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	<title>Comments for Green Pages NJ</title>
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	<link>http://www.pisaurolaw.com/greenpagesnj</link>
	<description>Issues Important to New Jersey&#039;s Environment</description>
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		<title>Comment on More promises on NJ&#039;s open space by NJ's Open Space in Jeopardy &#124; Green Pages - NJ</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/clean-air/more-promises-on-njs-open-space/#comment-24</link>
		<dc:creator>NJ's Open Space in Jeopardy &#124; Green Pages - NJ</dc:creator>
		<pubDate>Sat, 31 Oct 2009 18:08:11 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=124#comment-24</guid>
		<description>[...] I have a guest post on the Green Jersey blog on why we all should vote yes.  I have also written about the importance of open space on this blog  [...]</description>
		<content:encoded><![CDATA[<p>[...] I have a guest post on the Green Jersey blog on why we all should vote yes.  I have also written about the importance of open space on this blog  [...]</p>
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		<title>Comment on NJ is #2 in solar and seeking to increase by NJ Governor Canditates promote renewable energy, NJ needs more than rhetoric &#124; Green Pages - NJ</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/renewable-energy/nj-is-2-in-solar-and-seeking-to-increase/#comment-20</link>
		<dc:creator>NJ Governor Canditates promote renewable energy, NJ needs more than rhetoric &#124; Green Pages - NJ</dc:creator>
		<pubDate>Sat, 18 Jul 2009 14:05:35 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=106#comment-20</guid>
		<description>[...] Recently the Republican and the Democratic candidates for NJ governor addressed renewable energy. NJ needs renewable energy. The Country and the World needs the switch to renewable energy. Christie’s website indicates we have one of the strongest renewable energy portfolio standard (RPS), but rank 48th in the country for renewable energy generation. Why? Well according to the EIA a vast majority of the renewable energy capacity and generation in the country is hydro power. NJ does not have a lot of hydro possibilities. So, if you take out hydro from the calculations, I am not so sure that NJ is doing so badly. For example, NJ is second only to California in solar generation. Granted NJ is a long way down from California but it is still ahead of 48 other states. Take a look at NJ is #2 in Solar and seeking to increase. [...]</description>
		<content:encoded><![CDATA[<p>[...] Recently the Republican and the Democratic candidates for NJ governor addressed renewable energy. NJ needs renewable energy. The Country and the World needs the switch to renewable energy. Christie’s website indicates we have one of the strongest renewable energy portfolio standard (RPS), but rank 48th in the country for renewable energy generation. Why? Well according to the EIA a vast majority of the renewable energy capacity and generation in the country is hydro power. NJ does not have a lot of hydro possibilities. So, if you take out hydro from the calculations, I am not so sure that NJ is doing so badly. For example, NJ is second only to California in solar generation. Granted NJ is a long way down from California but it is still ahead of 48 other states. Take a look at NJ is #2 in Solar and seeking to increase. [...]</p>
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		<title>Comment on FERC and MMS begin to play nice. by Grays Harbor's application is dismissed &#124; Green Pages - NJ</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/federal/ferc-and-mms-begin-to-play-nice/#comment-26</link>
		<dc:creator>Grays Harbor's application is dismissed &#124; Green Pages - NJ</dc:creator>
		<pubDate>Thu, 14 May 2009 02:40:28 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=165#comment-26</guid>
		<description>[...] at RenewablesOffshore regarding the memorandum of understanding between FERC and MMS.  As I noted previously these agencies have entered into a memorandum of understanding on the handling of offshore [...]</description>
		<content:encoded><![CDATA[<p>[...] at RenewablesOffshore regarding the memorandum of understanding between FERC and MMS.  As I noted previously these agencies have entered into a memorandum of understanding on the handling of offshore [...]</p>
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		<title>Comment on Perfect Storm for site remediation disaster by Allen Wyman</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/clean-up/perfect-storm-for-site-remediation-disaster/#comment-29</link>
		<dc:creator>Allen Wyman</dc:creator>
		<pubDate>Thu, 16 Apr 2009 13:40:59 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=169#comment-29</guid>
		<description>Hello gentlement.  As some of you already know, I&#039;m a former MassDEP Auditor and know much about the inforamtion presented in the presentation.  I would just advise that you not missinterpret the numbers on that one powerpoint slide without having heard the presenter&#039;s explaination of it or the facts behind the number.  The powerpoint is meant to include a verbal description of the detail behind the number.  Also, there is a significant difference between L1 and L3 Audits.  Please understand that L1 Audits are not comprehensive and are only meant to identify potential issues (and not all associated with lingering risk).  A L3 Audit is required to assess that which was identified as a possible problem in a L1.  As Bill eludes to, the results of the L3 Audits are much different than the interpretation Mike has developed using this number.  I&#039;m not speaking to what NJ does either way and it is not my business to do so.  I&#039;m just pointing out that Mike might want to be careful about his interpretation of that particular data.  There is alot that went into that number that is not associated with actual Risk to Human Health or Environment or even actual L3 confirmation of Risk violations.  Plainly stated, it should not be interpreted to mean that 50% of the closed sites would have failed closure or present lingering risk.  That is in no way accurate or indicative of the data that went into the number.  Mike, additional information can be found here:  http://www.lspa.org/download/whitepapers/Internreport-FINAL052504.pdf.</description>
		<content:encoded><![CDATA[<p>Hello gentlement.  As some of you already know, I&#8217;m a former MassDEP Auditor and know much about the inforamtion presented in the presentation.  I would just advise that you not missinterpret the numbers on that one powerpoint slide without having heard the presenter&#8217;s explaination of it or the facts behind the number.  The powerpoint is meant to include a verbal description of the detail behind the number.  Also, there is a significant difference between L1 and L3 Audits.  Please understand that L1 Audits are not comprehensive and are only meant to identify potential issues (and not all associated with lingering risk).  A L3 Audit is required to assess that which was identified as a possible problem in a L1.  As Bill eludes to, the results of the L3 Audits are much different than the interpretation Mike has developed using this number.  I&#8217;m not speaking to what NJ does either way and it is not my business to do so.  I&#8217;m just pointing out that Mike might want to be careful about his interpretation of that particular data.  There is alot that went into that number that is not associated with actual Risk to Human Health or Environment or even actual L3 confirmation of Risk violations.  Plainly stated, it should not be interpreted to mean that 50% of the closed sites would have failed closure or present lingering risk.  That is in no way accurate or indicative of the data that went into the number.  Mike, additional information can be found here:  <a href="http://www.lspa.org/download/whitepapers/Internreport-FINAL052504.pdf" rel="nofollow">http://www.lspa.org/download/whitepapers/Internreport-FINAL052504.pdf</a>.</p>
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		<title>Comment on Perfect Storm for site remediation disaster by Mike Pisauro</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/clean-up/perfect-storm-for-site-remediation-disaster/#comment-28</link>
		<dc:creator>Mike Pisauro</dc:creator>
		<pubDate>Thu, 16 Apr 2009 01:53:07 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=169#comment-28</guid>
		<description>Thank you for your comments.  Unfortunately, the 50% comes directly from MASS DEP.  A copy of their document can be found at www.epa.gov/superfund/policy/ic/pdfs/potter.pdf at page 28.  I would be interested in your take on the 2007 Level 3 audits.  It looks like almost 75% of the sites under a Level 3 audit failed in 2007.  Does this means the program is working is not working?

Thank you again for you comments and I would enjoy more information the Mass program as NJ is going to go down the similar road.</description>
		<content:encoded><![CDATA[<p>Thank you for your comments.  Unfortunately, the 50% comes directly from MASS DEP.  A copy of their document can be found at <a href="http://www.epa.gov/superfund/policy/ic/pdfs/potter.pdf" rel="nofollow">http://www.epa.gov/superfund/policy/ic/pdfs/potter.pdf</a> at page 28.  I would be interested in your take on the 2007 Level 3 audits.  It looks like almost 75% of the sites under a Level 3 audit failed in 2007.  Does this means the program is working is not working?</p>
<p>Thank you again for you comments and I would enjoy more information the Mass program as NJ is going to go down the similar road.</p>
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		<title>Comment on Perfect Storm for site remediation disaster by Bill Gibbons</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/clean-up/perfect-storm-for-site-remediation-disaster/#comment-27</link>
		<dc:creator>Bill Gibbons</dc:creator>
		<pubDate>Wed, 15 Apr 2009 15:22:12 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=169#comment-27</guid>
		<description>&quot;Remember 50% of the RAO reviewed by Mass DEP required more work or were invalidated.&quot;

That statement is simply not true.  Very very few of the thousands of RAOs that have been submitted have ever been invalidated and of those that the MADEP deemed needed more work, after the work was done &lt; 4% resulted in any change RAO Opinion,  i.e. an RAO is submitted with three rounds of supporting groundwater that the LSP concludes is representative of site conditions.  A DEP staffer thinks another round is necessary for unknown reasons (they don&#039;t need to detail their rationale like a LSP does) and requires another round at the cost of several thousand dollars.  The LSP completes another round of groundwater sampling and anlysis and nothing has changed.</description>
		<content:encoded><![CDATA[<p>&#8220;Remember 50% of the RAO reviewed by Mass DEP required more work or were invalidated.&#8221;</p>
<p>That statement is simply not true.  Very very few of the thousands of RAOs that have been submitted have ever been invalidated and of those that the MADEP deemed needed more work, after the work was done &lt; 4% resulted in any change RAO Opinion,  i.e. an RAO is submitted with three rounds of supporting groundwater that the LSP concludes is representative of site conditions.  A DEP staffer thinks another round is necessary for unknown reasons (they don&#8217;t need to detail their rationale like a LSP does) and requires another round at the cost of several thousand dollars.  The LSP completes another round of groundwater sampling and anlysis and nothing has changed.</p>
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		<title>Comment on NJ legislature about to pass the buck on clean-ups by Both Houses about to pass LSP bills &#124; Green Pages - NJ</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/clean-up/nj-legislature-about-to-pass-the-buck-on-clean-ups/#comment-25</link>
		<dc:creator>Both Houses about to pass LSP bills &#124; Green Pages - NJ</dc:creator>
		<pubDate>Sun, 15 Mar 2009 14:23:45 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=152#comment-25</guid>
		<description>[...] signed as soon as possible.  For more information on the LSP bill you can read my previous posts. (here and here and [...]</description>
		<content:encoded><![CDATA[<p>[...] signed as soon as possible.  For more information on the LSP bill you can read my previous posts. (here and here and [...]</p>
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		<title>Comment on DEP releases proposed site remediation bill by NJ legislature about to pass the buck on clean-ups &#124; Green Pages - NJ</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/clean-up/dep-releases-proposed-site-remediation-bill/#comment-16</link>
		<dc:creator>NJ legislature about to pass the buck on clean-ups &#124; Green Pages - NJ</dc:creator>
		<pubDate>Thu, 26 Feb 2009 04:04:07 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=63#comment-16</guid>
		<description>[...] I wrote in prior posts (here and here) the State is pushing a complete revamp of our site remediation bill.  On February 2nd, I [...]</description>
		<content:encoded><![CDATA[<p>[...] I wrote in prior posts (here and here) the State is pushing a complete revamp of our site remediation bill.  On February 2nd, I [...]</p>
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		<title>Comment on DEP releases proposed site remediation bill by Cleaning Up Clean-ups in NJ &#124; Green Pages - NJ</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/clean-up/dep-releases-proposed-site-remediation-bill/#comment-15</link>
		<dc:creator>Cleaning Up Clean-ups in NJ &#124; Green Pages - NJ</dc:creator>
		<pubDate>Fri, 30 Jan 2009 03:34:23 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=63#comment-15</guid>
		<description>[...] proposed revisions to its site remediation laws.  I have written about the bill proposal before (here).  The administration has continued to push a solution that will not enhance the protections we [...]</description>
		<content:encoded><![CDATA[<p>[...] proposed revisions to its site remediation laws.  I have written about the bill proposal before (here).  The administration has continued to push a solution that will not enhance the protections we [...]</p>
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		<title>Comment on Global Warming Action plan has been released. by GreenPolNJ</title>
		<link>http://www.pisaurolaw.com/greenpagesnj/global-warming/global-warming-action-plan-has-been-released/#comment-21</link>
		<dc:creator>GreenPolNJ</dc:creator>
		<pubDate>Thu, 18 Dec 2008 21:14:03 +0000</pubDate>
		<guid isPermaLink="false">http://fplegal.com/wordpress/?p=111#comment-21</guid>
		<description>The Review meetings Jan 6-16 in Trenton are important. For instance, I&#039;ve called for the creation of a politically-experienced &quot;Implementation Team&quot; to be part of the Global Warming Response Act, because most experts say our execution stinks.  The Act should also direct the State to utilize NJ&#039;s home-grown Global Emissions Exchange to help measure AND GET REVENUE FOR the carbon reduction we&#039;re earning. I&#039;ve blogged both on www.GreenPoliticsNJ.com, for anyone interested in more.</description>
		<content:encoded><![CDATA[<p>The Review meetings Jan 6-16 in Trenton are important. For instance, I&#8217;ve called for the creation of a politically-experienced &#8220;Implementation Team&#8221; to be part of the Global Warming Response Act, because most experts say our execution stinks.  The Act should also direct the State to utilize NJ&#8217;s home-grown Global Emissions Exchange to help measure AND GET REVENUE FOR the carbon reduction we&#8217;re earning. I&#8217;ve blogged both on <a href="http://www.GreenPoliticsNJ.com" rel="nofollow">http://www.GreenPoliticsNJ.com</a>, for anyone interested in more.</p>
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