WolfeNotes.com

Delusion On The Pinelands

Propaganda On The Highlands Economic Development Plan Story 

23,000 acres – 36 square miles – targeted for corporate development

In another example of a pattern of horrible reporting, last week NJ Spotlight reporter Jon Hurdle wrote that Gov. Murphy’s withdrawal of his chemical industry lobbyist nominee for the Pinelands Commission was “a significant win for the environmental lobby”.

The next day, long time Star Ledger Editorial Board editor Tom Moran – certainly no flaming radical or tree hugger – saw things quite differently.

Moran called Gov. Murphy’s move “a craven power play”, “brazen”,  an attempt to “gut the Commission during lame duck”, and a “scheme” that was similar to the “bullying” by Gov. Christie.

Moran wrote to urge the Gov. to withdraw all the corporate nominees: not just the chemical industry lobbyist:

We’ve come to expect mischief during lame duck, when lawmakers try to rush things through stealthily in their final two months in office.

But we didn’t expect the governor who preaches environmental protection to make a craven power play at the Pinelands Commission – picking folks who represent corporate interests to replace environmental stalwarts on the board. Not even Chris Christie was so brazen as to appoint a corporate lobbyist.

Murphy needs to rethink his nominations, which include Laura Matos of Kivvit, a prominent public affairs and communications firm, and a guy who works full time for an offshore wind company, Davon McCurry of Ørsted. […]

Christie tried to bully this commission and the message Murphy’s sending now is a similar one. If this is a squabble over personnel, it should be worked out internally, not with another act of retribution. Governor, stop this scheme before the Senate acts. 

Certainly, this was no “significant win for the environmental lobby” as Hurdle delusionally claimed.

This was not the first time Hurdle got the story very wrong and was humiliated. There has been a pattern and I’ve repeatedly complained to Hurdle and his editors.

But after the Moran piece, one would think that would thoroughly embarrass Mr. Hurdle and his editors at NJ Spotlight and force much closer scrutiny of his reporting.

But, obviously that did not happen.

Because today he was right back on the bullshit beat.

Today, Mr. Hurdle found a way to put a positive spin on the recent Economic Development Plan for the Highlands – the one I recently exposed as seriously flawed, see:

• Gov. Murphy Promoting Corporate Development Of The Environmentally Sensitive NJ Highlands Region

Hurdle totally ignored the fact that the Economic Development Plan targeted and promoted development of 23,000 acres – that’s no small fact omission: it 36 square miles!

He ignored the applicable text and policy of the Highlands Act.

He ignored the fact that the Economic Development Plan ignored climate change, conducted no environmental impact analysis, and ignored the mandatory development “compatibility” protections of the Highlands Act.

(I’m guessing that Dan Van Abs – who is a Highlands Council member and was on the Technical Advisory Committee for the Economic Development Plan and knows better and should be ashamed of himself for legitimizing this schlock work – is whispering in Hurdle’s ear, in a cowardly off the record “on background” anonymous source fashion.)

He allowed Executive Director Plevin to spin the Highlands Act and the Economic Development Plan virtually beyond recognition.

Read Mr. Hurdle’s second pile of shit in a week, it is almost exactly the opposite of my take:

• Highlands plan says growth depends on environmental quality

 The opening paragraph is so misleading it borders on falsehood:

The Highlands Council has identified the industries it wants to grow in the environmentally sensitive region it manages but stresses natural resources remain key in its first-ever plan for economic growth in the seven-county region of northwestern New Jersey.

Mr. Hurdle obviously was duped by the “sustainable” rhetoric of the Plan, not the technical content of it. The plan does stress the vague standardless slogan “sustainable development”, but it does not stress or even mention substantive protections of actual natural resources (beyond rhetoric and slogans). Not even to incorporate them by reference.

Worse, the actual planning methodology used by the corporate consultants who wrote the plan doesn’t even mention the Highlands Master Plan in its siting and locational analysis, or in the point system it applies to assess suitable development (other than location in a RMP designated center). In a crazy biased “point system”, the Economic Development Plan gives equal weight to municipal zoning and the Highlands RMP and DEP sewer service are mapping. But they are NOT equal in law, policy, and regulation. Not even close.

Here’s a summary of that methodology on page 6

“Recognizing that on-the-ground information is critical to ensuring a complete picture of redevelopment opportunities, Colliers Engineering & Design prepared an online survey to obtain input from the 88 municipalities in the Highlands Region to self-identify properties in their community that are primed for future redevelopment. Colliers then determined a scale based on various factors to rank the suitability of redevelopment parcels according to the region’s target industries. A full description of this methodology is available in Chapter II of this report.”

Reliance on municipal self identification of developable property – via an on-line survey no less – is the antithesis of planning and contradicts the Highlands Act. Municipal development wishes are governed by the Highlands Act, the RMP, and DEP regulations.

Municipal “Home rule” on land use was THE problem the Highlands Act was intended to overcome. The corporate consultants who wrote this plan seem oblivious to that fundamental and their work reflects that failed understanding.

I don’t expect Hurdle to know anything about the Highlands, but, because Hurdle has written several stories on controversial warehouse sprawl issues, this quote he gave to Executive Director Plevin exposes the embarrassing sham of his reporting:

“Most people would agree that there are appropriate places for warehousing and less-appropriate, and that evaluation is part of a regional planning strategy,” she said. “I do expect that the warehousing issue will continue to be at the forefront of planning discussions in the Highlands region.”

That is a load of crap and Hurdle knows it.

As I wrote, the Economic Development Plan mentions warehouse development just once, and in a favorable context as being part of economic demand in the region the plan seeks to stimulate: (@ page 20)

There is continued demand for industrial real estate in the counties. The demand is driven by firms involved in distribution, supported by warehousing as well.

The Plan says nothing about restricting warehouses development, or regional planning for warehouse development, or provides any recommendations to amend the Highlands Regional Master Plan to including siting criteria for warehouse development.

Maybe Tom Moran can write another scathing editorial that sets the story straight and again humiliates Mr. Hurdle.

At this point, after the Pinelands embarrassment and now this Highlands misreporting, Mr. Hurdle needs to go.

NJ Spotlight editors John MacAlpin and John Mooney, where the hell are you?

I fired off this note to Hurdle and Spotlight editors:

Jon – did you actually read the Plan? I did.

Are you familiar with what the Highlands Act specifically says about economic development? I am. I wrote it.

Just one example, of warehouses, which you’ve done a lot of reporting about and totally misrepresented today in Plevin’s quote:

Here what the Plan says about warehouses – on page 20 – which it mentions just ONCE:

“There is continued demand for industrial real estate in the counties. The demand is driven by firms involved in distribution, supported by warehousing as well.”

The Plan seeks to stimulate “demand” for development, so that description can only be interpreted as a favorable assessment of warehouse development.

The Plan says NOTHING about discouraging warehouse development or recommending regional reviews or appropriate siting locations.

You allowed Plevin to totally misrepresent that Plan and the Highlands Act and the RMP. And your story misled readers. This is not the first time you’ve done that and it must stop.

Read the law and the facts, with links and excerpts of the Plan and the Highlands Act, here:

http://www.wolfenotes.com/2021/12/gov-murphy-quietly-promoting-corporate-development-of-the-environmentally-sensitive-nj-highlands-region/

BTW, the Plan targets 23,000 acres for development – that’s 36 SQUARE MILES.

I need to clarify, because the Plan is actually worse than what I wrote.

In seeking locations suitable for development – including warehouses – the methodology of the Plan actually ignores and goes outside the scope of the Highland RMP. 

Look at the methodology (p. 6): “municipal self identification” is the ANTITHESIS of planning and it as not based on the Highlands RMP:

“Recognizing that on-the-ground information is critical to ensuring a complete picture of redevelopment opportunities, Colliers Engineering & Design prepared an online survey to obtain input from the 88 municipalities in the Highlands Region to self-identify properties in their community that are primed for future redevelopment. Colliers then determined a scale based on various factors to rank the suitability of redevelopment parcels according to the region’s target industries. A full description of this methodology is available in Chapter II of this report.”

WOLFE

Will Upcoming DEP Environmental Justice Permit Review Rules Be As Bad As Climate PACT Rules?

EJ activists have made absolutely no clear regulatory and technical demands

Wild-goose chase: : a complicated or lengthy and usually fruitless pursuit or search

Wild-goose chase. I haven’t heard that phrase used in a long while.

I hate to see good people get duped and manipulated, which is why I wrote this;

• Murphy DEP Commissioner LaTourette Gaslights On Environmental Justice

But Commissioner LaTourette’s Administrative Order was just a placeholder for the main event.

The Murphy DEP will soon propose the long delayed and desperately needed “environmental justice” permit review regulations.

I have written several times that the law that authorized those regulations is seriously flawed and will not work. (e.g. see this and this and this).

I’ve focused on how that legislation completely ignored the specific technical requirements of current laws, standards, and DEP permit regulations and instead enacted vague and unenforceable novel feel good slogans that can not be implemented to meet the asserted goals of the legislation (e.g. see this)

Nonetheless, the environmental justice community (local activists and environmental groups) seem to have gone radio silent on the issues and have abandoned traditional activism.  Instead they are relying completely on quiet closed door DEP negotiations on the development of these regulations and praising – not pressuring – Gov. Murphy.

Climate activists did the same thing by participating for 2 years in a sham “Stakeholder” process and praising the Governor, instead of publicly pressuring the Murphy administration. And predictably they got screwed.

So, I am now predicting that the EJAC and EJ community – with some of the same Murphy climate cheerleaders in leadership positions – will get screwed just as badly as the climate community just did and for the same reasons.

We will soon see.

The EJ activists and radicals having been marginalized, that inside baseball effort is being managed through the DEP’s “Environmental Justice Advisory Council” (EJAC).

The DEP’s Environmental Justice Advisory Council is staffed by Joanne Held, the former head of DEP’s Hazardous Air pollution program. Surely, she knows where the skeletons are buried. Is she talking? Or is she still loyal to DEP? (For exactly what Ms. Held knows, see:

• 18 Years After Scathing Criticism By Federal Judge For Ignoring “Environmental InJustice”, NOTHING HAS CHANGED AT NJ DEP

Ask yourself: Why would a federal Judge – certainly no radical EJ activist –  in a legal opinion, be a harsher critic of DEP than the EJAC, environmental groups, and so called climate and EJ activists?

A review of the most recent posted September 15, 2021 meeting notes of the EJAC with respect to the pending EJ regulations states the following:

Ground Level Ozone Is The Primary Air Pollution And Health Concern, Especially For Urban NJ

Environmental Justice and Climate Activists Playing Inside Baseball 

Polluters and DEP Get A Pass (Again)

There’s always a lot of talk about the severe adverse public health impacts of ground level ozone, particularly on children and the elderly who live in New Jersey’s designated  overburdened “environmental justice” communities.

Ground level ozone is responsible for serious health effects, from asthma attacks to heart attacks and dramatic increases in respiratory distress and emergency room visits, especially on “bad air” days.

According to EPA:

People most at risk from breathing air containing ozone include people with asthma, children, older adults, and people who are active outdoors, especially outdoor workers. […]

Children are at greatest risk from exposure to ozone because their lungs are still developing and they are more likely to be active outdoors when ozone levels are high, which increases their exposure.  Children are also more likely than adults to have asthma.

The current health and air pollution problems will only grow much worse with global warming (note that this post cites DEP extreme heat and extreme injustice warnings issued back in 2004!).

Yet, NJ DEP just prepared and submitted to US EPA a proposed plan of compliance for meeting the ground level ozone standards and – despite this talk, which failed to mention DEP regulatory power – no one seems to even know about it or to care.

DEP cancelled the public hearing because no public hearing was requested. All talk, no action?

No environmental justice community press releases. No public hearings. No news coverage. Nada. A complete collapse of the advocacy community, despite the talk.

The polluters and DEP regulators are given a pass.

(see all the documents for DEP’s  State Implementation Plan (SIP) Revision: 2008 75 ppb 8-Hour Ozone Attainment Demonstration, 2008 75 ppb and 2015 70 ppb Reasonably Available Control Technology (RACT) Determinations and Nonattainment New Source Review (NNSR) Program Compliance Certifications, and 2017 Periodic Emissions Inventory

Back in the day, Tom Johnson at the Star Ledger would write 6 stories on the DEP Ozone SIP: 1) health effects of ozone and whether EPA standards were strict enough; 2) ozone monitoring data, map of monitoring station locations, # days out of compliance with standard, basic meteorology of ozone (hint: the air is cleaner in Chester and better monitored than the air in Paterson); 3) what it meant for big polluters: refineries, Big Pharma, and the chemical industry; 4) what it meant to small polluters (gas stations, dry cleaners, etc), consumer products (volatile organics in many consumer products), and mobile sources (cars/trucks – no way EV’s make a dent in reducing mobile source pollution, etc.); 5) what the politics were, what EPA would do, how NJ DEP would respond, regional transport states, etc; and 6) cover the Trenton press conference held by environmental groups. All the other big papers would follow suit with their own regional stories: Bergen Record, Philadelphia Inquirer, Trenton Times, Asbury Parks Press, AC Press, even The NY Times had a Trenton Office and would write a story and the AP would put out a wire story.

Today, we get crickets. (But we have Twitter, and Facebook and Google! Yaaay! – And DEP’s “Data Miner”)

That DEP Ozone SIP plan targets all the polluters, and importantly includes (DEP transmittal letter to EPA):

The New Jersey 2017 periodic emissions inventory, which will be used as the base year inventory for Reasonable Further Progress (RFP) for the 2015 70 ppb 8-hour Ozone NAAQS.

These documents have loads of important information on sources of air pollution, including the name of the corporation, how much pollution they emit, and where they are located. There are relationships between ground level Ozone levels, DEP permitted emissions of ozone precursors, and DEP’s climate regulations on CO2 emissions.

The Ozone SIP also shows how far DEP will have to go and the specific regulatory actions they must take to ratchet down on polluters to meet the stricter 70 ppb 2015 ozone standards.

From a greenhouse gas emissions perspective, it would be interesting, for example, to review Appendix 4-5 (see link above) which identifies air pollution emission projections from specific Electric Generating Units (point sources) and other industrial point source polluters. DEP’s climate regulation applies to some of the EGU but a smaller percentage of the industrial polluters. So comparisons would expose the narrow scope of the DEP climate regulatory proposal.

It also would be interesting to compare those emissions with DEP’s Regional Greenhouse Gas Emissions pollution cap; DEP’s Greenhouse Gas Emissions Inventory; and DEP’s recently proposed climate PACT GHG emissions. I strongly suspect that RGGI program locks in lower emissions than the DEP rule proposal.

I’m fairly certain that such comparisons would reveal exactly how weak the DEP’s proposed GHG proposal is, in terms of actual reducing GHG emissions.

That information would also enable targeting of the location and names of corporate polluters in NJ’s environmental justice communities.

I realize this is extremely complex material and not readily accessible to the public or the depleted media. In fact, my computer for some reason is unable to even download the documents, so I haven’t even read the DEP SIP (this could be due to a slow connection out here in the desert or lack of software. Regardless, I am unable to open and read the DEP documents).

But environmental groups – who all talk the talk about environmental justice and urban air quality and global warming – have resources to hire professionals and experts to review the documents and prepare accessible public reports to hold polluters and DEP accountable.

But instead of working on NJ specific issues and focusing on the behavior of NJ DEP, they fob off national Reports written by well paid beltway consultants. And then use them to support their current campaigns, like for EV’s (have they read the DEP mobile source emissions inventory?)

How could Environment NJ issue a national Report – at the time that NJ DEP was proposing NJ’s ozone SIP for public comment – and not even mention the DEP SIP? How could an Op-Ed ignore the DEP SIP? These folks are out of touch and totally ineffective.

The DEP’s Environmental Justice Advisory Council is staffed with Joanne Held, the former head of DEP’s Hazardous Air pollution program. Surely, she knows where the skeletons are buried. Is she talking? Or is she still loyal to DEP? (For exactly what Ms. Held knows, see:

• 18 Years After Scathing Criticism By Federal Judge For Ignoring “Environmental InJustice”, NOTHING HAS CHANGED AT NJ DEP

Why would a federal Judge, in a legal opinion, be a harsher critic of DEP that the EJAC, environmental groups, and so called climate and EJ activists?

But the EJAC did issue a Statement on the Death Of George Floyd – but I couldn’t find any public statements on the DEP’s ozone SIP. Millions can’t breathe clean air.

I also could find no specific policy or clear set of technical demands by the EJAC for critical current DEP regulatory clean air issues, including:

• EJ community exposures to cancer causing hazardous air pollutants
• DEP lack of regulation of cumulative risk & impacts to multiple exposures and multiple pollution sources
• DEP’s failure to update the cancer risk screening, risk assessment, & pollution dispersions technical requirements
• DEP’s failure to enforce the NJ Air Pollution Control Act’s “advances in the art” standard
• DEP’ failure to require community level ambient air quality monitoring
• DEP’s long delayed and upcoming “environmental justice’ permit review regulation
• DEP’s current Climate PACT GHG rule proposal

But from their most recently posted September 2021 meeting minutes, I noticed that Joanne Held is leading the EJAC efforts on the upcoming “Environmental Justice” rule (under an Orwellian “Ad Hoc Rules” banner, and behind schedule):

It sure looks like the EJ folks are playing all inside baseball with the DEP technocrats and political games with Gov. Murphy – and that is a losing game.

The American Lung Association and NJ Environmental groups used to issue Reports and hold press conferences to explain this important information to the public.

I read that the new head of the Sierra Club NJ Chapter is an expert on air pollution.

And any one could have simply requested that DEP hold a public hearing, which could provide a venue to present this information to the public, to hold DEP accountable and for the community to ask questions and pressure polluters.

But none of that happened (unless I and NJ media just missed it). 

It wasn’t always like this.

What went wrong? What explains the total collapse?

Why is no one working on these issues?

More Evidence That The Murphy DEP Is Worse Than The Christie DEP

[Update: I confirmed this in a second place. Buried on DEP website bio of Sean Moriarity:

Sean leads DEP’s internal legal team and serves as its general counsel on all matters of regulatory compliance and rule-making, and will oversee the newly created Office of Enforcement Policy. He also is a member of the Commissioner’s executive team, providing input on priority initiatives that include climate change and environmental justice.

This is overt politicization of enforcement. It centralizes control of enforcement in the hands of a former corporate lawyer.

If Gov. Christie and his DEP Commissioner Bob Martin ever did this, the environmental groups would be in the streets, complaining about “taking the cop off the beat” and “giving polluters a pass” and “polluters holiday” at DEP.

Yet not a peep of criticism – and I got no inquiries from media either. Unbelievable collapse. ~~~ end update]

Sometimes you find amazing things reading DEP documents.

Just now I learned, according to the DEP posted official minutes of the Environmental Justice Advisory Council’s June 2021 meeting, that DEP Commissioner LaTourette – former corporate polluter lawyer – has eliminated DEP’s enforcement Division!

And get this, ironically, the justification is “greater alignment”!

(Gov. Christie’s DEP Commissioner Bob Martin coined that phase in seeking “alignment” of DEP’s land use programs, which was a cover story for regulatory rollbacks and insane management re-assignments and bureaucratic reshuffling. But even Commissioner Martin wouldn’t get away with eliminating DEP’s enforcement division on those grounds. Of course, I nailed Martin on his “alignment” rollbacks, which he used to justify both land use “alignment” and federal consistency rollback “alignments”:

The “customer service” & “culture change”  Christie DEP Commissioner Bob Martin rolled back DEP’s Highlands and land use regulations under the guise of “regulatory alignment” and reducing “regulatory burdens” and “red tape”).

But let’s get back to Commissioner LaTourette’s elimination of DEP’s Enforcement Division (which Division, a single Division, or all of them, I don’t know).

Here are the EJAC minutes:

Highlands Council Releases Economic Plan Designed To Promote Development

Economic Development Oriented Plan Contradicts The Basic Goals Of The Highlands Act

Plan Developed By National Economic Consulting & Engineering Firms

Private corporate planning targets 23,000 acres for intensive new development

The ecologically precious Pinelands are not the only place that Gov. Murphy is promoting damaging corporate economic schemes (for Gov. Murphy’s Pinelands scandal, see: “Green Masks Are Off” and this Star Ledger editorial blasting the Gov.)

The Murphy Administration just released its plan for promoting development of the environmentally sensitive NJ Highlands, a million acre forested region that supplies millions of NJ residents with drinking water that was protected by special national model land use Legislation known as the NJ Highlands Act (you can read the Murphy economic plan here) (Gov. Murphy sure put “his stamp” on the Highlands).

[Note: Under the Highlands Act, the Gov. appoints the Chairman who appoints the Executive Director, Lisa Plevin, so she effectively “serves at the pleasure of the Governor.” The Gov. has veto authority over the Council’s minutes. The Gov. has budget control over the Council. If the Gov. did not support this economic plan development, he could have vetoed the minutes or not funded it in the budget. Lisa Plevin has been around government for many years and she would never pursue something this significant without a green light from the Gov.. While it was released by the Highlands Council, Gov. Murphy’s owns this plan.]

In contrast to the Gov.’s economic development vision for the region, the Highlands Act was enacted to preserve and protect the forests and water resources of the region from destruction by rampant development:

The Act bifurcated the Region into a core “Preservation Area” and a peripheral “Planning Area”.

Preservation is the goal of the core Preservation Area and the planning for that core is backed up by strict mandatory DEP regulations. The Act allows only very limited development in the Planning Area that is “compatible” with the severe environmental constraints of the region. The Act does not authorize or encourage economic development planning for the “Preservation Area”. For the less protected “Planning Area”, the Act specifically restricts development, to only that which is “compatible” with protecting the resources of the region. The Highland Act’s only development oriented goal for the less protected “Planning Area” of the region still requires recognition of environmental constraints (my emphasis):

The Act reiterates that mandatory compatibility requirement for the limited allowable growth areas of Planning Area:

The Murphy economic development plan ignores these goals and requirements of the Highlands Act, and never once mentions the “compatibility” requirements or any other regulatory or science based natural resource constraints (e.g. water availability or reducing greenhouse gas emissions). 

The Murphy economic development plan for the Highlands region was developed by two national corporate economic development consulting and engineering firms, Camoin Associates (they brag of “more than 1,000 completed economic development projects“), and Colliers Engineering and Design  (they brag of managing over $40 billion in assets with annual revenues of $3.3 billion). 

I do not know how much these consultants were paid or how the firms were selected, but I suspect that we will find more corporate cronyism with the Murphy administration.

There are many pressing high priority things that the Highlands Council needs to do to better protect the forests, water resources, and wildlife of the region from the accelerating threats of climate change, over-development, and legacy pollution (which leads to things like harmful algae blooms) – which is their mission under the Highlands Act. 

Perhaps highest on that list would be planning for the transition to zero carbon.

An economic development plan would be about the last thing on any rational, science based planning priority list for the Highlands region.

The Steering Committee for guiding the corporate consultants who wrote the economic plan was comprised of economic development and real estate interests, with no environmental representation. There was no formal public planning process for developing the economic plan.

This is an outrageous violation of fundamental planning and democratic principles which require balanced representation of affected interests, public participation, and transparency.

As such the Murphy economic plan amounts to private corporate planning for the region.

That is not the planning process or the planning goals established by the Highlands Act.

It is a betrayal of the public interest and a complete contradiction of all the public, open, and transparent planning processes that began with Gov. McGreevey’s Highlands Task Force (which I staffed when I was at DEP).

The goals of the economic plan hide behind all the best public relations and greenwashing slogans corporate money can buy (and they call the plan “Going Green”! – see chart on page 9: “Time to Go Green” )

This public relations greenwash sloganeering is reflected in the title of the economic plan itself: (aside from the scientifically meaningless term “sustainability”, note the economic focus – not ecological, water resource, forest, or environmental sustainability):

• The New Jersey Highlands Economic Sustainability Plan

Of course, this narrow and exclusive emphasis on economic development contradicts the legislative goals of the Highlands Act and the Highlands Regional Master Plan (RMP) and the DEP Highlands regulations.

Perhaps that’s why the plan mentions the Highlands Act exactly once and in a way that implicitly disparages the Act’s “mandates” and their limited scope and : (@ p. 24)

While Highlands Act mandates apply only to certain portions of the study area counties, it should be noted that this analysis seeks a global perspective on industry and sociodemographic trends that will guide policy for Highlands municipalities.

“Guide policy for Highlands municipalities? Say what? The Highlands Act stripped land use powers from Preservation Area municipalities and strongly encouraged Planning Area municipalities to “conform” their local land use plans and zoning to the Highlands RMP.

Why is a Highlands Council funded economic plan ignoring this fundamental land use issue and focusing on municipal policy? Land use policy is set by the Highlands Act, the RMP, the DEP regulations, and the Highlands Council, not municipal governments.

And for the record, as I wrote most of them, the “mandates” of the Highlands Act apply only to the Preservation Area as a result of a compromise with powerful political and economic development interests in the region.

The Plan mentions “regulations” just 3 times, and suggests that they are a barrier to development of housing for the region (@ p. 10):

The housing market is feeling pressure from both the supply and demand side. Determining the appropriate land use regulations that will support creative housing solutions will be key to retaining and attracting residents.

“Appropriate land use regulations” have already been adopted and codified in the Highland Regional Plan and the DEP Highlands Regulations. This economic plan is not the forum to reconsider what “appropriate land use regulations” are.

The plan virtually ignores DEP’s Highlands regulations, with one exception that promotes growth: location in a DEP approved sewer service are is one land use development “suitability criteria” (@ p. 94).

The Plan targets 23,000 acres for intensive new development (@ p. 95)

As shown in Table 1 below, the analysis indicates that over 23,000 acres of land are suitable for the development of new industrial manufacturing uses within the Highlands Region.

The location of this development is not known. The GIS maps are in the attachments which were not included in the plan they released.

The Plan analyzes “growth potential” and explicitly documents “locating opportunities” to attract new development, focusing on: (@ p. 94))

1) Industrial manufacturing development 

• Specialized Manufacturing
• Biotechnology & Life Sciences
• Food Production

2) Office development 

• Financial & Insurance
• Corporate Offices

With respect to the controversial proliferation of warehouse sprawl, the plan recognizes warehouses (seemingly as an appropriate economic development and a good thing!) but proposes no restrictions: (@ p. 20)

There is continued demand for industrial real estate in the counties. The demand is driven by firms involved in distribution, supported by warehousing as well.

This promotion of development is wildly in conflict with the vision and goals of the Highlands Act.

The “data sources” upon which the economic plan is based (see Attachment A) include the following:

• ECONOMIC MODELING SPECIALISTS INTERNATIONAL (EMSI)
• ESRI BUSINESS ANALYST ONLINE (BAO)
• COSTAR
• CENSUS OF AGRICULTURE, U.S. DEPARTMENT OF AGRICULTURE (USDA)

There is not one natural resource, water resource, or environmental data set even mentioned.

While the economic plan gives short shrift to mapped DEP sewer service areas and Highlands growth centers and gives them “suitability points”, the plan does not discourage or recommend prohibition of “inappropriate” and “incompatible”  development outside those areas.

Climate change – in terms of the requirement to reduce greenhouse gas emissions by 80% to meet the goals of the NJ Global Warming Response Act or the Gov. recent Executive Order (50% by 2030) – is completely ignored.

The need to reduce GHG emissions is not even mentioned in the economic plan. How can economic growth planning ignore carbon constraints?

There is no consideration of the energy or environmental or water resource or forestry impacts of the economic development promoted by the plan. No cumulative impacts considered (as required by the Highlands Act). No environmental justice impacts. No environmental impact analysis. None.

How could this be?

The economic plan limits consideration of climate change to “adaptation” to climate impacts.

And even the climate adaptation planning sections ignore the massive development pressures that will be created by people migrating out of coastal areas that are inundated or destroyed by sea level rise and storms or the people displaced by increasingly frequent and severe flooding.

These people will have to relocate somewhere and it will likely be in higher elevations like the Highlands.

On top of all these egregious flaws, I want to close by noting a deeply disturbing pattern:

1. Once again, the Murphy administration has promoted a corporate friendly Neoliberal economic scheme that is wildly out of step with NJ’s historical policy emphasis on environmental protection, strict regulation, and regional planning. The highly controversial initiative is developed largely behind the scenes with little or no public awareness or involvement.

2. Once again, the Governor’s economic development initiatives are worse for the environment than Gov. Christie’s. Christie attacked the Highlands Act and sought to promote economic development by rolling back the DEP septic density standards. But at least he did so openly and was held accountable for it. Murphy, no so much.

3. Once again the media fails to cover the issues.

4. And, perhaps most disturbing of all, the environmental watchdogs have failed to bark. No, they are too busy with promoting pub crawls and automobile tours and fundraising.

Julia Somers was “interviewed” by the corporate consultant who prepared the plan and was the sole token environmental interest that served on the Technical Advisory Committee, so she was fully aware of the initiative and apparently did nothing to warn the public or represent the many activists and environmental groups that fought for passage of the Highlands Act. What a fucking sellout.

Julia and Eliott Ruga at the Highlands Coalition now join Carleton Montgomery and  Ed Potosnak on the cowardly Gov. sycophant list and my shit list.