Cumulative Impacts and the Permitting Process
Introduction
This memorandum presents ideas regarding cumulative impacts and the permitting process that have been debated and discussed for several years by members of the New Jersey Environmental Justice Alliance, Environmental Justice Advisory Council to the New Jersey Department of Environmental Protection (NJDEP), Ironbound Community Corporation, Environmental Research Foundation, New Jersey Environmental Federation and Center for the Urban Environment. Although these ideas represent a considerable amount of thought they are not intended to be a final solution but a contribution to a discussion that will involve many participants.
The concept of cumulative impacts (CI) should be incorporated into the permitting process in such a way that at least two goals are achieved: 1) Applications for new pollution permits can be denied in environmental justice (EJ) communities, and communities already overburdened with pollution, if granting the permit would increase the amount of pollution in the community; 2) The amount of pollution in a community
would be decreased by a facility’s operations or actions when the facility applied for a permit renewal. To achieve these goals NJDEP will have to identify EJ and overburdened communities and then apply the concept of CI in several specific ways…
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