcoming Climate PACT regulatory initiative.

The Biden brief exposes the misguided strategy of NJ’s “Green Mafia”, who have relied on private property protections and virtually ignored State Police powers and DEP’s regulatory powers under Section 401 of the Clean Water Act to kill the PennEast and other pipelines.

We’ve been writing about that and NY State and Connecticut’s 401 WQC denials, and criticizing NJ fools like Tom Gilbert for their failure to focus on it for over 4 years, see:

Media should ask AG Grewal if NJ DEP is willing to pull that legal trigger.

We specifically warned – many times, for several years – about the misguided, dishonest, cowardly, and failed strategy of cheerleaders like Rethink Energy NJ.

NJ Attorney General Grewal and opponents of the PennEast pipeline are calling the US 3rd Circuit Court of Appeals decision a “major victory” and a “groundbreaking ruling” and that the decision “stops PennEast in their tracks”.

They are exaggerating, misleading the public, making factually false statements, and simply not telling the full story. The decision is not a “groundbreaking ruling”, not a “major victory”, and will not “stop the project in its tracks”.

By making these exaggerated and false claims, they are undermining activist efforts to block all proposed pipelines and all fossil infrastructure, to inject climate change in regulatory decisions, and to enforce the Clean Water Act.

We exposed the failed focus on open space, see:

And we exposed the failed neglect and outright lies about DEP’s regulatory power, most recently last January, see:

But you wouldn’t know any of that by reading NJ Spotlight –  a media outlet who has long spun the PennEast pipeline story and provided a platform for cheerleaders like Tom Gilbert of Rethink Energy NJ – or by following Green Mafia websites and press releases.

Just the opposite: NJ Spotlight’s cheerleading for gas even got quoted in the NJ BIA brief:

“Inexpensive natural gas from Pennsylvania has been a boon to both customers who heat their homes with the fuel and to businesses that rely on it as a basic building block of their manufacturing processes.” Tom Johnson, [cite omitted]

It’s radio silence over there and in many other high places that are adversely impacted by the Biden betrayal. Biden’s betrayals are being given a pass – just like Obama’s were.

Paging Tom Gilbert – where are you?

Paging Attorney General Grewal – where are you?

Paging Acting DEP Commissioner LaTourette – where are you?

Paging NJ BPU Commissioners – where are you?

Paging Gov. Murphy – where are you?

Paging Senate Environment Committee Chairman Smith – where are you?

NJ lawyers and Rutgers Law School- where are you?

Paging NJ press corps – where are you?

[End Note: The case will not be limited to the Natural Gas Act or pipelines.

It will vastly expand corporate power in many ways, and not just for infrastructure.

And it will also effect related issues, including federalism, interstate commerce, and the powers of State’s under the Clean Water Act.

Biden’s brief represents a radical and fundamental view: (@page 10)

In light of the long unbroken history of colonial, state, and federal delegations of such authority, there is no basis to conclude that, when the States granted the federal government the eminent-domain power in the plan of the Convention, they silently retained the right to veto delegations of its exercise, as long as they could first obtain any property interest in the land at issue.

And this argument has broad and damaging implications:

The interests States own today, moreover, are just the beginning. Most States utilize State-owned conservation easements like the ones that respondents rely on  here. …. The federal government generally supports States’ efforts to use such easements to protect valuable farmland and open space. See 7 C.F.R. Pt. 1468 (grant programs). But the decision below converts those programs into a sword against federally approved projects.

The Biden brief explicitly attacks the private property strategy Rethink Energy NJ relied on:

For example, in New Jersey, the State can acquire new conservation easements by purchase or condemna- tion. See N.J. Stat. Ann. §§ 13:8A-37(d), 13:8A-40(a) (West 2003). Under the court of appeals’ decision, all the State needs to preclude any FERC-approved project it opposes is a willing landowner along the route. Indeed, even if the landowner were unwilling, the State could invoke its own eminent-domain power. Id. § 13:8A- 40. While a landowner could fight those efforts, New Jersey is a quick-take State that can acquire immediate title upon filing a declaration of taking and depositing estimated compensation. Id. § 20:3-19 (West 1997).

Ans here’s where privatization and corporate power are magnified and extended beyond any effective limits:

The only question, then, is whether the federal eminent- domain power inherent in the plan of the Convention includes the ability to authorize private entities to exercise it. History answers that question with a yes.

b. The power of eminent domain has been under- stood since before the Founding as a sovereign power that private entities may exercise for projects that the sovereign deems in the public interest.

And in a grab your hat “holy shit!” moment, Biden’s brief actually celebrates the power of PLANTATION OWNERS!

In Pennsylvania, for example, any person could apply to a justice of the peace for a “road to be laid out from or to the plantation or dwelling-place of any person or persons to or from the highway.” 1735 Pa. Highway Act

And establishment of INDIAN RESERVATIONS:

For the nearly 150 years since Kohl, no one ap- pears to have seriously questioned that the federal government’s eminent-domain authority includes the authority to condemn property owned by a State. .[…] see Act of July 24, 1935, ch. 414, § 2, 49 Stat. 496-467 (authorizing Secretary of the Interior to “acquire by condemnation” certain lands “held in public, private, State, or Indian ownership” for purposes of establishing an Indian reservation);

How could conservatives support that expansion in scope of power, particularly to “take” property?

How could conservatives support trampling of State’s rights?

How could conservatives support such a vast expansion of federal government power?

I’m going to predict that the Supreme Court will narrowly decide the case based on jurisdiction.

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Green Mafia Again Whitewashes Their Attack On NJ State Parks

March 12th, 2021 No comments

A Story Of Self Dealing And Propaganda

Remarkable Hypocrisy Provided A Platform At NJ Spotlight

NJ Audubon Gave $123,000 To NJ League of Conservation Voters

NJ Spotlight just published an Op-Ed that is stunning in its hypocritical Orwellian revisionism, see:

Looking at New Jersey Department of Environmental Protection staffing since 2008, there were 3,240 full-time staff working, according to reports from the NJ Civil Service Commission … Although park visitation has not decreased, and in fact has increased substantially in 2020, DEP staffing has decreased by approximately 17% since 2008. Without proper staffing, parks cannot provide the services and amenities necessary for the heavy usage they are receiving. So, how can we prepare for the upcoming parks season?

The DEP staff cuts reflect the DEP budget, which is something the authors intentionally ignore (as is the 2008 baseline year, which also is designed to divert from more recent cuts that resulted from the Keep It Green Open Space diversions).

[And BTW, the biggest DEP budget and staff cuts were imposed by Gov. Christie Whitman (>27%), prior to 2008. (See “Whitman: A Toxic Choice”) One of the authors was at DEP at the time and knows this, but has instead chosen to give Whitman a pass. Whitman also diverted hundreds of millions of dollars of environmental funds, which was the reason for the Constitutional Amendment dedicating 4% of the corporate business tax to DEP programs. Those were the funds the Keep It Green campaign stole. Democrat Jon Corzine was terrible, but not quite as bad as Whitman. The ironies and contradictions pile up the more history is understood and interrogated. ]

We explain all that, see:

This is no accident – the NJ Spotlight Op-Ed authors do that for a reason.

The Op-Ed was written jointly by NJ Audubon and NJ League Of Conservation Voters. They don’t want you to know about this:

Here’s why they didn’t mention the DEP budget:

The Bergen Record finally published a story on funding cuts for the maintenance of NJ State Parks and how the Keep It Green Coalition – led by NJ Audubon and their Foundation and corporate friends – duped the voters into slashing those funds, despite a known $400 million backlog in capital maintenance projects, see:

It is a complex story to tell, but it all boils down to this (Bergen Record):

“Some environmentalists say the amendment had an unintended but severe impact on the Natural and Historic Resources capital budget. The budget had been replenished each year from the same tax, a dedication secured in a prior, 2006 voter-approved constitutional amendment. That amendment was to provide a “reliable and stable source of funding” that would enable the DEP to make “long-term investments in the state park system,” according to a 2013 draft of the state’s Comprehensive Outdoor Recreation Plan.

It provided about $15 million annually, and would have doubled to $32 million in 2016. ...

Mark Texel, head of the New Jersey Division of Parks and Forestry, called it a “massive blow” and said in a Facebook post soon after the vote that it was “the darkest day I have faced in my professional career.” [**Note: he called it “worse than Sandy“]

“We had a plan to really tackle some of these major capital projects that had been deferred for many, many years,” Texel said. “And we were making progress. Suddenly now our capital budget is having the legs cut out from underneath it. … It was disappointing, I admit. I was very disappointed. 

Finally, despite the continuing lies and pushback to undermine and divert attention from the nasty truth, the press finally held the culprits at Keep It Green accountable:

Bill Wolfe, director of the non-profit Public Employees for Environmental Responsibility, said he didn’t believe that voters in 2014 knew this would happen.

He accused NJ Keep It Green of “intentionally, knowingly” stripping state parks of capital funding to finance Green Acres so they wouldn’t have to ask voters to approve a bond. That, he said, let open space groups avoid a public brawl with Governor Christie, who has demanded no new debt be placed on taxpayers. The coalition, he said, “didn’t have the spine to fight for the money.”

The “Keep It Green Coalition” was responsible for this diversion of hundreds of millions of dollars of State Park funding.

They don’t want to tell you about all that.

Their fellow Foundation funded lackeys at NJ Spotlight won’t force the issue. It’s a gross whitewash.

I’ve long complained of the corrupt and incestuous self dealing between some NJ conservation groups, (AKA “Keep It Green Coalition”) specifically including NJ Audubon and NJ LCV, whom I’ve called part of the “Green Mafia”.

I’ve documented how these corrupt relationships have harmed the public interest, especially NJ’s public lands and State Parks.

So, I was not surprised to learn recently that NJ Audubon paid the NJ League Of Conservation Voters $114,500 for “publications” (see page 61)

I explained how this self dealing corruption operated:

I warned about exactly how this corruption negatively impacts State parks, see:

The diversion of State Parks capital funds prompted NJ DEP State Parks Director Mark Texel to speak out publicly in opposition.

Director Mark Texel wrote the following on Keep It Green Facebook page on 11/5/14:

As the Director of the NJ State Park Service now coping with the reality that our entire Parks capital budget will be completely eliminated beginning July 1, 2015 as a result of the YES vote I can say this is the darkest day I have faced in my professional career. Worse than Superstorm Sandy. 440,000+ acres of preserved open space, 52 historic sites, 39 parks — used by 8 million visitors each year — all managed by my agency and now with no funding plan in place for stewardship beginning in just 7 months. This is not a bad reality TV show. This is New Jersey’s Inconvenient Truth hidden from voters throughout this campaign.

As the Bergen Record reported at the time (see: Budget cuts doom state parks to disrepair (6/28/17):

Bill Wolfe, director of the non-profit Public Employees for Environmental Responsibility, said he didn’t believe that voters in 2014 knew this would happen.

He accused NJ Keep It Green of “intentionally, knowingly” stripping state parks of capital funding to finance Green Acres so they wouldn’t have to ask voters to approve a bond. That, he said, let open space groups avoid a public brawl with Governor Christie, who has demanded no new debt be placed on taxpayers. The coalition, he said, “didn’t have the spine to fight for the money.”

The people of NJ should be outraged by this incompetent, greedy self dealing masquerading as public interest public land conservation.

Sadly, NJ Spotlight will not only not tell the people about this, but they provided a platform for their fellow foundation funded fraudsters to lie to readers about it.

That is corrupt.

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School Bus Electrification: Strategic? Or Just Plain Stupid?

March 12th, 2021 No comments

Advocates Are Math Challenged And Politically Incompetent

Minuscule Greenhouse Gas Emissions Reductions, Huge Costs

[Update below]

NJ Spotlight ran another fact free puff piece on a “Report” advocating electrification of the public school bus fleet, see:

I previously wrote to criticize a similarly misguided proposal to electrify the NJ Transit diesel bus fleet, concluding:

Of course, the NJ energy sector and corporate NJ are breathing sighs of relief as environmentalists divert public attention from anything that could change the corporate status quo or cost them a thin dime.

Electric bus fleet replacement cost would be at least $660 million, and all of it from PUBLIC money, not one corporate dollar. *** There were no estimates provided of actual GHG emissions reductions associated with this public expenditure. (*** See Technical Update below)

If anything, the cost, equities, and greenhouse gas emission reductions are even worse for the public school bus fleet than the NJ Transit fleet.

1. Strategic or Stupid?

While I expect the advocates to be clueless on numbers and basic math, my jaw dropped when I read this quote from a highly regarded NJ energy consultant:

“Electric school buses are highly strategic — they reduce operating costs for the districts, lower harmful emissions in the local community and provide compelling evidence that electric vehicles are ready for mainstream adoption,’’ said Mark Warner, a vice president of Gabel Associates, an energy consulting firm based in Highland Park.

I think Mr. Warner meant “highly visible” or “a highly symbolic gesture” – because first of all, the numbers don’t work (see my back of the envelope sketch below).

But far worse, strategically, imposing huge new costs on chronically cash strapped, over-burdened, and underfunded public school districts (particularly in light of all the huge new costs related to COVID) is about the worst greenhouse gas reduction strategy I can think of.

It is enormously costly, provides tiny greenhouse gas emissions reductions, diverts scarce resources from far more cost effective options, and is almost designed to generate harsh public opposition and spawn a backlash (think “Yellow Vests”).

A local school budget is the most closely and critically scrutinized public budget there is. School budgets drive local property taxes and require local taxpayer and voter approval.

School budgets are annualized and school boards and voters approve annual budgets, so any alleged “long term” cost savings associated with electric conversion – even if real – are irrelevant (do the Report authors and Mr. Warner understand how school budgets are structured and approved??? Do they really think that entire budget structure would be abandoned to buy high cost electric school buses? Do they think voters will approve long term bonds to buy these buses, when school facilities are dilapidated and inadequate?)

Does anyone think that local voters will approve a $200,000 climate premium on purchase of a $100,000 new school bus?

Even if they would, diverting scarce public education resources to an extremely cost-ineffective greenhouse gas emission tactic is obscene.

There are many other far more cost effective greenhouse gas emissions tactics, including private sector fleet vehicles (like Amazon, Fed Ex, UPS, etc), but the “advocates” lack the courage to take on the fight with these powerful corporate interests. It’s sooo much easier to target the public sector and school buses!

Targeting public school buses is not “strategic”, it’s just plain stupid.

2. The Number Don’t Work

According to the “Report”:

Transitioning to all-electric school bus fleets would avert 5.3 million tons of greenhouse gas emissions each year,5 keeping our air cleaner and our communities healthier— all while saving school districts money to invest in the classroom.

I attempted to find the basis for the 5.3 MT estimate. The Report cited footnote #5. So, I went to that FN, which was to a prior October 2019 Report by the same group. That 2019 Report cited the basis of the 5.3 MT estimate in footnote #37. So, I went to FN #37, which then sent me to Footnote #2, which said this:

2. Emissions savings calculated using Argonne National Laboratory’s Heavy-Duty Vehicle Emissions Calculator available at https://afleet-web.es.anl.gov/hdv-emissions- calculator.

The link to Argonne failed – and even if it worked, they probably have individual vehicle emissions factors but I highly doubt that they would have a national estimate of total school bus GHG emissions – so I was unable to confirm or replicate their methodology or the calculations used to derive this critically important point, which is the primary basis for spending all the money to electrify the  school bus fleet (there are air quality and health co-benefits beyond the scope of this rough estimate). (My 8th grade algebra teacher emphasized the need to show your work! And I got a 99 on the Algebra NYS Regents exam for failure to put a check mark next to my work)

So, I thought I’d do a back of the envelope estimate based on a quick Google (not an advisable methodology!).

The alleged 5.3 million ton national greenhouse gas emission reduction is tiny, and requires context.

For context, according to the most recent 2018 US EPA Greenhouse Gas Emissions Inventory:

In 2016, total gross U.S. greenhouse gas emissions were 6,511.3 million metric tons (MMT) of CO2 Eq.11

Do the math – at the national level, 100% fleet replacement of electric school buses would reduce national GHG emissions by just 0.08% (5.3 MT/6,511.3 MT) x 100 = 0.08%

How much would that tiny 5.3 MT emission reduction cost?

The Report did not address that question or provide even basic data (e.g. size of the school bus fleet, gallons of diesel fuel consumed, etc).

So I tried to find a reliable estimate. According to the NY State School Bus Contractors Association:

  • Nationally, 26 million children in the U.S. take 480,000 buses to and from school each day.
  • School buses travel about 12,000 miles per year per bus or almost 6 billion cumulative miles per year.
  • Each school bus, at an average 7 mpg and 12,000 miles, uses 1,700 gallons of fuel per year.

According to the US Energy Information Administration, there are 22.4 pounds CO2 per gallon of diesel.

Let’s do the math to estimate total emissions from the school bus fleet:

(480,000 buses) X (1,700 gallons/bus) X (22.4 Lbs/gal)/2,000 lbs/ton = 9, 139,200 tons CO2

That almost twice the 5.2 MT from the Report – a discrepancy that large raises credibility issues. It could be due to the difference between the Report (total greenhouse gas emission) and my back of the envelope (total CO2 emissions). Because the Report failed to show their numbers or methodology, we can’t know.

So, let’s do the math to estimate total costs (additional cost of electric over diesel) and cost effectiveness in reducing emissions ($/ton):

(480,000 buses) X $200,000/bus = $96 BILLION

Cost effectiveness: ($/ton reduced)

($96 BILLION)/5.2 MT = $18,461/ton

That’s an absurdly high cost. Certainly not a “strategic” option.

For context, for an equivalent CO2 emissions reduction from cars, it would translate into a gas tax of $181 per gallon! (See:

(2000 lbs/ton)/gas emission factor: (19.6 lbs/gal) = 102 gallons of gas per ton of CO2

($18,461/ton cost)/(102 gallons gas/ton CO2) = $180.99/gal

Typically car goes 15,000 miles at 25 mpg = 600 gallons/year

(600 gallons/year) x $181/gal = $108,600 per car!

It would be 1/3 the cost to buy people an electric car!

[Update:  The comment section on this blog does not work. So, here’s what a reader suggested, with which I completely agree:

you raised some good points but your argument would be stronger –  if you showed the larger reduction by spending that money on EE. [energy efficiency] The $10 million from CEF going to busses vs EE for low and moderate income families .EE would reduce the pollution and save those families money exponentially compared to few school buses .Same thing with RGGI money EE for L&M verses trucks for Amazon

 end update]

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More Crazy In The Pinelands And Highlands

March 9th, 2021 No comments

Every government document I read offers up more absurd developments

[Update below]

I just read the Pinelands Commission’s February 2021 Monthly Report and thought I’d share the latest in crazy down the Pines:

1. End Run Around Highlands Septic Density Standards?

The Pinelands Commission staff met with the Highlands Council staff – at the request of the Highlands Council – to discuss septic systems and receive a briefing on the Pinelands’ Alternate Design Treatment Systems Pilot Program. That program is designed to promote development and provide flexibility and basically relief from strict regulations.

There is no valid scientific or regulatory rationale for such a meeting between the 2 staffs. Scientifically, the geology and groundwater recharge are fundamentally different. From a regulatory perspective, the Highlands benefit from a strict “Septic Density Standard” and that standard is based in NJ DEP regulations.

Here’s how the Pinelands Report summarized that meeting:

New Jersey Highlands Council: At the Council’s request, staff provided a briefing on the Commission’s Alternate Design Treatment Systems Pilot Program. The use of advanced treatment septic systems for both residential and commercial development was discussed.

The only reasons for the Highlands Council to request such a briefing is to undermine or find a work around the DEP’s strict Highlands Septic Density Standard by developing a similar sham alternative pilot program under the Council’s jurisdiction.

This is a bad idea that needs to be nipped in the bud, and soon before it gains any momentum.

2. Climate Blues – Over-Regulation Of Solar

Here is another reason why the Pinelands needs a climate policy and renewable energy policy and CMP amendments to implement that policy, see

The Commission’s February Management Report reveals that they are already implementing renewable energy regulations for solar in the absence of an over-arching climate policy to promote renewables:

New Jersey Board of Public Utilities (BPU): Applications for participation in Year 2 of BPU’s Community Solar Pilot Program were due by February 5, 2021. If any such application proposed a ground‐mounted solar facility in the Pinelands Area, BPU required the applicant to obtain a letter from the Commission on the consistency of the project with Pinelands regulations. Commission staff issued letters on nine proposed community solar facilities. In each case, the letter stated whether or not the proposed solar project’s scope and location were consistent with CMP land use priorities. Staff also met with an applicant seeking to construct a community solar project in Pemberton Township, outside the Pinelands Area, that has the potential to provide solar energy to the Commission’s offices.

So, the Pinelands Commission is conducting “consistency reviews” for solar.

What are the policies and standards that are applicable? Is solar given any preferential treatment, or is it treated like any other less desirable land use? Are there barriers to solar? Is this done publicly?

And too bad BPU did not require this “letter” of consistency review before they approved the SJG pipeline. BPU approved the pipeline BEFORE the Pinelands Commission reviewed it.

So why should a solar project be more strictly regulated than a fossil pipeline? Absurd.

And the Highlands Council is not even trying to develop a climate policy.

3. Privatizing Water Regulation

After many years of delay, it looks like the Pinelands Commission is finally moving forward with CMP amendments and new regulations to implement the science behind the Kirkwood-Cohansey Project, see:

But it also looks like the Pinelands Commission is gutting the program before it is even designed or regulations are adopted by contracting out the regulatory reviews (and don’t you just hate that passive voice?):

Kirkwood‐Cohansey: Research was conducted into potential partners or contracts for review of drawdown models that will be required for well applications when new rules are adopted.

These reviews must be conducted by Pinelands staff.

They are regulatory reviews that can not be contracted out and effectively delegated to a private third party.

If the Commission doesn’t currently have staff with the necessary expertise, they must hire some.

Where are Pinelands advocates on this?

[Update: 3/10/21 – and while we’re speaking of crazy, just a few miles north, the good folks at Catskill Mountainkeeper just put out an alert on 2 terrible projects (too bad that the NY folks don’t have a Highlands Act! They have “forever wild” in the NY State Constitution and the Adirondack Park Agency, but not a regional planning and regulatory model like Highlands)

1. First, a power company from Southern California called Premium Energy Holdings wants to create an enormous underground hydroelectric plant adjacent to the Ashokan Reservoir. If this project moves forward, the company would be digging into valleys in the towns of Olive or Shandaken and damming streams to create reservoirs as part of “pumped storage” for electricity to be generated using associated water transport tunnels. Tapping into any energy generated would require a massive new high power electric transmission network. New York needs clean energy, but this is not the way to go.

Scroll to the bottom of this email for a sample comment you can copy/paste into the Federal Energy Regulatory Commission’s (FERC) online portal and make your comments part of the official record.

The proposal caught everyone by surprise, as Premium Energy Holdings had not reached out to New York City’s Department of Environmental Protection (NYCDEP) or the local communities that would be impacted by the project. It’s a shame that the idea of hydroelectric power in our region came forward this way, because this ill-advised proposal for massive construction adjacent to the drinking water reservoir that supplies a portion of the water for nine million people seems totally implausible. Any reasonable ideas about generating hydroelectric from the reservoir system may now become harder to discuss, and local communities, already addressing more pressing issues, are being forced to divert attention to mobilize in opposition.

We believe this really bad project is unlikely to move forward, yet we must stay vigilant in our opposition until we are sure it’s been shut down for good. Remember: scroll down for a sample comment and instructions to submit your thoughts to FERC.

2.  the New York City Department of Environmental Protection (NYCDEP) is seeking permission to release turbid (muddy) water from the Ashokan Reservoir downstream into the clean flowing waters of the Esopus Creek in West Hurley, Kingston, Saugerties, and eastern Ulster County, a stretch sometimes called the Lower Esopus (see https://www.dec.ny.gov/enb/122281.html). The turbid waters have to go somewhere, and NYCDEP obviously doesn’t want to send the muddy water into their drinking water system, but these releases would carry particles of clay and silt out of the reservoir and could go on for months at a time, especially following heavy rains and storms.

Turbid, muddy waters harm the ecology, economy, and quality of life along the stream, which flows into the Hudson River, and new information suggests that the turbidity may be contaminating drinking water for the Town of Esopus and other communities along the Hudson. The Draft Environmental Impact Statement released by NYCDEP supporting its request does not address solutions that would prevent both flooding and further contamination, like investing in stream bank restoration and flood resilience projects both upstream and downstream of the Ashokan Reservoir.

The New York State Department of Environmental Conservation (NYSDEC) is accepting comments on the NYCDEP’s proposal through June 16th. Please speak out and tell NYSDEC to send NYCDEP back to the drawing board! SEND COMMENTS TO NYDEC

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