Comments on BPU Charging Infrastructure Straw

Comments on: In The Matter Of Medium And Heavy Duty Electric Vehicle Charging Ecosystem, New Jersey Electric Vehicles Infrastructure Ecosystem 2021 – Medium And heavy Duty Straw Proposal

One of the most important policy recommendations that has been supported by a significant segment of the environmental justice (EJ) advocacy community is that climate change mitigation policy, in addition to fighting climate change, should be used to reduce the disproportionate amount of pollution often found in EJ communities.

In the power generation sector the EJ advocacy community has indicated this means, at least partly, that electricity generating plants located in EJ residential communities should be required to reduce emissions, no matter what type of climate change mitigation program applies to the plants. This policy would guarantee that climate change mitigation policy would deliver critical reductions in locally harmful greenhouse gas co-pollutants to vulnerable and overburdened EJ communities. These reductions would improve the health of residents living in communities affected by plant emissions. The New Jersey EJ Alliance (NJEJA), has called this policy “mandatory emissions reductions for EJ communities through climate change mitigation policy”.

NJEJA is a statewide organization that focuses solely on EJ issues and advocates for policies that will improve the quality of life of low-income communities and communities Of Color, i.e. EJ communities, in New Jersey and across the nation. It is important to note that NJEJA has strongly advocated for the adoption of the mandatory emissions reductions for EJ communities through climate change mitigation policy and opposed New Jersey’s entrance into the Regional Greenhouse Gas Initiative and Transportation and Climate Initiative, in part because they do not guarantee such reductions. A comparable type of mandatory emissions reductions policy that directly and unequivocally improves the health of EJ communities is needed for the transportation sector. The New Jersey Board of Public Utilities’ (NJBPU) Notice, In The Matter Of Medium And Heavy Duty Electric Vehicle Charging Ecosystem, New Jersey Electric Vehicles Infrastructure Ecosystem 2021 – Medium And heavy Duty Straw Proposal (hereinafter referred to as Straw Proposal), provides New Jersey with an opportunity to discuss and make progress on this type of important policy. NJEJA is submitting the following comments in an effort to further that discussion.

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Achieving Emissions Reductions for Environmental Justice Communities Through Climate Change Mitigation Policy

Nicky Sheats

INTRODUCTION

The Clean Power Plan rule is the U.S. Environmental Protection Agency’s (“EPA”) regulatory method of reducing the nation’s carbon dioxide emissions and, by doing so, of fighting climate change.1 There was very little in the original Clean Power Plan proposal that addressed environmental justice (“EJ”)2 using section 111(d) of the Clean Air Act3 as authorization; it instead featured averaging carbon dioxide emissions rates4 and facilitated emissions trading.5 The EJ advocacy community responded to the Clean Power Plan’s failure to address equity by propos- ing a number of ways that EJ could be incorporated into the proposed rule.6 The three primary recommendations were: 1) mandated emissions reductions for EJ communities, i.e., communities of color and low-income communities; 2) prioritized use of energy efficiency and renewable energy in EJ communities; and 3) mandatory EJ analyses included in state plans developed pursuant to the Clean Power Plan that demonstrated the implementation of the first two recommendations and determined the distributive impacts of a state plan on EJ communities within the state.7 There were other important EJ recommendations such as the recommendation that states should not be able to use carbon trading to fulfill their obligations under the Clean Power Plan.8 However, the above three suggestions were also usually core recommendations.

The final version of the rule does provide what might best be characterized as an EJ “foothold” by requiring that states interact with EJ communities during development of their state plans9 and the inclu- sion of an optional incentive program for the use of energy efficiency in low-income neighborhoods.10 However, the Clean Power Plan still pro- vides no mandatory substantive protections for EJ communities and does not attempt to incentivize emissions reductions for any particular communities, including EJ neighborhoods…

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EJ Bill

Chapter 92

AN ACT concerning the disproportionate environmental and public health impacts of pollution on overburdened communities, and supplementing Title 13 of the Revised Statutes.

BE IT ENACTED by the Senate and General Assembly of the State of New Jersey:

C.13:1D-157 Findings, declarations relative to impact of pollution on overburdened communities.

1. The Legislature finds and declares that all New Jersey residents, regardless of income, race, ethnicity, color, or national origin, have a right to live, work, and recreate in a clean and healthy environment; that, historically, New Jersey’s low-income communities and communities of color have been subject to a disproportionately high number of environmental and public health stressors, including pollution from numerous industrial, commercial, and governmental facilities located in those communities; that, as a result, residents in the State’s overburdened communities have suffered from increased adverse health effects including, but not limited to, asthma, cancer, elevated blood lead levels, cardiovascular disease, and developmental disorders; that children are especially vulnerable to the adverse health effects caused by exposure to pollution, and that such health effects may severely limit a child’s potential for future success; that the adverse effects caused by pollution impede the growth, stability, and long-term well-being of individuals and families living in overburdened communities; that the legacy of siting sources of pollution in overburdened communities continues to pose a threat to the health, well-being, and economic success of the State’s most vulnerable residents; and that it is past time for the State to correct this historical injustice…

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Executive Director’s First Year Community Letter

Dearest Family, Friends and Supporters,​

It has been one year since I assumed leadership of NJ’s premiere statewide organization dedicated to Environmental Justice since its founding 19 years ago. I am truly pleased with the progress we’ve made this year and I’d like to take this opportunity to share a few thoughts.

First, our deep condolences to all of those who have lost loved ones in the past year. The cumulative im- pacts of environmental pollution combined with social determinants of health like race, income and zip code during the worldwide Covid-19 pandemic, made life even more tenuous in EJ Communities.

We simultaneously found our entire EJ movement under threat…

First, our deep condolences to all of those who have lost loved ones in the past year. The cumulative im- pacts of environmental pollution combined with social determinants of health like race, income and zip code during the worldwide Covid-19 pandemic, made life even more tenuous in EJ Communities.

We simultaneously found our entire EJ movement under threat…

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Unequal Access to Local News Undermines Democracy

Truthout, Sept. 1, 2015

By Peter Montague

A new report on community access to local news in New Jersey has revealed one more way democracy is being undermined by economic inequality: Judging by access to critical local news and information, poor communities are “dramatically under-served” compared to wealthier ones, the report concludes.

The Federal Communications Commission (FCC) has described “critical information” that community residents must have for democracy to work – and this study reveals how low income communities and communities of color are being shut out.

The new report, from Rutgers University, compares access to local news and information in three cities in New Jersey:

Newark: Population 281,000; 26 percent white; median household income, $34,000 per year;

New Brunswick: Population 57,000; 45 percent white; median household income, $40,000; and

Morristown: Population 19,000; 62 percent white; median household income, $71,000.

Among these typical New Jersey cities, economic disparity correlates with an astonishing gap in access to essential news and information.

For example, relatively wealthy Morristown supports six journalism sources per 10,000 residents; New Brunswick has 3.5 and Newark has 0.6. In other words, the wealthiest (and smallest) of the three cities supports 10 times as many sources of news and information (per 10,000 residents) as the poorest of the three.

Not surprisingly, this disparity in number of news sources translates directly into disparities in journalistic “output” (total combined stories on the web, plus postings on Twitter and Facebook).

During the seven days that the Rutgers group analyzed, news sources in Morristown produced 541 stories per 10,000 residents, compared to 181 in New Brunswick, and only 26 in Newark. Of these, in Morristown, 461 stories were deemed “original” (not rehashed from other sources), compared to 145 in New Brunswick and only 20 in Newark.

The situation looks even worse when examining journalism that focused on local issues. In Morristown, 42 percent of stories had a local focus; in New Brunswick, 28 percent, and in Newark, only 15 percent.

Members of the New Measures Research Project at Rutgers used “content analysis” to examine the routine output (plus social media posts) of standard news outlets – radio, TV, online and print – in the three cities. All together, they analyzed 2,679 stories (1,028 on the web and 1,651 on social media) during seven non-consecutive days selected at random during the month of January, 2015.

As we have seen, the Rutgers group analyzed the defining aspects of the “local journalism ecosystem” in each city: (1) how many local news sources exist; (2) the quantity of journalistic output by these sources, plus the extent to which their output is (a) original and (b) about local issues.

Importantly, the Rutgers group also analyzed the quality of local journalism, to judge how well local sources are meeting the “critical information needs” of residents.

“Critical information needs” comprise the information that is essential for citizens of a functioning democracy, as defined by the Federal Communications Commission. For details, see Table 1.

These “critical needs” include news and information about:

(1) policing, public safety and public health hazards;

(2) local conditions of health and health care (comparing different neighborhoods);

(3) quality of education and educational opportunities (again, comparing city districts);

(4) local transportation systems – who is served and how well;

(5) environmental conditions (air and water) plus land-use and planning issues (in various parts of the city, compared);

(6) economic development, employment data, employment and training opportunities;

(7) civic information: local service organizations and their services; and

(8) political life – who’s who, what’s what and opportunities for residents to find out what’s going on and participate.

From the viewpoint of generally meeting a community’s critical information needs, in Morristown, 329 stories per 10,000 residents (61 percent of all stories) measured up; in New Brunswick, it was 104 stories (58 percent of total); and in Newark, 10 stories (38 percent of total).

Analyzing for stories that met critical information needs about local conditions, Morristown had 187 stories (35 percent of total) per 10,000 residents; New Brunswick had 35 stories (19 percent); and Newark had 3 stories (12 percent).

Although this study examined only three cities, it’s hard to avoid the conclusion that, if you are a person of color or of low income in New Jersey, you are likely being deprived of the critical information you need to participate effectively in a democracy. Is New Jersey unique? It seems unlikely, but no one can say for sure. One of the main purposes of the Rutgers report was to develop and describe a standard way of analyzing a “local news ecosystem,” which could then be applied anywhere. Other college journalism departments could take up the challenge and replicate this study in their own locales. Then we could know whether New Jersey’s distorted “news ecosystem” and degraded democracy are typical of communities across the US.

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