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

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.

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NJEJA and Partners Oppose Chemical Recycling

On April 18, the New Jersey Environmental Justice Alliance and environmental partners submitted a letter to NJ Assembly Speaker Craig Coughlin highlighting our unified opposition to chemical recycling. We do not support any project that employs chemical recycling or similar processes as it does not constitute genuine recycling and, in fact, leads to increased pollution and safety risks for workers and host communities without offering a real solution to the problem of plastic pollution.

In an effort to demonstrate our solidarity on this issue, inform our elected officials regarding the dangers of this technology, and oppose its development in our state, we submitted this letter on the matter. Read our letter below.

Opposing-Chemical-RecyclingDownload

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

Mercer County EJ Community Engagement Session

Join the NJDEP Office of Environmental Justice for this Environmental Justice Community Engagement Session in Mercer County. Share your concerns with the DEP Commissioner Shawn LaTourette and EP Region 2 Regional Administrator Lisa Garcia. 

Attend in-person or virtually via Zoom. Translation is available in Spanish and Haitian Creole.

Register here.

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

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

Questions for the MACH2 Community Engagement Team

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. We are deeply concerned about the level of community engagement and the claim of community benefits agreements without significant investment, input, and consent from the communities who will host this infrastructure.

It is imperative that organizers for the hub consider the input of host communities, which are primary Environmental Justice communities and frontline communities who are already significant burdened by pollution and negative air quality. We call upon OCED and hub organizers to honor the community’s right to exercise free, prior and informed consent as well as their right to refuse, by providing transparent and robust information.

In an effort to increase transparency and get these questions answered, please see the concerns that NJEJA has raised to the MACH Community Engagement team regarding the logistical development of this process.

MACH2-Community-Engagement-Questions-1Download

Press Release: EJ Community Members Say: EPA Rules Must Incorporate Cumulative Impacts Analysis and Discontinue Reliance on CCS

FOR IMMEDIATE RELEASE: April 26, 2024

Press Contacts

NJ Environmental Justice Alliance: Melissa Miles | melissa@njeja.org 

Center for the Urban Environment of the Watson Institute for Urban Policy & Research: Dr. Nicky Sheats, Esq. | nsheats@kean.edu

Tishman Environment and Design Center: Dr. Ana Isabel Baptista | baptista@newschool.edu  

Ironbound Community Corp.: Maria Lopez-Nunez | mlopeznunez@ironboundcc.org 

 

EJ Community Members Say:

EPA Rules Must Incorporate Cumulative Impacts Analysis and Discontinue Reliance on CCS

 

Washington D.C. – On April 25, the EPA announced a suite of four standards on toxic air pollution, water pollution, land contamination, and GHG (greenhouse gas) emissions from fossil fuel burning power plants. Key among these is the final rule for existing coal-fired and new natural gas-fired power plants. 

 

We recognize the important steps the EPA has taken in removing hydrogen co-firing from consideration as a BSER (Best System of Emissions Reduction) and understand the importance in a delayed ruling on reducing GHG emissions from existing natural gas plants in order to consider the best approach and to address environmental justice concerns. 

In order to best address the risks of climate change and local air pollution as well as protect frontline Environmental Justice communities, the EPA should incorporate a cumulative impacts and MER (mandatory emissions reduction) approach. 

We would also call upon the EPA to continue to strengthen its rules and ensure that future rules do not include hydrogen co-firing or CCS/CCUS as a BSER. We urge the EPA to discontinue its reliance on and promotion of CCS as a technological solution to climate change mitigation. CCS is an unproven and high-risk approach to reducing GHG emissions, and fails to address co-pollutant emissions from power plants in a meaningful and holistic way. 

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“The EPA Power Plant Rule update resulted from decades of organizing and advocacy and years of partnerships between the EPA and Environmental Justice communities. The EPA is modeling some of the best practices around the engagement of impacted communities, and these updated rules are a win for us all. At the same time, we acknowledge the parts of the rules flagged by communities as non-starters, namely the use of carbon capture, utilization and storage in EJ communities. The implicit inclusion of this dangerous technology was a loss for us all. However, we maintain hope that the next update will incorporate cumulative impacts and a mandatory emissions reduction approach to regulating existing power plants.”

Melissa Miles, 

Executive Director, New Jersey Environmental Justice Alliance

 

“I congratulate EPA on the decision to remove hydrogen co-firing from the power plant rule. However, cumulative impacts and mandatory emissions reductions policies should be incorporated into the rule to protect environmental justice communities in general, and especially as a safeguard for the potential harms of carbon capture technology, which unfortunately remains in the rule. These protective policies should also be incorporated into the existing gas plants portion of the rule.”

Dr. Nicky Sheats, Esq., 

Director, Center for the Urban Environment, John S. Watson Institute for Urban Policy and Research at Kean University 

President of the Board and member of the New Jersey Environmental Justice Alliance

 

“We want to urge the USEPA to prioritize the health and well-being of environmental justice communities in the implementation of these rules. We look forward to seeing mandatory emissions reductions and approaches to reducing cumulative impacts embedded in the regulations now being developed for existing natural gas plants.”

Dr. Ana Isabel Baptista, 

Co-Director Tishman Environment & Design Center

NJEJA Board Member 

 

“EPA has to show progress on cumulative impacts and mandatory emissions reductions if we are to believe that this administration is not just all talk regarding the welfare of the most vulnerable communities. These concepts must be embedded into existing and future regulation to safeguard our communities from bad local actors.”

 

Maria Lopez-Nunez,

Deputy Director, Organizing and Advocacy Ironbound Community Corporation

 

For questions regarding this statement, please contact Brooke Helmick, NJEJA Director of Policy at brooke@njeja.org. 

The New Jersey Environmental Justice Alliance is an alliance of New Jersey-based organizations and individuals working together to identify, prevent, and reduce and/or eliminate environmental injustices that exist in communities of color and low-income communities. NJEJA will support community efforts to remediate and rebuild impacted neighborhoods, using the community’s vision of improvement, through education, advocacy, the review and promulgation of public policies, training, and through organizing and technical assistance.

The Center for the Urban Environment (CUE) strives to protect communities Of Color and low-income communities from disproportionately high amounts of pollution by addressing environmental justice (EJ) issues on the local, state and national levels. 

The Tishman Environment and Design Center at The New School is a collaborative community of practice that leverages research, policy, and design in accordance with the Jemez Principles for Democratic Organizing. Our Center brings together research and action to tackle the root causes of climate and environmental injustice and commit to changing higher education practices within and beyond The New School. 

The Ironbound Community Cooperation upholds and builds upon the principles of “Justice and Equality for All.” We strive to practice and build equity, work towards a Just Transition, and organize community on the basis of the Jemez Principles. We envision a safe, healthy, just, and nurturing Ironbound; a welcoming and fully inclusive community that supports equal and accessible opportunity and the quest for a better life. For us, revitalization means uplifting both people and place. Therefore, we aim to lead the transformation of Ironbound into a neighborhood where anyone might choose to live and current residents can remain in their homes and their community without fear of being displaced.

VIEW Press Release PDF

Press Release: Protect EJ Communities While Mitigating Climate Change

NJEJA logo ICC logo

FOR IMMEDIATE RELEASE: March 15, 2024

Press Contacts

NJ Environmental Justice Alliance: Brooke Helmick | brooke@njeja.org

Center for the Urban Environment: Nicky Sheats, PhD, Esq. | nsheats@kean.edu 

Ironbound Community Corp.: Maria Lopez-Nunez | mlopeznunez@ironboundcc.org 

 

Environmental Justice Communities Say: 

Protect EJ Communities While Mitigating Climate Change 

 

Trenton – On March 14, the Senate Energy and Environment Committee both strengthened and voted in favor (3-2) of a Clean Energy Standard (S237/A1480). The EJ community has been actively involved in calling for a nation-leading definition of clean energy and climate change mitigation policy that reduces locally harmful GHG co-pollutants in overburdened Environmental Justice communities, and does not allow for potential loopholes or false solutions. 

 

We celebrate the passage of this strong definition, and the fact that this bill makes New Jersey a leader in ensuring states prioritize the procurement of clean energy. However, we also recognize that this bill has a long way to go before it can be enacted into law. This moment cannot be the end of the conversation, and we will continue to call for new language and provisions that actively protect EJ communities while creating new jobs and a cleaner environment. 

 

We call upon legislators to continue fine-tuning this bill by ensuring that the legislation: 

  • Reduces toxic air pollution in EJ communities by removing “net emissions” calculations;
  • Creates a strong standard for “de minimis” levels of pollution that are as close to zero as possible; and 
  • Prevents polluting facilities such as incinerators from receiving ratepayer subsidies when they violate air permits. 

 

“This moment represents a turning point for the state and the country. Including co-pollutants in the definition makes New Jersey a leader in protecting frontline communities. There is more work to be done to make sure that the bill is as protective of EJ communities as possible, but we take this moment to celebrate and honor the many advocates who have worked tirelessly to protect public health, call for climate change mitigation, and ensure that EJ communities are not left behind in the energy transition.” 

Melissa Miles

Executive Director 

New Jersey Environmental Justice Alliance 

 

“It’s so refreshing to see a holistic and necessary approach to defining clean energy. If we do not include co-pollutants, we stand to repeat the mistakes of the past where we sacrifice local communities for the so-called “greater good.” Today is an important step in leading the country towards a future that deals with both public health and climate change.” 

Maria Lopez-Nuñez

Deputy Director, Organizing and Advocacy

Ironbound Community Corportation

 

“Incorporating GHG co-pollutant reductions into a clean energy standard is the type of action the environmental justice community has been strongly recommending for many years. It will help protect communities near energy infrastructure from locally harmful co-pollutant emissions while at the same time fighting climate change.”

Nicky Sheats, Ph.D., Esq.

Director, Center for the Urban Environment

John S. Watson Institute for Urban Policy and Research at Kean University

Member of the New Jersey Environmental Justice Alliance

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The New Jersey Environmental Justice Alliance is an alliance of New Jersey-based organizations and individuals working together to identify, prevent, and reduce and/or eliminate environmental injustices that exist in communities of color and low-income communities. NJEJA will support community efforts to remediate and rebuild impacted neighborhoods, using the community’s vision of improvement, through education, advocacy, the review and promulgation of public policies, training, and through organizing and technical assistance.

 ICC upholds and builds upon the principles of “Justice and Equality for All.” We strive to practice and build equity, work towards a Just Transition, and organize community on the basis of the Jemez Principles. We envision a safe, healthy, just, and nurturing Ironbound; a welcoming and fully inclusive community that supports equal and accessible opportunity and the quest for a better life. For us, revitalization means uplifting both people and place. Therefore, we aim to lead the transformation of Ironbound into a neighborhood where anyone might choose to live and current residents can remain in their homes and their community without fear of being displaced.

VIEW Press Release PDF