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

Environmental Justice Concerns with Carbon Capture and Hydrogen Co-Firing in the Power Sector

Read the latest report on Environmental Justice Concerns with Carbon Capture and Hydrogen Co-Firing in the Power Sector, prepared in partnership with the New School Tishman Environment and Design Center, Center for the Urban Environment of the John S. Watson Institute for Urban Policy and Research at Kean University, and the Center for Earth, Energy, and Democracy.

CCS & EJ White PaperDownload

For questions, please reach out to Brooke Helmick, Director of Policy at brooke@njeja.org.

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

NJEJA and Partners Submit Comments on EPA’s Power Plant Rule

On May 28, the New Jersey Environmental Justice Alliance and EJ partners submitted crucial comments to the U.S. Environmental Protection Agency (EPA) regarding the second part to their Power Plant Rules. These comments reflect a unified effort from numerous EJ organizations across the country to call on the EPA to substantially address the cumulative impacts of air pollution and the disproportionate burden of both greenhouse gases and greenhouse gas co-pollutants on environmental justice communities. Click here to read our full comments.

Read Our Statement Below, and hear what EJ advocates had to say about the unique opportunity in this comment period:

EJ-Comments-on-EPAs-Existing-Gas-Rule-STATEMENT-May-2024-1Download

NJEJA Toolkit: EPA Power Plant Rule

 

On April 25, the EPA announced a new suite of rules aiming to decreasing pollution in four areas. Key among these was the EPA’s decision not to consider hydrogen co-firing as a solution to mitigating emissions in the power sector. Communities now have an unprecedented and unique moment to continue influencing the EPA rule making process, which will have repercussions for decades to come. 

Recognizing the importance of this moment, NJEJA hosted a webinar on Tuesday, May 14 for community organizations, advocacy groups, and individuals interested in engaging in this comment period.

 

Use this toolkit to learn more about the rule and its relationship to carbon capture and hydrogen, as well as what you can do to take action for your community!

Download Toolkit