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.
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.
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.
TheNew 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 aJust 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.
We are excited to invite you to a Community Listening Session on Waste Issues in Camden! The purpose of these sessions is to listen to what Environmental Justice community members have to say about waste-related injustices and issues they are experiencing in their communities.
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.
There is an unprecedented amount of environmental justice funding allocated for organizations and the window to access these dollars is closing. Recognizing the urgency of the moment, we are excited to partner with the NJ Department of Environmental Protection to host Funding Our Futures: Navigating State and Federal Grants.
UPDATE: Due to weather concerns, we’ve decided to shift #FundingOurFutures seminar to a virtual webinar.
To date, climate change mitigation policy has typically been carbon-centric and focused solely on reducing carbon emissions. We urge the 45(v) tax credit proposed rule to move away from carbon centrism by addressing EJ issues that include limiting the emissions of GHG co-pollutants in general as much as possible.
A carbon centric approach and focus on solely using the lifecycle GHG emissions rate of hydrogen production as the metric to determine whether the hydrogen produced is “clean”, is a significant EJ concern. This approach ignores the emissions of GHG co-pollutants along the life cycle of not just hydrogen production but storage, delivery and end uses (such as the burning of hydrogen-blended natural gas at power plants3). Additionally, when a life cycle GHG emissions rate is the sole metric to determine whether the hydrogen produced is clean, a myriad of environmental and health impacts along the hydrogen production chain remain insufficiently addressed.
On December 21, 2023, the New Jersey Environmental Justice Alliance (NJEJA) marked a significant milestone with the conclusion of its first-ever Offshore Wind Training Program. The program culminated in a heartwarming graduation ceremony held at The Salvation Army, bringing together participants, their families, and distinguished guests to celebrate the accomplishments of the 24 graduates.
The comprehensive training initiative aimed to equip participants with essential skills and knowledge related to offshore wind energy, a cleaner alternative to traditional fossil fuel sources. Throughout the program, participants underwent 150 hours of foundational Offshore Wind Training, hands-on construction training, and received crucial job placement support. Additionally, they obtained Occupational Safety and Health Administration (OSHA) certification, further enhancing their employability in the growing clean energy sector. One unique aspect of the program was the recognition of participants’ commitment, as each graduate received a stipend for their dedication to the training. This not only acknowledged their hard work but also provided tangible support as they transitioned into new career opportunities. In a symbolic gesture, graduates were presented with toolboxes, representing the tools they had acquired during the program and their readiness to contribute to the growing field of offshore wind energy.
The ceremony featured other speakers such as Favio Germán of Attentive Energy, a representative from an offshore wind company, South Ward Councilman Patrick Council, and Catresa McGhee, Deputy Director of the Workforce Development Board.
Melissa Miles, the Executive Director of NJEJA, emphasized the significance of transitioning from polluting fossil fuel energy, especially in communities burdened by the presence of harmful fossil fuel plants. She highlighted the program’s role not only in shifting to a cleaner energy system but also in rectifying historical injustices faced by communities like Newark.
Victor Gavilanes, a proud graduate of the Offshore Wind Training Program, expressed gratitude and advocated for the continuation of such training opportunities in the city. “We need good opportunities to get those good paying jobs so that we can get out of our situations and do better,” Gavilanes stated, underlining the importance of creating avenues for quality employment in disadvantaged communities.
One of the most touching moments came from Murphy Kelly, a program participant, who shared a personal journey of finding purpose and passion through the Offshore Wind Training Program. “Before this program, I was a bit lost, somewhat broken after experiencing the loss of both my parents. I lost a passion for life. By a chance of serendipity, I stumbled upon this program and it reignited my passion for life, learning, and education,” Kelly expressed, reflecting the transformative power of education and opportunity.
The NJEJA’s Offshore Wind Training Program stands as a beacon of hope, demonstrating how education, clean energy jobs, and community collaboration can create positive change. As the graduates embark on new career paths, they carry with them the knowledge and skills to contribute to a greener and more equitable future for New Jersey and beyond.
NJEJA’s Offshore Wind Training Program is a transformative initiative designed to empower individuals from overburdened communities with the essential skills and knowledge needed for a career in the growing field of offshore wind energy. Prospective participants are encouraged to stay informed about upcoming cohorts by signing up for NJEJA’s mailing list.
Nicky Sheats, Ph.D., director of the Center for the Urban Environment at Kean (center) receives his award at a ceremony in Trenton from New Jersey DEP Commissioner Shawn M. LaTourette (left) and David Zimmer, executive director of the New Jersey Infrastructure Bank (right). Photo credit: NJDEP
The Director of the Center for the Urban Environment at Kean University’s John S. Watson Institute, Nicky Sheats, Ph.D., received a 2023 Governor’s Environmental Excellence Award, a premier honor recognizing outstanding environmental work in New Jersey.
Sheats, an attorney, scholar and leader in the environmental justice community, received the award in the category of environmental justice on December 18 in Trenton.
“It is an honor to receive the award, which I feel is really in recognition of what the New Jersey environmental justice community has accomplished together,” Sheats said. “This is important work.”
Sheats was one of 12 environmental leaders receiving awards.
“The achievements of this year’s award winners capture the essence of environmentalism in New Jersey and set a shining example for us all to follow,” said state Department of Environmental Protection Commissioner Shawn LaTourette. “It’s an honor to celebrate their determined efforts to protect the state’s natural resources and help others connect to nature.”
Sheats was recognized for his instrumental role in the development and passage of New Jersey’s landmark environmental justice law, and his work establishing pollution reduction policies.
“His recent efforts seek to integrate environmental justice in climate mitigation policies called Mandatory Emissions Reductions (MER) that target reductions of associated co-pollutants, along with greenhouse gas emissions, and which impact overburdened communities,” DEP said in a statement.
Sheats convened the state’s first MER policy workgroup with the New Jersey Environmental Justice Alliance, and was lead author of a recently published paper exploring the implementation of MER policies in New Jersey, Minnesota and Delaware.
At the Watson Institute for Urban Policy and Research, Sheats provides leadership on environmental justice, and scientific, legal, financial and other issues affecting communities throughout the state and nation.
Kean Senior Vice President for Transformational Learning and External Affairs Joseph Youngblood, Ph.D., said Sheats has been a “visionary” leader for 20 years as director of the Center for the Urban Environment.
“Dr. Sheats was a pioneering researcher and policy expert in the environmental justice movement in America,” Youngblood said. “His work at Kean’s Watson Institute has informed state and federal policies that mitigate the cumulative impacts of environmental hazards and eliminate the disproportionate impact of environmental racism on communities of color. His life’s work and influence will have a lasting impact on society.”
Sheats said key areas being addressed from an environmental justice standpoint are cumulative impact of pollutants on neighborhoods; climate change mitigation policy that ensures communities are benefitted, rather than harmed, as they fight climate change; chemical policy and waste policy.
Sheats said credit also goes to the New Jersey Environmental Justice Alliance, the Tishman Environment and Design Center of the New School, the Ironbound Community Corporation, the South Ward Environmental Alliance and the Center for the Urban Environment.
Motiva, another plant involved with a carbon capture project, lays out new built pipes in Donaldsonville, Louisiana, on June 19, 2023. (Photo: Emily Kask for the Washington Post)
The transition away from fossil fuels is an urgent necessity, but we must ensure that renewable energy development doesn’t leave anyone behind. Environmental justice communities need real change – not a rebrand of the same discriminatory plans that slow the clock on fighting the climate crisis and reinforce the status quo.
There is a heightened focus on justice and equity in the Biden administration—but what does that look like for communities living with the realities of systemic and institutionalized discrimination?
For generations, environmental justice communities have borne the brunt of policies and practices that have relegated our homes, workplaces, recreational spaces, and places of worship to the shadows of fossil fuel and petrochemical infrastructure. As the administration and lawmakers advance opportunities to “decarbonize” the energy sector—the largest source of climate change-causing greenhouse gases in the U.S.—many communities are given little insight into the plans and technologies marketed as the solution. As a result, environmental justice communities—those predominantly composed of people of color and those with low income—have to navigate a maze of new federal investments in obscure policies and plans.
Specifically, carbon capture and sequestration (CCS), utilization (CCUS), hydrogen hubs, and direct air capture projects are being rolled out without transparency and our communities are targeted as development zones. It’s time for real change—not a rebrand of the same discriminatory plans that slow the clock on fighting the climate crisis and reinforce the status quo.
While CCS is being pushed as a way to cut emissions, it’s actually enabling further fossil fuel reliance.
The emergence of carbon management initiatives, including the Environmental Protection Agency’s (EPA) latest carbon rule proposal in tandem with the Department of Energy’s (DOE) regional hydrogen hub plan, are a major part of the problem. These initiatives are based on the promise of siphoning off greenhouse gas emissions from power plants and industrial facilities, but they often rely more on greenwashing and wishful thinking than on real solutions. They divert focus from the critical need to break free from fossil fuels, such as coal and natural gas, that disproportionately burden environmental justice communities.
While CCS is being pushed as a way to cut emissions, it’s actually enabling further fossil fuel reliance. What’s even more infuriating is that these projects are poised to reap the benefits of federal tax credits bolstered by the Inflation Reduction Act of 2022. This is a con job on the American public that will funnel funds into risky projects ultimately helping fossil fuel companies and perpetuating the systems that caused the climate crisis.
Now, CCS, CCUS, and direct air capture, along with certain types of hydrogen hubs using CCS along with natural gas, are planned for locations already overburdened by heavy industry, imposing additional risks such as leaks, pipelines blowing up, and health-harming air pollution like nitrogen oxide emissions. Unfortunately, a staggering 90% of the proposed or existing CCS/CCUS plants are located in or dangerously close to EJ communities. This means that investments in these risky schemes will inflict more damage on those already most vulnerable to pollution and climate change for years to come. Louisiana alone faces over two dozen proposals for CCS, CCUS, and hydrogen projects.
If these energy plans move forward, EJ communities will again be collateral damage.
One of these is a colossal $4.5 billion hydrogen plant and carbon capture complex in Ascension Parish by Air Products. This project includes carbon pipelines, wells, and underground storage that pose a grave threat to Lake Maurepas and contribute to air pollution from the new CCS plant, along with the real possibility of explosions. To make matters worse, project applicants may only carry liability for 10 years instead of the usual 50, leaving one of the poorest states with potential liabilities indefinitely.
Federal agencies promise new “regulatory regimes,” to protect EJ communities, but all we see in response to our concerns is an offering of community benefit agreements and public engagement processes that lack substantial, enforceable protections or the right to say “no.” In the absence of concrete federal protections, speculative industry proposals will capitalize on generous federal incentives like the 45Q and 45V tax credits, which allow upfront benefits without a clear mechanism by which governments will oversee and ensure the permanent storage of CO2. Likewise, the Inflation Reduction Act lengthened application timelines and opened up the criteria for which CCS projects qualify. And when disasters hit, we’ll all pay the price through skyrocketing healthcare and housing costs, along with other rising costs linked to pollution and the climate crisis. This approach not only rewards the industries that drive climate change and pollution in EJ communities, but it also perpetuates the big scam of oil, gas, and petrochemical giants.
It’s time we put an end to this farce.
EJ communities were given promises for real investment and involvement in a just energy transition through the administration’s Justice40 Initiative that would not mirror prejudicial policies of the past. If these energy plans move forward, EJ communities will again be collateral damage. There are sustainable solutions that desperately need our support and funding, including transitioning to truly clean, renewable energy such as wind and solar with an equitable transmission build-out.
We have what we need to do right by EJ communities nationwide, and to stave off the worst of the climate crisis before it’s too late—it’s time to move in the right direction.
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