Draft Global Warming Response Act Recommendations Report

Jan. 23, 2009

 

The Association of New Jersey Environmental Commissions (ANJEC) is pleased to submit the following comments on the Draft Global Warming Response Act Recommendations Report. ANJEC commends the Department for producing the Report with a series of specific near term recommendations and for holding a series of informational meetings to solicit public comment.

 

As you have stated in the Report, “…aggressive and immediate action is needed to stabilize, and then reduce, atmospheric GHG concentrations in order to avoid the most serious climate change impacts.” We join with other stakeholders in expressing a great sense of urgency about moving this agenda forward in the most vigorous and coordinated way possible.

 

The Association submits these comments in the spirit of constructive criticism and is in general highly supportive of New Jersey’s efforts to address global warming, climate change and energy consumption.

 

Prioritize Actions

While the 2020 Supporting Recommendations listed in the Report are all good ideas, a cohesive plan calls for more than a laundry list of actions. What is missing in the Report—and so essential in this tight fiscal environment—is the establishment of clear priorities based on:

  • Greatest return on investment
  • Ease and speed of implementation
  • Strategic importance to long-term goals.

 

Need to Define “Response Principles”

Reducing greenhouse gas emissions will require a paradigm shift and will prove to be a highly interconnected process.  It is important to all those involved to have as a guide for action the basic principles for decision making.  The Department should define the principles of response in the Report.

 

Need for a “Continuing Planning Process” Section

It is clear, however, that meeting the goals--as ambitious as proposed--over a protracted time period will require the development of a continuing planning process -that is periodically revisited to adjust approaches, goals and objectives.  Maintaining institutional continuity through at least 2050 is a daunting task.  Creating and maintaining broad-based public support for greenhouse gas reduction will also be necessary to both drive and support the various, perhaps currently unknowable, regulatory and legislative responses that will be needed.  The Report should include a section on the continuing planning process and make specific recommendations for public education, monitoring and reporting and making of revisions.     

 

Need for an Energizing Vision Statement

The Department should seriously consider the creation of a vision statement that would allow individuals, businesses, and all levels of government to develop a level of comfort and confidence in participating in the process over time.  All of New Jersey’s residents must realize that their actions matter and that there is a rational reason for acting sooner rather than later.

 

Need for a “Clearing House” for Research Dissemination

At numerous points the report calls for additional research.  There is, however, no centralized repository or distribution system to place these research products in the hands of practitioners.  ANJEC strongly recommends that the Department establish a web-based clearing house for research information developed as part of the greenhouse gas response in New Jersey and elsewhere.

 

Land Use

We echo the voices of other NJ stakeholders in calling for:

  • Integration of GHG reduction goals into the State Plan;
  • Ensuring inter-agency accountability for meeting these and other statewide planning goals by elevating the Office of Smart Growth to a cabinet level position with direct oversight by the Governor.

 

Green Building

Because the greenest building is the one already standing, the Report should include incentives for adaptive reuse and rehabilitation of existing buildings as well as deconstruction and recycling of building materials, particularly for redevelopment.

 

As we establish incentives for green residential buildings, greater consideration should go to multi-unit dwellings and residences with a smaller footprint per occupant, so that we are not simply fostering construction of greener McMansions.

 

Transportation

We strongly support the policy described in Appendix 5 calling for the development of methods to analyze the carbon footprint impacts of all transportation capital programs, and we would like to be sure than any proposed construction or widening of highways, including those “in the pipeline” now, such as the Garden State Parkway and NJ Turnpike, also be examined through this lens.

 

VMT Reduction

We support the proposed 1 percent limit on growth in VMT between now and 2020. Recognizing, however, that automobile transportation still requires carbon-intensive activities such as road repair, tire manufacturing, and parking lot construction, it is also essential that we take cars off the road.

 

In addition to the Green Commuting options outlined in the 2020 Transportation Supporting Recommendations, we should also explore:

  • Community or corporate-sponsored jitneys to transport people to trains and buses, removing the need for bigger parking lots at train stations and reducing the VMTs and idling involved with delivering and picking up transit riders;
  • Incentives and resources to help companies embrace more use of home-based workers;
  • No-car zones in urban centers, similar to the August 2008 Summer Streets program in NYC;
  • Community car sharing programs like ZipCar or FlexCar that make it easy for people in developed communities to eschew car ownership;
  • Bike sharing programs like the one in Washington, DC, that make it easy for people to bike instead of drive, even if they don’t own or want to buy a bicycle;
  • Encouraging flexibility in policies that currently provide school bus transportation only to students traveling more than two miles to school;
  • Freezing transit fare increases by diverting funds that would have been spent on new highway construction and road widening.

 

Vehicle Emissions Reduction

Given that transition to zero-emission vehicles could take 20 years or more and depressed car sales could delay the rollout of more hybrids and other “green” cars, other measures will be needed to achieve the Report’s goal of ensuring completely green VMT within the next 15 years. We therefore suggest consideration of the following:

  • Idling – Strengthen the commitment stated in the Report’s 2020 Supporting Recommendations for reduction of truck idling by adding specific numerical goals. Also look beyond trucks by enforcing anti-idling laws for all vehicles, and provide public education about idling;
  • In addition to the aggressive eco-driving campaign described in the Supporting Recommendations, New Jersey should consider reducing the maximum speed limit back to 55 mph in areas where it is now 65 mph to improve fuel efficiency;
  • Congestion – We agree that reducing congestion is a good idea, but want to be sure the potential carbon reduction resulting from HOT lanes and expanded emergency service patrols is cost-competitive with other carbon cutting investments;
  • Investigate alternative fuel retrofits (such as CNG) for existing vehicles for the interim 10 years before the new generation of electric vehicles achieves market penetration;
  • Investigate “cash-for-clunkers” programs for larger or older vehicles.

 

Carbon Sequestration

The Department is to be complemented on including carbon sequestration in the document as part of the overall response.  We would note, however, that the current Garden State Preservation Trust, the primary financial vehicle for open space (forest, wetlands tidal marshes and farmland) preservation is exhausted.  The GSPT must either be refunded or an “outside the box” solution be provided to allow the continuation of open space preservation programs in New Jersey.  Use of carbon credits for forest preservation is one such out-of-the-box solution.  Recognizing that most of New Jersey’s forests are privately owned, often in small parcels, the approaches used in other situations may not be particularly productive.

 

Of particular interest is the use of agricultural soils to sequester carbon.  ANJEC supports the concept but urges the Department to stress the continual improvement of soil health to maximize carbon retention.  The report should advocate organic farming approaches that have been shown to not only store carbon but also improve productivity and resistance to weather extremes and soil erosion.  A soil-based carbon sequestration strategy could provide the State with multiple benefits, including water quality enhancement and agricultural viability in a changing climate.  An excellent guide to sustainable soil management is available at www.attra.org . One very interesting study in this area provides an analysis of these issues: “The Potential of U.S. Agriculture and Forestry to Mitigate Greenhouse Gas Emissions: An Agricultural Sector Analysis,” Schneider and McCarl, Working Paper 02-WP 300, May 2002, Center for Agricultural and Rural Development, Iowa State University, Ames Iowa (www.card.iastate.edu).

 

Afforestation and Reforestation

ANJEC strongly supports strategies for carbon sequestration linked to afforestation and reforestation.  We would note, however, that the likely success for such efforts in many areas is limited by deer browse unless fencing or tree protection is applied.  The plan should recognize the linkage between deer populations and forest health and make specific recommendations for herd reduction wherever warranted.  Additionally, afforestation should be pursued where reestablishment of large forest blocks is facilitated, in denuded riparian areas, and on easily eroded soils that were historically forested. 

 

GIS-Based Deed Restriction Registry

ANJEC strongly supports the development of such a system to assist in tracking carbon sequestration capacity.  Additionally, such a system is justifiable for a variety of reasons relating to the long term stewardship of conservation easements.  In recent years, the land preservation community has become aware of the need for an organized data recording and retrieval system to assist in conservation easement stewardship

 

Greenhouse Siting 

 ANJEC believes that preserved farmland should, at a minimum, preserve agricultural soil capability and, in this case, the potential for soil sequestration of carbon.  This would argue against the installation of permanent greenhouses, soil compaction or site grading to establish either permanent or temporary greenhouses on preserved farmland.  Additionally, viewing greenhouses as a strictly rural issue ignores the fact that there may be opportunities in urban or industrial areas to power greenhouses with unused (waste) heat resources.  The Report should recognize that urban greenhouses may be supported by such sources and could contribute, if properly located, to the provision of locally available food.

 

 

Adaptation Strategies

The Department is to be complemented for including a section on adaptation strategies and recognizing that adverse climate-related impacts are inevitable.  ANJEC strongly recommends that this section be greatly expanded to more guidance for the preparation of the “comprehensive adaptation policy” recommended on p. 76.  For example, sea level rise will not only impact civil works and development but may increase saltwater intrusion into aquifers and render certain surface water intakes marginal or no longer viable.  At least posing appropriate questions to be addressed would seem advisable at this time.