Pinelands Preservation Alliance’s Pitiful Defense Of DEP’s Logging Plan
Ex. Director Carleton Montgomery Directs Junior Staffer To Walk The Plank
PPA Puff Piece Provides Pitiful Platitudes
Let me first state right up front that Carleton Montgomery is a despicable and dishonorable coward. And a gaslighting liar. And possibly a plagiarist as well (see #8 below).
Instead of publicly defending the controversial DEP logging plan that he supported for two years in behind closed doors meetings consumed with making quiet compromises with DEP, he forced his most junior staffer to write a blog post defending the DEP plan.
And this blog post was written AFTER the Commission approved the plan and the critics, like myself, first became aware of the project and started to protest and seek a veto by Gov. Murphy.
Carleton directed a young woman, Heidi Yeh, Policy Director, who joined PPA just this year, who has no forestry science or land use or regulatory expertise or experience, and who is likely distracted by writing her PhD dissertation at Rutgers on unrelated Marine and Coastal Science issues, to post on PPA’s blog, this pitiful capitulation, which is riddled with fact errors, assumptions, unsubstantiated premises, lack of relevant information, and flawed science:
Here is my first round of questions and comments to the author of that piece – criticism I feel terrible in having to write to her, when Carleton bears responsibility and should be the target of this criticism. (I apologize for the screwed up font, which I can’t seem to fix):
(and I thought that candidates for the PhD degree in science had been taught to honor the scientific method, which includes, among other things, weighing all available credible evidence in reaching conclusions and striving to eliminate bias. The informal blog format and engagement in a “policy” domain does not alleviate a scientist of that burden of basic reasoning and thinking skills.)
Hi – I’ve been writing quite a bit on the DEP plan and a mutual friend just sent me your blog post, so I’d like to ask you a few questions, OK?
I’ll do this in 2 steps: first, a few questions about your awareness of relevant available information and then some questions on the substance (in a second email).
By way of introduction, I’m a retired DEP policy planner (13 years), policy Director of NJ Sierra Chapter (7 years) and Director of NJ Public Employees for Environmental Responsibility (PEER) (10 years).
I see you’re in coastal science at Rutgers, so you can say hello and ask Professor Mike Kennish about me if necessary. I worked with him on some of his Barnegat Bay work. I also note your interest in [the role of the scientist in] policy, so you might want to check out a piece I wrote about that topic and the stance of certain scientists at Rutgers and Princeton, see:
Jim Hansen’s Talk at Princeton Provides A Sharp Contrast to Rutgers Climate Conference On Role Of Scientist
You wrote this, which is obviously targeted at my work, so I think I deserve the courtesy of a reply:
“Unfortunately, there has been some hyperbole in criticisms raised for the first time after the Commission approved the plan”
My criticisms are fact based and grounded in science and law and reflect 35 years of professional experience and graduate school level training (Cornell). They are not “hyperbole”. In terms of coming “after” the approval, as described below, I was affirmatively prevented from reviewing documents and timely submitting comments. Your comments are false and personally offensive. [That “after the fact” BS is amazing criticism, in light of the fact that PPA and NJCF kept this DEP plan quiet and off the public radar for 2 years.]
1. Your bio notes you joined PPA in 2022 – were you involved in PPA’s 2 year long review of the plan, which you note began in 2020? If not, who was? How did you review that process to gain sufficient knowledge to vouch for it in your own words?
Do you have training or experience in forestry, or DEP and CMP regulations?
2. You note that:
“Pinelands Preservation Alliance and the New Jersey Conservation Foundation were the only members of the public who provided substantive comments to DEP and the Pinelands Commission during the development and review of this plan.“
Were you aware that I filed a petition for rulemaking to the DEP and Pinelands Commission on these specific issues of forest management, wildfire and land use earlier this year, and that petition was denied and gathered no support from PPA and NJCF?
Were you aware that I learned of this project by reading the Commission’s July Monthly Management Report and immediately filed an OPRA public records request on August 9 for the DEP plan and related Commission review documents? Are you aware that the Pinelands Commission staff denied that request on the basis that they had “no responsive records”?
Were you aware that I then attempted to file public comments on the DEP plan, in the absence of any documents, which were rejected by staff because they were submitted after the close of the public comment period?
The fact that there was no public participation other than PPA and NJCF is because there was no public knowledge of the plan and DEP and the Commission actively suppressed information.
So, why were no other members of the public given a heads up and opportunity to participate in this informal review process by PPA and NJCF?
Are you aware that when a controversial project comes along, NJ environmental groups typically issue “action alerts” to the public and their members to allow participation (or they issue press releases, or blog posts).
Did PPA do ANY of that? For the 2 YEARS they negotiated with DEP?
3. Are you familiar with the DEP land use, water quality, and forestry regulations and Pinelands CMP provisions that apply to this project (or provide loopholes, exemptions, voluntary standards, etc)? Do you have regulatory training and experience?
Are you aware that Stacey Roth, Pinelands Counsel, has taken the legal position that the Pinelands CMP does not apply to greenhouse gas emissions or climate change impacts and therefore are not regulated under the CMP?
The same loopholes – and more – apply to DEP regulations (more on that in next post, especially ad your blog post praises specific regulatory aspects).
4. Did you personally review the DEP plan and the Pinelands Commission’s approval document (w/conditions)?
5. You write:
“Our fundamental criteria for evaluating any forest management proposal on public land are whether it has a legitimate justification,“
Are you aware of Pinelands Commissioner Wallner’s analysis and comments on the plan – he’s a retired *National Park Service wildfire expert?
Wallner stated on the public record that he reviewed the maps and found little to no people or property at risk and therefore found no justification for the project. He also said DEP provided no wildfire justification for the project in the Plan. He also said DEP conducted no alternatives analysis (like required under NEPA) or consideration of a “no action” alternative. (NJ does not have a State NEPA law, so there is no EIS required).
Wallner’s analysis directly contradicts the headline, assertions, and conclusions of your blog post. His analysis is not mentioned in your blog post. Are you comfortable with that as a scientist?
6. Are you aware of Pinelands Commissioner Lohbauer’s analysis – both orally on the public record and in writing after to explain his no vote?
Again, Lohbauer’s findings and conclusions directly contradict your analysis, yet are not even mentioned in it.
Again, are you comfortable with that as a scientist?
You feel confident to directly contradict a retired USFS wildfire expert and a longstanding leading Pinelands Commissioner? And without even mentioning their criticism? That arrogant approach contradicts the conclusion of your blog post:
“PPA supports plans that take into account all aspects of Pinelands health and diversity, and welcomes comments based upon science and experience about how best to protect this unique ecosystem.”
7. You state (with no supporting citations)
“Modern forestry science advocates that this ladder be cut off to prevent more destructive forms of fire.”
Where did you get that? From DEP forestry people?
Have you reviewed Chad Hansen’s (PhD, forest ecology) work that was presented to the Pinelands Commission in March 2021 by Leslie Sauer (PhD forest ecologist)?
Are Chad and Leslie somehow ancient and scientifically misguided?
Again, no mention of that critically relevant and important scientific work.
8. You used two phrases that caught my eye:
“Critics that focus only on the number of trees, but not their size and type, are quite literally missing the forest for the trees. The resulting forest will be a healthy native Pine Barrens habitat.”
Curious, both those phrases were attributed to Carleton Montgomery in the Associated Press story.
Did you write those words? If so, did Carleton plagiarize them? Or did Carleton edit them into your piece.
Regardless, your claim are false. My criticism – and that of all others I am aware of – did not “focus only on the number of trees”.
[And what are your definitions, criteria, and standards that support this conclusion that the DEP logging will result in a “healthy native Pine Barrens habitat.”
My next inquiry will focus on fact errors in your post and other substance.
I appreciate a timely and thoughtful reply.
Bill Wolfe
*corrected 12/13/22