BY JEFF TITTEL

COMMENTARY

We all know that Barnegat Bay is in serious trouble and the state needs to act to protect the Bay. Governor Christie has outlined a ten point plan to deal with Barnegat Bay. This proposal is more public relations than public policy. It is more about looking good than actually protecting the Bay. Instead of taking a holistic approach and looking at secondary cumulative impacts the Governor has set out a proposal that has more holes in it than a leaky boat.

The Governor's proposal includes a narrative for nutrients for the Bay instead of a clear standard. This would be like in traffic safety the rule saying you shouldn't speed and not actually having an enforceable speed limit of 55 MPH. The Governor did not commit to having total daily maximum loads (TMDLs) he requires more studies and more processes. The Governor's proposal has just Too Many Damn Loopholes. The proposal does not look at land use and the impacts to the Bay from sprawl and overdevelopment. Therefore this proposal does not look at the Bay holistically or the secondary and cumulative impacts.

We all know why Barnegat Bay is dying. Sprawl, overdevelopment, superheated water from Oyster Creek, and pollution from runoff are just some of the reasons why this important treasure is being destroyed.

Every day, 2.8 percent of the total volume of Barnegat Bay moves through the Oyster Creek Nuclear Generating Station to cool the plant's systems. This artificially heated water kills fish and pollutes the bay. When Governor Christie ran for office he promised that he would protect Barnegat Bay and Oyster Creek even if it means requiring cooling towers, he has done neither.

The deal that was agreed to between Governor Christie and Exelon will allow for the operation of Oyster Creek nuclear power plant for the next ten years without cooling towers. This will mean super heated water will continue to come into the bay, while Exelon will be making more money at the expense of the Bay. This is the same concept that was floated around when Corzine was Governor. The concern than and still is, is that this agreement may not be enforceable. We have to trust Exelon and a different administration ten years from now who can always change their mind, as could Exelon. Exelon has said if they were required to build cooling towers they would have closed the plant a lot earlier.

The plant will still be using Barnegat bay water for cooling until it is decommissioned in 2035. Under the administrative consent order for Oyster Creek the DEP says cooling towers is not the best available technology. We believe this will undermine or prevent cooling towers being built at Salem Nuclear Plant and B.L. England in Cape May.

Fertilizer runoff from lawns is putting nutrients into the bay adding to eutrophication. Governor Christie has said he supports fertilizer legislation, but has not endorsed 20% slow release, which is in the bill that just passed the legislature. We hope he signs the bill and does not take sides with special interest over Barnegat Bay. If he does not sign the bill, Governor Christie is just shoveling more fertilizer into our waterways.

Christie is going to put up 100 million dollars in low cost loans for town to do storm water management. That money has always been available, but towns have decided not to do it. Unless the Governor creates a mechanism to have towns develop storm water systems the money will still sit there and the Bay will continue to get extra storm water and non point pollution.

Barnegat Bay is the Jersey Shore's most heavily used body of water. On summer weekends, as many as 100,000 people a day use the bay for boating. The collapse of the bay would be catastrophic for the viability of not only New Jersey's environment, but also its economy. The bay is a critical part of New Jersey's $4 billion tourism industry and there are about a $100 billion in ratables in and around the bay. If the bay dies, people will loose their investments, impacting jobs. We believe Barnegat Bay is a resource for all the people of New Jersey and must be protected.

Any real plan to save Barnegat Bay has to look at the Bay in its entirety. We need to have a growth management plan and limit impervious cover to protect our aquifers and to prevent runoff. We need to pull back unused water allocation permits so we can try to get more fresh water into the Bay. We need to keep development out of environmentally sensitive areas and clean up existing sources of pollution. We need to develop a comprehensive storm water management plan with the funding to implement it. Cooling towers need to be placed at Oyster Creek nuclear plant or close the plant much sooner to prevent the killing of marine life and affecting the temperature of the Bay.

The Governor's proposal will add more time and delay without actually fixing Barnegat Bay. The special area management plan will be 5 years more of studies and actually be used to weaken environmental protections. Barnegat bay has been studied to death we do not need studies we need actually protecting to be adopted. This is a very weak regulatory proposal with not enough substance to it. What's important to save the bay is to get beyond local and narrow-minded interest. The current system is broken. If we don't change things the bay will die. The legislative package of is a step in the right direction and is even more important now, given the Christie Administration's attacks on the environment. WE all love Barnegat Bay we end up loving it to death unless there is a stronger set of rules and standards coming from the Christie Administration.

Jeff Tittel is the Director of the New Jersey Chapter of the Sierra Club.

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