DEP Privatizing Assessment Of Carbon Sequestration & Storage In NJ Forests
DEP is flying by the seat of their pants in an ad hoc and site specific fashion, totally reliant on private groups and contractors with scientific bias and economic interests in the outcome, and with zero transparency or accountability.
This is straight up privatization of NJ’s public forests and it’s being done in the dark.
Management of NJ’s forests to promote carbon sequestration and storage and adapt to climate impacts were the most important and controversial issues that were debated for months by Senate Environment Committee Chairman Bob Smith’s Forestry Legislative Task Force.
The Task Force issued its Report and recommendations – including a dissenting minority Report – almost 2 years ago. Their Legislative and regulatory reform recommendations have gone nowhere.
But none of that seems to have had any impact on the Murphy DEP’s climate and forest management policies and practices, which promote commercial logging in public forests as an acceptable form of “forest management”.
Given this backdrop, and the significant controversy over logging at Sparta Mountain Wildlife Management Area (WMA) – and other DEP logging fiasco’s at WMA’s – I was surprised to learn today that DEP has now expanded the justification for that logging to include carbon sequestration and storage and is implementing a carbon management program.
Today, via the NJ Open Public Record Act, I obtained a DEP approved “Carbon Assessment for Sparta Mountain WMA Stand 7/8 Activity”.
The “assessment” was submitted to the DEP by NJ Audubon. Audubon promotes forestry (logging), provides paid forest management consulting services, benefits from private and public grants to conduct forest management, and owns forested land. Thus they have gross scientific bias and economic conflicts of interest, particularly in light of emerging lucrative carbon credit markets and opportunities for carbon trading and carbon offsets in regulatory programs.
Despite these gross biases and conflicts, the Murphy DEP is relying on NJA to basically write their own ticket and define the policy objectives and scientific and technical methods for NJ’s forestry and climate related programs.
This is straight up privatization of NJ’s public forests and it’s being done in the dark.
See the letter I circulated below – this is unacceptable and must be stopped.
———- Original Message ———-
From: Bill WOLFE <b>
To: Silvia Solaun <ssolaun@gmail.com>, Dante DiPirro <dante.dipirro@gmail.com>, “dante@dantelawyer.com” <dante@dantelawyer.com>, “carleton@pinelandsalliance.org” <carleton@pinelandsalliance.org>, jason menegus <jwmenegus@hotmail.com>, Jaclyn Rhoads <jaclyn@pinelandsalliance.org>, Mark Lohbauer <mlohbauer@jgscgroup.com>, Julia Somers <julia@njhighlandscoalition.org>, “ben.spinelli@highlands.nj.gov” <ben.spinelli@highlands.nj.gov>, “Grogan, Susan [PINELANDS]” <Susan.Grogan@pinelands.nj.gov>, Anjuli Ramos <anjuli.ramos@sierraclub.org>, “Taylor McFarland, NJ Sierra Club” <taylor.mcfarland@sierraclub.org>, “dpringle1988@gmail.com” <dpringle1988@gmail.com>, domalley <domalley@environmentnewjersey.org>, “emile@njconservation.org” <emile@njconservation.org>, Matthew Smith <msmith@fwwatch.org>, Ken Dolsky <kdolsky@optonline.net>
Cc: senbsmith <SenBSmith@njleg.org>, sengreenstein <sengreenstein@njleg.org>, “senmckeon@njleg.org” <senmckeon@njleg.org>
Date: 01/08/2025 9:08 AM EST
Subject: DEP Forest Carbon Assessment Methods
Dear Climate and Forestry Leader – Attached is a Report submitted to DEP last year by NJ Audubon which provides an assessment of carbon and climate issues related to “management” (logging) at Sparta Mountain WMA:
Carbon Assessment for Sparta Mountain WMA Stand 7/8 Activity
The NJA analysis appears to be based on dated scientific literature and US Forest Service models – here are links to them:
ForGATE
https://research.fs.usda.gov/treesearch/43540
NED – 3
For comparison, here is a New York State analysis:
NEW YORK FOREST CARBON ASSESSMENT
https://www.esf.edu/cafri-ny/documents/cafri-report-2023.pdf
I lack the expertise to assess the NJA analysis or the USFS models. I do have sufficient expertise to know that models can be manipulated, vary in reliability, and are sensitive to and dependent on many subjective technical and value judgements about model design, assumptions, input parameters, and objectives.
I am very concerned because the NJA analysis, which was apparently accepted by the DEP, makes positive findings in terms of both carbon sequestration and storage resulting from NJA and DEP’s forms of “forest management” (logging).
I am also very concerned that DEP is implementing complex and controversial forest and climate management strategies and laying the groundwork for carbon credit generation and trading in the absence of:
- scientific peer review
- public involvement
- adopted standards, methods, models, Guidance, Technical Manuals, or protective regulations
- performance monitoring and assessment (and verification of carbon credits generated)
- staff and budget
- Legislative authorization and policy guidance
In other words, DEP is flying by the seat of their pants in an ad hoc and site specific fashion, totally reliant on private groups and contractors with scientific bias and economic interests in the outcome, and with zero transparency or accountability.
This is not acceptable.
Accordingly, I request that perhaps your organizations collectively retain expertise to review and critique the NJA assessment.
I also ask that you reach out to DEP to demand that they stop work on these various “forest management” projects pending adequate scientific and public oversight and adoption of a formal management program.
Bill Wolfe