• October 19, 2018

    COMMENTS: IN THE MATTER OF THE IMPLEMENTATION OF L. 2018, c. 16 REGARDING THE ESTABLISHMENT OF A ZERO EMISSION CERTIFICATE PROGRAM FOR ELIGIBLE NUCLEAR POWER PLANTS

    On behalf of the Chemistry Council of New Jersey, which represents the business of chemistry in the state, we remain concerned with the potential subsidy for nuclear generation. As I testified during the extensive legislative process, this subsidy will drastically increase the electricity cost to manufactures in NJ, an industry that state has been trying to bolster. The potential cost of this program will increase electricity bills for companies who already pay an average of 45% more than there competition from around the country. To put it in a dollar and cents perspective, this subsidy could cost some smaller manufactures in NJ nearly $100,000 in additional energy cost, while larger manufactures could pay upwards of $1 million annually.


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  • October 11, 2018

    COMMENTS: REGARDING NEW JERSEY 2019 ENERGY MASTER PLAN – REDUCING ENERGY CONSUMPTION

    Energy is a vital component of the industry’s cost structure and higher energy prices can have a substantial impact on our members and the consumers of their products.  As such, we support goals to drive down the cost of energy for all customers, to promote a diverse portfolio of new, clean, in-state generation and to reward energy efficiency and energy conservation and reduce peak demand.  The Council believes that these goals are in the best interests of all energy consumers, as their implementation will lead to significant improvement in energy utilization throughout the state, ensure that the environment remains protected, and foster innovation and economic growth.


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  • September 11, 2018

    ISSUE PAPER: ENERGY IN PERSPECTIVE

    In a Chemistry Council of New Jersey (CCNJ) membership survey conducted during the months of June and July of 2018, respondents for the eleventh consecutive year unanimously ranked energy costs as one of the top issues of concern facing their companies in New Jersey.  One can understand why, since New Jersey’s industrial energy rates are among the highest in the nation. For some energy-intensive products, energy for both fuel and power needs and feedstocks account for up to 85% of total production costs. Because energy is a vital component of the industry’s cost structure, higher energy prices can have a substantial impact on jobs and the bottom line.


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  • June 28, 2018

    COMMENTS: POTENTIAL REPORTING CHANGES TO THE TOXIC CATASTROPHE PREVENTION ACT PROGRAM

    On behalf of the members of the Chemistry Council of New Jersey (CCNJ), we would like to share our concerns regarding the attached draft “Annual Report Compliance Audit and Near Miss Handout” dated May 2, 2018, which summarizes potential changes to the Toxic Catastrophe Prevention Act (TCPA) annual report requirements.


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  • June 6, 2018

    COMMENTS: NJPDES FISCAL YEAR 2018 ANNUAL FEE REPORT AND ASSESSMENT OF FEES

    First, we would like to share some history and background on our past efforts in advocating for improvements to the NJPDES fee structure.  Back in 2013 and 2014, CCNJ and its members participated in NJPDES stakeholder meetings with the focus on ensuring that the reduction of permittees and environmental loading was taken into account when calculating the industrial NJPDES fees, which were rising uncontrollably.


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  • March 6, 2018

    COMMENTS: ECOLOGICAL EVALUATION TECHNICAL GUIDANCE DOCUMENT VERSION 1.4

    CCNJ and the Site Remediation Industry Network (SRIN) provided comments on the proposed revisions to the Technical Guidance for Ecological Evaluation (EE) to the New Jersey Department of Environmental Protection (NJDEP) on March 6, 2018.


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  • February 22, 2018

    COMMENTS: IMMEDIATE ENVIRONMENTAL CONCERN TECHNICAL GUIDANCE DOCUMENT VERSION 2.0

    CCNJ and the Site Remediation Industry Network (SRIN) provided comments on the proposed revisions to the Technical Guidance for Immediate Environmental Concern (IEC) to the New Jersey Department of Environmental Protection (NJDEP) on February 22, 2018.


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  • February 5, 2018

    COMMENTS: REQUEST FOR PUBLIC INPUT FOR PERFLUOROOCTANE SULFONATE

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and the Site Remediation Industry Network (SRIN) appreciate the opportunity to provide comments to the Drinking Water Quality Institute (DWQI) pursuant to the Institute’s request for public input regarding the recently released subcommittee reports on Perfluorooctane Sulfonate (PFOS). CCNJ/SRIN have long advocated for greater transparency and public input with respect to DWQI’s activities and we appreciate the steps taken to provide this opportunity.


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  • October 6, 2017

    COMMENTS: NJDEP PROPOSED AMENDMENTS TO AIR QUALITY RULES (DEP DOCKET NO. 12-17-06, PROPOSAL NO. PRN 2017-139)

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP, the Department) on the proposed amendments to Air Quality, Energy, and Sustainability Program rules published in the New Jersey Register on August 7, 2017.


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  • September 29, 2017

    COMMENTS: NJDEP PROPOSED AMENDMENTS TO SITE REMEDIATION AND WASTE MANAGEMENT PROGRAM RULES (DEP DOCKET NO. 10-17-06, PROPOSAL NO. PRN 2017-134)

    COMMENTS ON NJDEP PROPOSED AMENDMENTS TO SITE REMEDIATION AND WASTE MANAGEMENT PROGRAM RULES (DEP DOCKET NO. 10-17-06, PROPOSAL NO. PRN 2017-134)


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  • November 21, 2016

    COMMENTS: REQUEST FOR PUBLIC INPUT FOR PERFLUOROOCTANOIC ACID

    On behalf of our members, the Chemistry Council of New Jersey (CCNJ) and Site Remediation Industry Network (SRIN) appreciates the opportunity to provide comments to the Drinking Water Quality Institute (DWQI) pursuant to the Institute’s request for public input regarding the recently released subcommittee reports on Perfluorooctanoic Acid (PFOA).


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  • November 4, 2016

    COMMENTS: COASTAL ZONE MANAGEMENT RULES, N.J.A.C. 7:7-16.9; PUBLIC ACCESS

    On behalf of the members of the Chemistry Council of New Jersey (CCNJ), we appreciate the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP) on the proposed public access amendments to the Coastal Zone Management Rules (the “Proposal”).<br />  


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  • February 9, 2016

    COMMENTS: “PLANNING FOR AND RESPONSE TO CATASTROPHIC EVENTS AT CONTAMINATED SITES” TECHNICAL GUIDANCE DOCUMENT

    On behalf of the members of the Chemistry Council of New Jersey (CCNJ) and the Site Remediation Industry Network (SRIN), we appreciate the opportunity to provide comments to the New Jersey Department of Environmental Protection (NJDEP) on the “Planning for and Response to Catastrophic Events at Contaminated Sites” (Catastrophic Events) Technical Guidance Document. 


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  • May 1, 2015

    Issue Paper: Energy in Perspective

    In a Chemistry Council of New Jersey (CCNJ) membership survey conducted during the months of June and July of 2014, respondents for the seventh consecutive year unanimously ranked energy costs as one of the top issues of concern facing their companies in New Jersey. One can understand why, since New Jersey’s industrial energy rates are among the highest in the nation. For some energy-intensive products, energy for both fuel and power needs and feedstocks account for up to 85% of total production costs. Because energy is a vital component of the industry’s cost structure, higher energy prices can have a substantial impact on jobs and the bottom line.


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  • March 31, 2014

    OSHA | Docket No. OSHA-2013-0020 Request for Information for Modernization of PSM Standard

    The Chemistry Council of New Jersey (CCNJ) is pleased to respond to the U.S. Department of Labor’s (DOL’s) Occupational Safety and Health Administration (OSHA) notice of Request for Information (RFI), Docket No. OSHA-2013-0020, published in the Federal Register on December 9, 2013 at 78 Federal Register 73756-73768. The CCNJ represents over 70 New Jersey companies involved in the business of chemistry (pharmaceuticals, chemicals, flavors and fragrances, petroleum refining, etc.). The business of chemistry directly employs more than 50,000 persons in New Jersey and is responsible for over $25 billion dollars in revenues in New Jersey each year. CCNJ members place high value and priority on safety and security for their employees, their workplaces, and the communities that host them. The CCNJ member companies are committed to continually improving environmental, health, safety, and security performance through common sense advocacy designed to address major public policy issues, health and environmental research, and product testing.


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