WolfeNotes.com

Environmental And Climate Groups Oppose DEP Extension Request 

Very Little Public Participation In DEP’s Public Hearing This Morning

The Murphy DEP is seeking a 9 year delay, until 2033, for compliance with the 70 part per billion National Ambient Air Quality Standard (NAAQS) for ground level ozone:

Reclassification Request for Northern NJ-NY-CT Nonattainment Area

As discussed in New Jersey’s letter to USEPA dated May 23, 2024, based on monitoring data and modeling data, New Jersey requests a voluntary reclassification for the Northern NJ-NY-CT Nonattainment Area from Moderate to Severe, with a new attainment date of August 3, 2033. (SIP @ p. xix)

NJ is not in compliance with the current standard, failing to meet the standard on 17 days in 2023. Ozone is a major threat to public health, see DEP Ozone SIP:

Ozone causes health problems because it damages lung tissue, reduces lung function, and sensitizes the lungs to other irritants. Ozone has long been known to increase the incidence of asthma attacks in susceptible individuals. Ozone exposure also makes the lungs more vulnerable to lung diseases such as pneumonia and bronchitis. Ozone not only affects people withs impaired respiratory systems, such as asthmatics, but healthy adults and children as well. Exposure to ozone for several hours at relatively low concentrations significantly reduces lung function and induces respiratory inflammation in normal, healthy people during exercise. This decrease in lung function is generally accompanied by symptoms such as chest pain, coughing, sneezing, and pulmonary congestion. Recent research in southern California strongly suggests that, in addition to exacerbating existing asthma, ozone also causes asthma in children.39 Longer-term exposure to ozone can also lead to scarring of the lung tissue and permanent reductions in lung capacity.40 Long-term exposure to ozone can eventually lead to premature death.41

Climate change and increasing number of extreme heat days will only make current problems worse, as high temperatures exacerbate ozone formation and lead to higher levels.

The DEP held a public hearing on the proposed State Implementation Plan (SIP) proposal this morning.

The DEP submitted the proposed SIP and 2033 extension request to the EPA for approval.

DEP is also asking for an extension and compliance relied under an “Extreme Events Demonstration” as a result of wildfires in Canada and the Midwest that impacted NJ’s air quality last June.

Two environmental groups testified to oppose the delay request: Ken Dolsky of Don’t Gas The Meadowlands and Amy Goldsmith of Clean Water Action.

Both made similar comments about the need to ratchet down on current pollution sources and impose mandatory measurable and enforceable pollution control strategies. Both emphasized the impacts of climate change on extreme weather and the number and intensity of bad air ozone days.

I testified as a citizen.

I criticized the procedural error the Department made in posting an incorrect date of the public hearing on the DEP website. I requested that the DEP go back to square 1 and republish a new 30 day comment period and hold real public hearings across the state. I also criticized the lack of public outreach and community involvement, particularly in disproportionately burdened environmental justice communities.

I also criticized the closure of the Newark air quality monitoring station and failure to open a replacement. I noted conflicts between the DEP’s claims of 17 monitoring stations versus reporting data from only 8 of them. And I called for an expansion of the network to measure actual ground level urban conditions where people breathe. see:

“The NJDEP currently measures ozone concentrations at 16 sites in New Jersey. Seventeen sites were running prior to September 2022. The Newark Firehouse site was closed in September 2022 and NJDEP is currently working on re-establishing a new monitor in Newark City.” (@ page 2-1)

• There Is No Air Pollution Monitoring Station In Newark – The Murphy DEP Shut It Down

I opposed the wildfire exceptional event demonstration. see:

• Murphy DEP Seeking Relief For Violating Clean Air Ozone Standards – Blames Wildfires As “Exceptional Events”

I noted significant inconsistencies and conflicts in data, particularly with respect to projected climate related emissions reductions versus various projected growth factors, particularly for use of natural gas. DEP SIP projects emissions reductions and compliance, yet many other variables are increasing.

Finally, I questioned the assumptions, data and models for the Transportation Conformity Analysis. There have been major increases in highway and port capacity, vehicle miles driven, and emissions, yet the SIP relies on projected reductions in mobile source emissions, despite all this growth!

I was pleased by Ken’s and Amy’s testimony, but disappointed that there was no other environmental groups or citizens participating, given the importance of this DEP plan for public health.

I’ll file a request for a hearing transcript and post a link when I get it.

In the meantime, the public comment period is still open until July 17 and people should reach out to EPA and demand that they deny DEP’s extension request and enforce the Clean Air Act. This would force DEP to crack down on polluters and reduce emissions.

Overt Politicization Of Science, Industry Control, Abdication To Voluntary Local Efforts

The Red Meat Ideological Rhetoric Is Revealing

“The Paranoid Style in American Politics”

Again way out in front, we were warning and beating the drum about “Project 2025” last July. 

In a July 25, 2023 letter to NJ legislators, Gov. Murphy’s DEP Commissioner LaTourette, and media, we wrote:

I write to give you a heads up and urge you to read the Heritage Foundation’s recent initiative called “Project 2025″. It is explicitly designed to “dismantle the administrative State”. FULL REPORT HERE:

Chapter 13 provides a radical agenda to dismantle EPA and virtually all regulatory, science, and climate programs – read it here:

https://thf_media.s3.amazonaws.com/project2025/2025_MandateForLeadership_CHAPTER-13.pdf

I strongly urge you to get out in front of and do everything within your power to derail this freight train.

Of course we were ignored.

But now that the Democrats, Biden campaign, and the media finally have begun to focus on Project 2025, we thought we might begin to highlight the overt ideological framework and key aspects of the environmental and climate policies of Project 2025.

These radical policies must be considered in light of the personnel who will implement them – as originally outlined in the Trump “Schedule F” plan – to replace thousands of civil service scientists and experts with Trump loyalists.

And as we’ve written many times, these policies also must be considered in light of a right wing Supreme Court hell bent on “dismantling the administrative State”.

Chapter 13 targets US EPA.

Right up front, in red meat ideological rhetoric, they revealingly state the “problem”, and in doing so overtly politicize the EPA:

The challenge of creating a conservative EPA will be to balance justified skepticism toward an agency that has long been amenable to being coopted by the Left for political ends against the need to implement the agency’s true function: protecting public health and the environment in cooperation with states. Further, the EPA needs to be realigned away from attempts to make it an all-powerful energy and land use policymaker and returned to its congressionally sanctioned role as environmental regulator.

The first attack is on EPA regulations, particularly regarding climate and energy:

The Status Quo. Not surprisingly, the EPA under the Biden Administration has returned to the same top-down, coercive approach that defined the Obama Administration. There has been a reinstitution of unachievable standards designed to aid in the “transition” away from politically disfavored industries and technologies and toward the Biden Administration’s preferred alternatives. This approach is most obvious in the Biden Administration’s assault on the energy sector as the Administration uses its regulatory might to make coal, oil, and natural gas operations very expensive and increasingly inaccessible while forcing the economy to build out and rely on unreliable renewables.1

They next signal exactly how they will “dismantle” EPA.  In doing so, they assert and connect dangerous political and legal falsehoods.

The dismantling will occur first by installing Trump loyalists to replace the “leftists” (“embedded activists”) via Schedule F. With radical Trump loyalists in charge and EPA science sidelined, there will be overt legal attacks in EPA regulatory policy and the invitation of right wing legal groups to bring cases to the US Supreme Court in order to expand their radical new “Major questions” doctrine and restoration of the 19th Century pre New Deal “non-delegation” doctrine.

The Court’s reversal of the “Chevron” doctrine was only the first step in dismantling the New Deal’s “administrative state”.

Here are Project 2025’s own words:

A Coopted Mission. The EPA has been a breeding ground for expansion of the federal government’s influence and control across the economy. Embedded activists have sought to evade legal restraints in pursuit of a global, climate-themed agenda, aiming to achieve that agenda by implementing costly policies that otherwise have failed to gain the requisite political traction in Congress. Many EPA actions in liberal Administrations have simply ignored the will of Congress, aligning instead with the goals and wants of politically connected activists.

EPA is a “breeding ground” that has been “coopted” by “embedded activists”? That’s an echo of “the paranoid style in American politics”:

I call it the paranoid style simply because no other word adequately evokes the sense of heated exaggeration, suspiciousness, and conspiratorial fantasy that I have in mind.

The ideological attacks particularly focus on climate – and are code for Trump’s cruder claim that climate change is a Chinese government “hoax”:

Although the U.S. environmental story is very positive, there has been a return to fear-based rhetoric within the agency, especially as it pertains to the perceived threat of climate change. Mischaracterizing the state of our environment generally and the actual harms reasonably attributable to climate change specifically is a favored tool that the Left uses to scare the American public into accepting their ineffective, liberty-crushing regulations, diminished private property rights, and exorbitant costs.

EPA works via “fear” not science. The climate emergency is merely a “perceived threat”, not real (in other words, a “hoax” to quote Trump). The “Left” is “mischaracterizing” science and “scaring” the American public (“fake news!”). And it’s all really just a communist attack on Liberty and Property Rights!

As they say, when the right wing’s rhetoric makes their radical political program so obvious, believe what they say.

“When someone shows you who they are, believe them the first time.” #MayaAngelou

(In Part 2 and subsequent posts, we will highlight specific policy and program recommendations to “dismantle the [EPA] administrative state”)

NJ Spotlight Interview Misses The Mark

The Rutgers annual State Of The Climate Report, while dodging key policy and regulatory issues, explicitly poses a critically important and terrifying scientific question:

In a full page sidebar the Report asks:

Is Global Warming Accelerating? (@ page 7)

If the rate of global warming is accelerating, the climate emergency is far worse than current science estimates and all the climate models underestimate the actual warming and impacts.

Of course, if the warming is accelerating, that means that policy responses must be faster and more aggressive than current lame efforts.

If the rate of warming is accelerating, then emissions reductions must be deeper and faster than the stated reductions governments are failing to make.

Here’s how Rutgers poses the question:

Dr. James Hansen of Columbia University has suggested that the record temperatures in 2023 may be indicative of an increase in the rate of global warming. 96 He has cited recent increases in Earth’s energy imbalance – the difference between the sunlight absorbed by the Earth and the heat energy radiated back to space – in support of the accelerated warming hypothesis.

But, Rutgers fails to note how absolutely devastating that acceleration hypothesis would be or to explore the implications for climate science or for public policy.

Instead, Rutgers concludes that the hypothesis is just that and its too soon to tell:

The accelerated warming hypothesis is controversial. Accurately measuring Earth’s energy imbalance is challenging, and there are technical disagreements among climate scientists about the evidence for a recent increase in the imbalance. Another complicating issue is that the global temperature record is replete with short-term ups and downs, even in the absence of the effects of El Niño (and La Niña, its cooler counterpart), which make it difficult to determine if the warming rate has increased. Global temperature data over the next several years, in conjunction with measurements of Earth’s energy imbalance, may eventually allow us to answer the question posed in the title of this sidebar.

Controversial? Challenging? Complicated? Difficult? May Eventually?

Those are timid words of evasion, equivocation, and obfuscation, as I wrote just days ago:

The [Rutgers] Report also downplays recent scientific concerns that the rate of climate warming is accelerating greatly, see:

• Profiles In Climate Courage

Amazingly, essentially validating my criticism, State Climatologist was interviewed in a NJ Spotlight story today.

Instead of engaging this critical issue of whether warming is accelerating, he deftly dodged it, but did manage to muddy the waters with an emphasis on how NJ warming is greater than the rest of the country:

NJ Spotlight News spoke with David Robinson, the state climatologist and co-author of the report, about the threats that the warming climate might pose for the state.

“We are rising at a pace almost twice that as other parts of the country for a variety of reasons that are known and still being worked on,” said Robinson. “And so you’re dealing with that added heat, which is directly affecting your body, but you also have to start thinking about invasive species that can come in and bring disease with them. In the past, [they] maybe couldn’t make it through a cold Jersey winter, and now they’re able to survive.”

The NJ Spotlight journalists and the general public have little ability to distinguish between the rate of global warming versus the relatively greater NJ warming.

If the rate of global warming is accelerating, that devastatingly impacts everything and it is far more significant than the relatively greater NJ warming – and Robinson knows that.

And of course, Robinson spun the science in his emphasis on NJ “wildfires”. He knows which way the winds blow in Trenton.

Once again, no profile in courage.

Lack Of Monitoring Contradicts “Environmental Justice”  & Public Health Science

DEP Will Hold A “Virtual” Public Hearing On July 16

(Caption: I took the above photo back in 2009 and posted it on Newark pollution. I just now learned the Reichold Chemical Newark plant was shut down in 2012 as a result damage from Superstorm Sandy.)

[Important Updates Below]

The Murphy DEP Commissioner LaTourette constantly stresses his priority commitment to “environmental justice”.

The DEP and public health scientists warn that the worst pollution threat to the health of overburdened environmental justice urban communities – particularly children and elderly people –  is ground level ozone: (Source: DEP Ozone SIP)

Ozone causes health problems because it damages lung tissue, reduces lung function, and sensitizes the lungs to other irritants. Ozone has long been known to increase the incidence of asthma attacks in susceptible individuals. Ozone exposure also makes the lungs more vulnerable to lung diseases such as pneumonia and bronchitis. Ozone not only affects people withs impaired respiratory systems, such as asthmatics, but healthy adults and children as well. Exposure to ozone for several hours at relatively low concentrations significantly reduces lung function and induces respiratory inflammation in normal, healthy people during exercise. This decrease in lung function is generally accompanied by symptoms such as chest pain, coughing, sneezing, and pulmonary congestion. Recent research in southern California strongly suggests that, in addition to exacerbating existing asthma, ozone also causes asthma in children.39 Longer-term exposure to ozone can also lead to scarring of the lung tissue and permanent reductions in lung capacity. Long-term exposure to ozone can eventually lead to premature death.

So, why is there is no DEP ozone monitoring station in Newark?

Take look at this, from the DEP Ozone SIP:

“The NJDEP currently measures ozone concentrations at 16 sites in New Jersey. Seventeen sites were running prior to September 2022. The Newark Firehouse site was closed in September 2022 and NJDEP is currently working on re-establishing a new monitor in Newark City.” (p. 1-12)

Did you get all that? Almost 2 YEARS later, and they’re “working on it”?

This is outrageous and unacceptable.

Why did DEP shut the Newark Fire House ozone monitoring Station down?

Why have they not replaced it with more and better monitoring in Newark and all NJ environmental justice communities?

Why are they holding a virtual meeting that is NOT accessible to many community members?

Why are they not holding real public meetings in environmental justice communities? 

Why did they do NO outreach to communities on this critically important air quality plan (SIP)?

Why doesn’t DEP mandate that major polluters monitor and pay for monitoring air quality in EJ communities?

Why doesn’t DEP greatly expand the monitoring network, both in terms of the number of stations and the pollutants monitored?

In response to my request, DEP is holding a virtual public hearing on July 16 at 10 am – you can get the call in information and speak and ask DEP these questions at this DEP website.

Time to walk the talk.

Don’t let them get away with this bullshit.

[End Note: DEP only collects ozone data at 8 sites, not the 16 sites they claim in the excerpted text above – to verify that lie, hit this link to see the DEP air quality monitoring network data.]

[Update: There’s no monitoring in Camden either, but the Biden EPA is all in: (EPA Press Release today)

Rowan University working in Camden, NJ will receive $100,000 for their project “Greening Camden: Educating, Empowering, and Enriching Communities for Climate Action and Cleaner Air”

Using urban greening initiatives (e.g., tree planting, nature-based solutions, and urban gardening) to help address the impacts of climate change and air pollution in Camden, New Jersey, an environmental justice and overburdened community. Activities span all seven stages of the environmental education continuum, including awareness, knowledge, critical thinking, problem-solving, decision-making, action, and stewardship. Notable activities involve creating learning modules, an online certificate program, and collecting micro-level air quality data from various locations.

These token grant programs are designed for patronage and manipulation – they do NOTHING to actually improve air quality and reduce air pollution. They are no threat to the corporate polluters and serve to mollify urban EJ communities and create the false appearance of doing something. Really disgusting. ~~~ end update]

[Update #2 – I just got this email from DEP – glad they noted they are acting in response to my request, but are they trying to gaslight me? The email says the hearing is on July 15, but the DEP link and webpage says July 16:

Dear Mr. Wolfe,

In accordance with the public notice below and attached, and per your request, NJDEP is holding a virtual public hearing on July 15, 2024 at 10:00 AM.   As noted below, the hearing call in information and guidelines are posted on our website at:

NJDEP| Air Planning | State Implementation Plan (SIP) Dashboard

[Update #3 – 7/10/24 – DEP made a fatal procedural error. DEP sent me an email that admits that they posted the wrong date (July 16) in their original public notice and on the DEP website. The actual hearing is on July 15. DEP wrote:

The hearing is on July 15, 2024 at 10:00 AM.

The public notice with the July 15, 2024 date is at the bottom of this email, was sent out via our listserv, and was posted on our webpages on June 6, 2024.

The hearing call in information link including the incorrect July 16 date was added to the webpage yesterday afternoon, and we have corrected the typo you mentioned.

Thank-you,

Judy Rand, PE she/her

That DEP correction gives the public 3 working days of public notice.

But hey, she/her got she/her’s pronouns right!

I filed an objection with DEP and EPA, demanding that they cancel the July 15 hearing and re-public notice a hearing with adequate 30 day notice. – ~~~ end update

No Data Or Analysis Of NJ Greenhouse Gas Emissions Or Policies To Reduce Them

New Focus On Wildfires Parrots Murphy DEP And Even Cites A DEP Press Release

Rutgers Scientists Are Hiding Behind The “Science”

This Thursday July 10 at 11 am (EST), Rutgers will host a webinar on their annual “State Of The Climate” (2023) Report. According to Rutgers: (emphasis mine)

The report provides an overview of outstanding 2023 weather events, followed by an in-depth analysis of historical climate data and future projections for New Jersey.

The authors focus on temperature, sea-level rise, precipitation, and extreme events, including a discussion of the summer 2023 Canadian wildfires that impacted air quality throughout New Jersey and how wildfires may be exacerbated with continued climate change.

Registration is required and you can register here.

I)  Big Data and Policy Issues Are Buried In The Methodology, Frustrating Accountability

In general, the Report paints a pretty dire picture of projected NJ impacts. I won’t go into them here, and urge you to read the Report.

However, the formatting, structure and presentation of the data and the projection methodologies make it virtually impossible to compare it to and evaluate it in terms of exactly the same science and data that DEP relies on as the basis for various regulations. From the flood elevation maps to the air quality data to the statistical storm events, this is extremely frustrating and the practice is by design.

Of course, in this Report, Rutgers – and the State Climatologist – continue the cowardly (mal)practice of presentation and analysis  to actually frustrate an assessment of DEP regulatory policy and performance. The Report also downplays recent scientific concerns that the rate of climate warming is accelerating greatly, see:

• Profiles In Climate Courage

Huge science and policy issues are buried in euphemism and use of the passive voice – examples: check out how the extent of and inability to control NJ’s over-development as a cause of flooding are hidden behind the term “type of ground cover”: (@ page 17)

The more saturated the ground, the less moisture it can accept, so more water will run off and accumulate in streams.Other factors influencing runoff include the type of ground cover and vegetation, terrain, storm duration, and precipitation intensity.

Accumulate in streams? Like flooding?

The Report does the same thing with the role of unregulated development and wildfire risk, masking DEP’s failure to limit development in high hazard wildfire areas: (@ page 27)

With more people moving into rural areas due to New Jersey’s high population density and housing pressure in urban areas, more human-caused wildfires are likely to occur.

Ironically, this statement cites the NJ Hazard Mitigation Plan. That was data I relied on in a petition for rulemaking to DEP to limit hazardous development – DEP denied it.

It’s as if land development (“more people moving”) were like the weather: an uncontrollable natural phenomenon!

Similarly, they continue a timid methodology which creates an artificial wall between just presenting the “science”, as opposed to engaging DEP policy and regulation. I’ve long been critical of this approach to communicating science and public policy, see:

• Jim Hansen’s Talk at Princeton Provides A Sharp Contrast to Rutgers Climate Conference On Role Of Scientist

Most glaringly, the Rutgers report does not mention actual NJ specific greenhouse gas emissions and trends in emissions or any ability to understand whether the State is making progress in reducing these emissions in terms of meeting science based reductions or the voluntary emission reduction goals established by the NJ Global Warming Response Act. see:

• Rutgers Covering Up Their Role In Drafting Flawed Climate Change Legislation

These practices effectively provide cover for major policy failure by the Governor, the Legislature, the DEP. They let the corporate climate polluters who emit greenhouse gases continue with impunity (i.e. no regulatory compliance obligations or financial accountability for “the social cost of carbon” their pollution imposes on NJ residents and ecosystems).

II)  New Wildfire Emphasis

This year’s Report includes a new section highlighting wildfire issues. My bullshit meter was immediately pinned.

This emphasis was not surprising, given the DEP’s recent emphasis on wildfires, nor was the fact that Rutgers broke their own fake wall between science and policy, even citing – multiple times – DEP press releases for data! (see footnotes 67, 68, and 93).

Of course, Rutgers does not go near any of the relevant DEP regulatory data or Clean Air Act State Implementation Plans (SIPs) for fine particulates and Ozone related to wildfire issues – including a currently pending ozone SIP – as I recently wrote about. see:

• Murphy DEP Seeking Relief For Violating Clean Air Ozone Standards – Blames Wildfires As “Exceptional Events”

• Murphy DEP Submits Revised Clean Air Plan for Fine Particulate Pollution (PM 2.5) To EPA – Plan Does Not Consider Smoke From Wildfires In Emissions Inventory

The Report, with one exception, also fails to mention the relationships with DEP’s failed forest management policies, with this exception, which inadvertently documents why DEP’s forestry and “prescribed burn” policies are fatally flawed:

Although it is projected that rainfall may increase in New Jersey on average, increasing temperatures and water demand will result in drier soils less suitable for agriculture and more conducive for wildfires in forest environments. (@ page 16)

On June 1st, a lightning strike ignited a wildfire in Quebec Province that grew
rapidly due to these dry conditions, continuous southeasterly winds, and unusually high temperatures and drought. (@ page 22)

Following this process, 63% of the variability in the Canada-wide annual area burned from 1959 to 1999 was affected by summer available moisture. (@ page 27)

In contrast, the DEP “prescribed burn” program mistakenly assumes that “fuel load” is the driver of wildfire risk, ignoring the science that document that humidity, wind, and soil moisture are the major factors, see:

• DEP’s Own Analysis Of The Dynamics Of The Wharton State Forest Wildfire Illustrates Why Their “Forest Thinning” And “Firebreak” Logging Plan Won’t Work

The DEP burns pollute the air and risks uncontrolled wildfire.

Amazingly, Rutgers fails to note that, according to DEP ozone SIP, that some of the wildfires that impacted NJ were caused by a “prescribed burn” that got out of control! see:

• Murphy DEP Seeking Relief For Violating Clean Air Ozone Standards – Blames Wildfires As “Exceptional Events”

Rutgers also fails to mention that DEP forestry (logging) projects reduce canopy cover, increase fragmentation and penetration of sunlight and wind, which dry out soils, duff, and vegetation, thereby increasing wildfire risks. They also stimulate the growth of invasive grasses and other highly combustible plants that also increase wildfire risks.

III) Air Quality Analysis Suggest Large Flaws In DEP Air Quality Monitoring

See below.

Given the above and other flaws, I posed a few questions to the Rutgers crew and asked that they respond to the following questions at Thursdays webinar. These are right up Ms. Kaplan’s wheelhouse, as she is a former longtime DEP professional.

———- Original Message ———-

From: Bill WOLFE <b>

To: “kaplan@envsci.rutgers.edu” <kaplan@envsci.rutgers.edu>

Cc: “Grogan, Susan [PINELANDS]” <Susan.Grogan@pinelands.nj.gov>, “shawn.latourette@dep.nj.gov” <shawn.latourette@dep.nj.gov>, “john.cecil@dep.nj.gov” <john.cecil@dep.nj.gov>, “ben.spinelli@highlands.nj.gov” <ben.spinelli@highlands.nj.gov>, Mark Lohbauer <mlohbauer@jgscgroup.com>, “wparry@ap.org” <wparry@ap.org>, “fkummer@inquirer.com” <fkummer@inquirer.com>, “jonhurdle@gmail.com” <jonhurdle@gmail.com>, Ken Dolsky <kdolsky@optonline.net>, Silvia Solaun <ssolaun@gmail.com>, Anjuli Ramos <anjuli.ramos@sierraclub.org>, “Taylor McFarland, NJ Sierra Club” <taylor.mcfarland@sierraclub.org>, “emile@njconservation.org” <emile@njconservation.org>, “carleton@pinelandsalliance.org” <carleton@pinelandsalliance.org>, Jason Howell <jason@pinelandsalliance.org>, Jaclyn Rhoads <jaclyn@pinelandsalliance.org>, Ruga Elliott <elliott@njhighlandscoalition.org>, Julia Somers <julia@njhighlandscoalition.org>, Matthew Smith <msmith@fwwatch.org>, domalley <domalley@environmentnewjersey.org>, “dpringle1988@gmail.com” <dpringle1988@gmail.com>, “Tittel, Jeff” <jeff.tittel@verizon.net>

Date: 07/08/2024 8:29 AM EDT

Subject: Rutgers State of Climate Report

Hi Ms. Kaplan – I’m reading the Report now and had a few questions on the new wildfire section.

1. Air quality monitoring data and analysis relies on EPA stations and interpolation. (maps are from Canadian sources?)

Why was there no mention of the DEP monitoring network and why no use of that data?

That DEP data is used for regulatory purposes in the NJ Clean Air Act SIP, I assume it is more robust, representative, and reliable.

2. There seem to be conflicts between the Rutgers air quality “hazard” analysis and the DEP SIP plans for PM 2.5 and ozone. Conflicts deal with frequency, duration and severity of the air quality hazards and health risks.

DEP SIP’s for PM 2.5 and Ozone report fewer and less severe violations of NAAQS that the Rutgers analysis suggests.

Are those conflicts a result of methodology and do they suggest that NAAQS are inadequate or is DEP air quality monitoring and SIP planning inadequate?

3. Why was national data on hospital admissions due to asthma (17% increase) used instead of NJ specific data?

I was out west for the last 7 years and am aware of wildfire issues. I assume that the national data reflect western conditions, which are far more extensive in scope (geography) and severity and duration.

4. The Report mentions a wildfire on Allen Road in Brigantine. This wildfire was the WORST in terms of air quality impact:

“Another day to note, on June 2nd, the Brigantine station registered a higher AQI than the rest of the sites due to smoke from the Allen Road wildfire in Bass River Township that burned 5,474 acres, 67,68 leading to locally degraded air quality.” (page 24)

The US Air Force REPI program data state that they create a NJ wildfire once every 10 – 14 days – I’ve written about that, see:

http://www.wolfenotes.com/2024/04/the-us-air-force-is-the-biggest-arsonist-in-the-pinelands/

Here is a map showing the location of in proximity to the Warren Grove AFB to Allen Road:

https://www.google.com/maps/search/allen+road+bass+river+nj/@39.6730715,-74.4847809,13z/data=!3m1!4b1?entry=ttu

The DEP also conducted a “wildfire prevention” forest management logging project along Allen Road.

Was the cause of that wildfire ever determined?

I find the location and timing with respect to the Warren Grove AFB and the DEP wildfire project more than coincidental.

5. DEP conducts a “prescribed burn” program that creates air quality impacts and risks of out of control wildfire – why was this program not mentioned and analyzed?

6. DEP conducts forest management programs that impact carbon emissions and budgets, wildfire, soil moisture, and air quality – again, why no mention of this?

7. Why no mention of DEP data on NJ’s greenhouse gas emissions and trends?

Why is analysis limited to global emissions? 

Please respond to these questions during the July 10 briefing.

Bill Wolfe