NJEJA and ICC Provide Comments on BOEM’s EJ Strategic Plan

New Jersey Environmental Justice Alliance and the Ironbound Community Corporation submitted comments to the BOEM (the US Bureau of Ocean Energy Management) regarding their 2024-2028 draft Environmental Justice Strategic Plan. The comments included discussion of important topics related to ocean energy development and community engagement including,

  • Recommendations of practices to increase community participation including language justice, compensation, outreach, and hybrid models of engagement
  • Support for community organizations facilitating partnership and outreach with community members
  • Increase mechanisms for feedback implementation, not just solicitation
  • Metrics for monitoring progress towards advancing environmental justice

Read our full comments below:

BOEM EJSPDownload

DEP Must Reject the PVSC Proposal for Another Power Plant in Newark

On October 29, NJEJA submitted comments to the NJ Department of Environmental Protection in the public comment period regarding PVSC’s permit proposal for the construction of another power plant in the Ironbound Community of Newark, NJ. For years, community members and advocacy groups have been clear: we cannot afford to have another power plant in Newark. Another plant would risk exacerbating already disproportionate levels of air pollution, contribute to cumulative impacts, and continue to bring negative health outcomes to residents in the surrounding area.

As was said in our letter to the board of commissions, “High rates of asthma, cancers, cardiovascular diseases, and reproductive issues already plague the Ironbound community. Moving forward with this project would be a direct and disrespectful disregard for the health of the people who live, play, and work in this community. It would continue the harms of environmental racism and exacerbate the climate crisis.”

Read our full comments below:

RE_ PVSC_Response to Comment_NJEJADownload

NJEJA Joins Partners in Tackling Plastic Pollution

On October 8, NJEJA joined partners in a webinar focusing on plastic pollution in New Jersey. Topics included upcoming bills including “Skip the Stuff”, a Bottle Bill, and an “Extended Producer Responsibility” bill. Watch the webinar below and take action by sending a letter to your state legislator in support of these important pieces of legislation. 

NJEJA Submits Comments on the 45Y/48E Tax Credits

On August 2, 2024, the New Jersey Environmental Justice Alliance, along with co-signed allies, submitted comments to U.S. Department of the Treasury and the Internal Revenue Service regarding the proposed regulations for the 45Y/48E Clean Energy Tax Credits.

This federal funding will be an integral component in the Just Transition and funding clean energy in the United States. However, as these credits are designed to be technology-neutral (i.e. no one particular type of energy production is to be favored), there is a risk that these credits may be granted to facilities which do not truly produce clean energy and pose a risk to the surrounding communities.

We submit these comments to: (1) urge the Dept. of the Treasury and the IRS to center environmental justice, (2) incorporate GHG co-pollutants into the emissions calculations, (3) expand the emissions calculations, (4) include a geographical analysis in the alternative fates analysis, (5) exclude polluting combustion and gasification facilities from the list of qualified facilities as they cannot demonstrate a zero emissions mode of production, and (6) address EJ concerns with carbon captures. All of these changes can bring significant protections to environmental justice communities and greatly reduce the risk of harm.

For questions regarding NJEJA’s position and related policy concern, please contact Brooke Helmick, Director of Policy at brooke@njeja.org.

Read our full comments below:

NJEJA-Re-REG-119283-23_Section45Y-48EDownload

NJEJA Submits Comments to the Department of Energy on the Environmental Justice Strategic Plan

On July 12, 2024, the New Jersey Environmental Justice Alliance submitted comments to U.S. Department of Energy on their draft Environmental Justice Strategic Plan to vocalize the environmental justice perspective and offer a new angle for the DOE to review, develop, and carry-out their strategic plan for community engagement and energy planning.

These comments highlighted our view of environmental justice and laid out grounding principles for this definition, as well as drawing a connection between environmental justice and the necessity of robust community engagement. We close our comments with a case study applying these principles: the MACH-2 project and hydrogen hubs.

As we write in our comments, “we continue to offer support in building a more resilient, renewable energy infrastructure and energy economy, both in New Jersey and across the United States.”

For questions regarding NJEJA’s position and related policy concern, please contact Brooke Helmick, Director of Policy at brooke@njeja.org.

Read our full comments below:

NJEJA_DOE EJ Strategic Plan RFIDownload

NJEJA, ICC, and SWEA Submit Comments to the U.S. Coast Guard Opposing the N.J. Turnpike

On July 12, 2024, New Jersey environmental justice organizations, the New Jersey Environmental Justice Alliance, Ironbound Community Corportation, and Southward Environmental Alliance, submitted joint comments to the U.S. Coast Guard in order to continue vocalizing opposition to the proposed New Jersey Turnpike expansion project.

These comments highlight grave concerns regarding negative environmental and climate impacts, subsequent health impacts, and disproportionate burdens to environmental justice communities. Our concerns are grounded in a desire to protect our communities from adverse health impacts as a result of toxic air pollution, increased emissions of greenhouse gases and co-pollutants, and the cumulative impacts of living in environmental justice communities which host multiple polluting projects.

We stand firm in the knowledge that there are better alternatives than expanding the turnpike and that any project must acknowledge, center, and meaningful address the risks to environmental justice communities before being allowed to move forward. Furthermore, there must be intentional and substantive community engagement processes in order to be considered.

For questions regarding NJEJA’s position and related policy concern, please contact Brooke Helmick, Director of Policy at brooke@njeja.org.

Read our full comments below:

EJ-Opposes-the-Turnpike-ExpansionDownload

Comments to the White House Environmental Justice Advisory Council on Carbon Management

On June 19, the New jersey Environmental Justice Alliance submitted comments to the White House Environmental Justice Advisory Council (WHEJAC) regarding carbon management. NJEJA highlighted the risks of CCS and hydrogen co-firing, the necessity of directing federal funding towards communities and sustainable, renewable technologies, and recommending increased oversight, transparency, and accountability in DOE project development. Click here to read more about the WHEJAC.

Read our full comments below:

WHEJAC-Comments-NJEJA-June-2024Download

NJEJA and ICC Submit Comments on the Energy Master Plan

On June 12, the New Jersey Environmental Justice Alliance and the Ironbound Community Corporation submitted public comment to the Board of Public Utilities regarding the 2024 Energy Master Plan. These comments reflect a joint effort to decrease emissions in the state of New Jersey and facilitate to swift transition to affordable truly-clean energy for everyone, particularly low- and moderate-income and EJ communities. Click here read other public comments and view the BPU’s docket.

Read our full comments below:

NJEJA-ICC_EMP-CommentsDownload

Comments to the U.S. EPA regarding the Power Plant Rules

On May 28, the New Jersey Environmental Justice Alliance and EJ partners across the country submitted comments to the EPA regarding the Power Plant Rules for Existing Natural Gas Plants. The comments reflected a unified effort from EJ organizations to call upon the EPA to address the cumulative impacts of pollution and the disproportionate burden of greenhouse gases and greenhouse gas co-pollutants in EJ communities.

In all, the comments addressed four key areas:

  1. Recognizing that retrofitting for carbon capture and hydrogen co-firing must not qualify as a “BSER” (Best System of Emission Reduction) ;
  2. Locating other operational mechanisms to increase efficiency, such as heat rate improvements;
  3. Ensuring that the EPA provide effective oversight to state implementation of these rules;
  4. Demonstrating that facilities sited in EJ communities will not cause or contribute to adverse cumulative impacts as a result of their compliance with the rules;
  5. Incorporating a cumulative impacts framework into the rule.

For all questions and concerns regarding these comments, please contact Brooke Helmick, Director of Policy at brooke@njeja.org.

EPA-HQ-OAR-2024-0135-0080_attachment_1Download

Questions at the MACH2 April 10 Listening Session

The New Jersey Environmental Justice Alliance has raised significant questions to the MACH2 engagement team both via email and at the April 10 MACH2 Listening Session. During the April 10 Listening Session, our team sent in questions via chat. Due to the number of participants, only one person from NJEJA was put onto the speaking list which was created and shared by OCED prior to the event.

We raise these questions out of deep concern and love for our community. The life cycle of hydrogen production is not only costly and economically inviable, but has not been proven safe for our communities. In fact, in many instances, demonstration tests for hydrogen projects have proved to be dangerous, unsustainable, and not effective projects. Furthermore, regardless of whether or not the hydrogen produced is “green” (I.e. hydrogen theoretically created from entirely renewable technology), it poses the same risks during transportation, storage, and end use as hydrogen created from fossil fuels.

In an effort to increase transparency and get these questions answered, please see the concerns that NJEJA has raised to the MACH2 team regarding the structure, function, intention, and infrastructural development of the MACH2 project.

MACH2-April-10-Listening-Session-QuestionsDownload