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

https://research.fs.usda.gov/nrs/products/dataandtools/software/ned-3-ecosystem-management-decision-support

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

Another News Management Job Brought To You By $100 Million From The Wm. Penn Foundation

All The News Money Can Buy

Today’s NJ Spotlight story that focuses on the Delaware River fisheries impacts of the drought is another illustration of news management, questionable journalistic ethics, and of sham science and spin from the NJ Department of Environmental Protection (DEP), see:

• Delaware River watershed drought: Good for the birds, the trout – not so much

I’ve long written about the water quality impacts from drought – a major issue that is again ignored by today NJ Spotlight story –  and I wrote specifically last month about concerns with trout impacts of low river flows and and NYC reservoir releases, see:

• The Murphy DEP Is Doing Nothing To Monitor Or Assess The Water Quality Impacts Of Drought On Drinking Water, Including Fisheries Or Ecological Impacts

[Note: DEP press spokespersons and NJ reporters should read NJ Geological Survey Reports, like this:

• History of Passing Flows In New Jersey, With Contemporary And Future Applications

The spin from DEP quotes in today’s NJ Spotlight story almost seems intended to rebut that criticism. So, I need to drill down on the falsehoods, omissions and misleading DEP claims.

First of all, the “journalistic source” for the NJ Spotlight story was created, funded by, and is a mouthpiece of the Wm. Penn Foundation ($50,000). They are the propaganda arm of Penn’s $100 million Delaware Watershed initiative. I’ve long been critical of Penn’s narrow, corporate friendly, and anti-regulatory issues focus and strategy. They often provide cover for regulatory failures and most always bring the safe “good news” that never offends the corporate and political powers that be. They always seem to manage to rely on “expert sources” from the groups and campaigns that they are funding.

In this case, Wm. Penn has pulled off a triple dip:

• Penn created and funds the news outlet that reported the story (Delaware Currents)
• Penn funds the “expert” source quoted by that news outlet (Friends of the Upper Delaware River). In turn, Friends of UD is part of a Penn funded coalition of groups and Penn funds an even larger interlocking set of “partners”. They are an incredibly inbred, transactional, and self serving group.
• Penn funds the secondary news outlet that picked up the story (NJ Spotlight)

The NJ Spotlight story begins on solid ground, with some accurate statements by the FUDR source about trout, the same points I made last month:

“It’s a perfect storm of conditions during a critical time for trout, particularly the brown trout that are spawning in the fall,” said Jeff Skelding, the executive director of Friends of the Upper Delaware River.

But then the story suddenly shifts to the DEP, who make a series of false, misleading and diversionary statements. So let’s drill down on each DEP quote to show how what they said is irresponsible, misleading or distorted – and what they left out is even worse.

[Note: DEP press spokespersons and NJ reporters should read NJ Geological Survey Reports, like this:

• History of Passing Flows In New Jersey, With Contemporary And Future Applications

After the FUDR highlight the negative impacts on trout, the DEP fisheries expert reveals that they don’t give a damn about any trout or wildlife issues up-river in New York:

“If we’re going to have a drought, we’re fortunate that it’s occurring from the fall into the winter,” said Shawn Crouse, chief of the Bureau of Freshwater Fisheries at the New Jersey Department of Environmental Protection’s Fish & Wildlife division.

This DEP statement not only ignores up-river conditions in NY, it frames the issue as summer versus winter conditions, which narrows the focus to the water quality parameters of dissolved oxygen and temperature, conveniently ignoring concentrations of other pollutants that threaten drinking water, aquatic life, fisheries, and ecosystems. For example:

Oftentimes, in periods of low water in winter, chemicals or toxins will move more slowly through the stream system & exist in higher concentrations. This may cause chemical or physical characteristics to be worse during the winter months.

DEP even makes the lack of concern with up-river conditions explicit:

Unlike in the Upper Delaware, trout spawning seasons are less of a concern in the stretch of the Delaware River that passes through New Jersey and Pennsylvania.

“We don’t have year-round trout supporting conditions, so we actually don’t get any spawning,” Crouse said.

Gee, now what are “trout spawning conditions”? NJ waters are too polluted to support trout reproduction!

DEP then goes on to speculate about the “good news” on low drought flows:

Up the food chain, waterfowl may have an easier time finding food.

“If there’s less water, foraging for bald eagles and waterfowl should actually be a little bit easier, since the fish are a little bit more concentrated,” Crouse said.

That’s like the climate denial folks who make sham claims that the increasing CO2 levels driving global warming is actually GOOD, because it increases plant photosynthesis rates and agricultural productivity.

But here’s where DEP goes off the rails with misleading statements about science.

Brook trout, New Jersey’s only native trout species, do spawn in other parts of the state and some tributaries of the Delaware River.

“They are, for the most part, relegated to headwater streams,” Crouse said. “Fortunately, headwater streams have a lot of groundwater or springs feeding them, so they’re generally more consistent during summertime high temperatures or drought situations.”

This is false.

NJ headwater streams tend to run bone dry during the summer, even before actual drought conditions exist. Groundwater levels decline and don’t provide adequate recharge. In rural areas dependent on agricultural irrigation and wells, residential wells go dry (my well well dry in West Amwell). For example, take a look at Delaware tributaries Copper Creek and Alexauken Creek:

The DEP’s comments about the water quality impacts from wildfire again are misleading and a diversion.

In the spring, Justin Rozema, the NJDEP’s assistant fisheries biologist, will take a team to survey an area that may have been affected by wildfires.

“He is planning to do a fishery survey in proximity to one of the wildfires, in an attempt to determine its impact,” Crouse said. “The major threat there would be lost forest canopy, because that would allow additional solar impact on the stream, warming it up.”

First of all, the spring will be far too late to assess the water quality and ecological impacts of wildfire.

[Note: Back in the day (2002), DEP used to monitor water quality in real time during drought to assure no violations of water quality standards, see this NJGS Report:(@ p.34):

The major impacts on water quality are mostly immediate and short term, see: (California DFG)

Immediate Effects of Fire on Aquatic Systems

Forest fire often directly affects water quality in nearby streams and other bodies of water. These direct influences are also considered immediate effects, as they are manifest either during fire or very shortly thereafter. Here we describe the direct effects of forest fire on water temperature and chemistry that have been observed by scientists in the Northern Rockies. We then discuss expected and observed responses of aquatic invertebrates, amphibians, and fish to these fire-caused changes in water quality.

By waiting until spring to sample, DEP will miss most of the impacts. See no evil.

Second, DEP again tried to limit the scope of water quality issues to temperature.

Wildfires have dramatic impacts on water quality, and temperature is just one of many: (USGS)

• Water Quality After Wildfire

Wildfires pose a substantial risk to water supplies because they can lead to severe flooding, erosion, and delivery of sediment, nutrients, and metals to rivers, lakes, and reservoirs. The USGS works with federal and state land managers and local water providers to monitor and assess water quality after wildfires in order to help protect our Nation’s water resources.

After wildfire, loss of canopy vegetation and changes to soil properties can result in more water flowing over the land surface during storms, leading to flooding, erosion, and delivery of sediment, ash, pollutants, and debris to surface water. This can result in decreased water quality, loss of reservoir storage capacity, stream habitat degradation, and increased treatment costs for drinking water providers.

I’ve previously written about how logging in New York’s Catskill’s resulting in “100% trout mortality” in nearby streams due to toxic aluminum concentrations, see USGS:

• Effects of Forest Harvesting on Ecosystem Health in the Headwaters of the New York City Water Supply, Catskill Mountains, New York

“Clearcutting caused a large release of nitrate (NO3 -) from watershed soils and a concurrent release of inorganic monomeric aluminum (Alim), which is toxic to some aquatic biota. The increased soil NO3 – concentrations measured after the harvest could be completely accounted for by the decrease in nitrogen (N) uptake by watershed trees, rather than an increase in N mineralization and nitrification. The large increase in stream water NO3 – and Al concentrations caused 100-percent mortality of caged brook trout (Salvelinus fontinalis) during the first year after the clearcut and adversely affected macroinvertebrate communities for 2 years after the harvest.”

DEP ignored that science and denied my petition for rulemaking to set water quality standards for aluminum

So DEP wants to downplay any issues related to water quality – because if they knew, people might begin asking tough questions about their drinking water and how DEP manages public land and regulates development, water pollution, and drinking water.

We finish up the holiday’s posting of photos tomorrow, with 2 reposts of scenes from our western saga.

The Year In Road Photos: January – June (Part 1 of 2)

Happy New Year

Repost (January 28, 2017)

A Fleeting Moment of Beauty and Truth

[Update below]

During the Women’s March on DC last Saturday, as the protesters converged into an ocean at the corner of 14th and Constitution, I managed to make eye contact with this beautiful woman – her loving gaze penetrated my soul:

Road Trip Photos – Year 1

Moran Point, Grand Canyon

I posted this in August of 2017, after 5 months on the road of what became an awesome 7 year nomadic adventure! Truly “Glory Days”!

I was on the road and off the grid in the forest and deserts of the west, and thus able to avoid the entire Trump first term nightmare, as well as the COVID pandemic.

We won’t be so lucky in 2025, as we’re locked down in Philly and the Fascist consolidation of Trump 2 starts in just 3 weeks.

And I guarantee that the First Day will begin with a tidal wave of Trump Executive Orders and dictates. People are not remotely prepared for the shitstorm Trump will unleash.

Trump will flood the zone with so much sewage that it will overwhelm the capacity of the media and the institutions and people to even understand, never mind effectively oppose: A simultaneous Category 5 Hurricane, tsunami, 1,000 year flood, wildfire, and 9.o Richter scale earthquake. Gory Days! Mark my words.

There’s blood in the streets, it’s up to my ankles
Blood in the streets, it’s up to my knee
Blood in the streets, the town of Chicago
Blood on the rise, it’s following me. ~~~ Peace Frog, The Doors (1970)

“Destruction” – The Course Of Empire, Thomas Cole, 1836)

Now, the original post:

Here’s the verse that many USA! USA! USA! Springstein fans forget:

My old man worked twenty years on the line
And they let him go
Now everywhere he goes out looking for work
They just tell him that he’s too old
I was nine years old and he was working at the
Metuchen Ford plant assembly line
Now he just sits on a stool down at the Legion hall
But I can tell what’s on his mind:

Glory days yeah goin’ back
Glory days aw he ain’t never had
Glory days, glory days  ~~~~ Glory Days (Bruce Springsteen, 1984)

He does the same thing in songs like “Born in the USA” and “My Home Town” – crafting the song in such a way as to allow some listeners to draw the exact opposite meaning of the song. That’s why he’ll never live up to the bold legacy of a Woody Guthrie or Pete Seeger.

[Update: 10/13/17 – Expanding upon exactly the point I was driving at above, the NY Times review of “Springsteen on Broadway” describes various “masks” and “contradictions”, and calls him out for “revisionism”. Springsteen even calls himself a “fraud”. Read the whole thing. ~~~ end update]

There’s mosquitoes on the river
Fish are rising up like birds
It’s been hot for seven weeks now
Too hot to even speak now
Did you hear what I just heard? ~~~ The Music Never Stopped (Grateful Dead, 1975)

Colorado River, at Moab Utah

Left school with a first class pass

Started work but as second class

School taught one and one is two

But right now, that answer just ain’t true. ~~~ Ride My Seasaw (Moody Blues, “In Search of the Lost Chord”, 1968)

Im reluctant to write this, because there were so few tourists and summer homes of the rich and famous (we wouldn’t like it to become like Sun Valley), but the finest clear streams with turquoise pools, prolific wildflowers, and scenic hikes I’ve enjoyed on my trip so far were in Bridger-Teton National Forest in the Star Valley Front. Of those, the most spectacular was Strawberry Creek Trail! (of course, I forgot to bring the camera – but below is a view from my dispersed campsite at the bottom):

The hike up to Trout Lake in the Northern Cascades was a close second –

And here’s a different spectacular Trout Lake, just below Lizard Head Pass & Wilderness, Colorado:

Here’s a highlight from Rocky Mountain National Park:

Lovely spot on the Salmon River in Idaho:

How about the Snake River:

The hike above Cutthroat Lake in the Northern Cascades was brutal – I didn’t make it out and back and turned back as the brutal sun hit the trail at 11 am:

But Blue Lake, in Northern Cascades was very easy walk in:

We camped and had our own beach in this spot on the Skagit River – as all sorts of RV’s sped by at 60 mph, rushing to pay to jam into an RV ghetto in Cascade National Park:

O’ man river,
Dat ol’ man river,
He mus’know sumpin’
But don’t say nuthin’
He jes’ keeps rollin’
He keeps on rollin’ along.  ~~~~ Paul Robeson version, 1936

Glory Days.