#b#To the Editor: DEP Should Say No To Permit Waivers#/b#

One week before Earth Day, April 22, New Jersey’s environment is being threatened by a new rule proposed by the state Department of Environmental Protection. The “Waiver Rule” would give the DEP the authority to provide anyone applying for an environmental permit a waiver from compliance.

Up for review at a public hearing on Thursday, April 14, this new rule is essentially a get out of jail free card for anyone looking to skirt their environmental responsibilities. Although the Waiver Rule is being proposed under the guise of efficiency and economic growth, it opens up the potential for a tremendous negative impact on our environment.

Our environmental rules are strong and have been adopted in the best interest of the state and its residents. For example, tourism is one of New Jersey’s leading industries. Ensuring clean freshwater streams for fishing, clean beaches for sandcastles, healthy oceans for surfing, and clean soils for blueberries, peaches, cranberries, pumpkin picking, hayrides, and corn mazes is in New Jersey’s best economic interest.

When we start compromising on our environmental rules we will compromise the health of our environment, the health of our residents, and the health of our economy.

The Waiver Rule proposes four easy outs for complying with our strong environmental rules: hardship, “net environmental benefit,” public emergency, and conflict. While these arguments may seem benign they have negative consequences.

Hardship Is No Excuse. If the new rule is adopted, anyone proposing a new development could apply for a waiver from compliance simply by claiming an environmental regulation poses a hardship. The rule provides no criteria for decision-making on what constitutes a hardship, putting our public health and safety, and clean air, water, and soil at risk.

Is Clean Water Better Than Clean Air? Under the new rule, the DEP could also issue a waiver if doing so would result in a “net environmental benefit.” This means an applicant could do environmental harm in the name of some environmental good. It pits environmental objectives against one another — clean soils against clean water, or clean water against clean air. For example, why should the DEP get to choose whether a developer could destroy wetlands that protect against flooding if the developer agrees to clean up site contamination? Flooding and clean water should both be a consideration when cleaning up a contaminated site. New Jersey residents should not have to settle for one or the other.

Emergency Provisions In Place. The new proposed rule also provides waiver provisions for cases of public emergency. However, many of our tough environmental regulations already allow rules to be waived for public emergencies.

‘One-stop-shop’ Already Prevents Conflict. Finally, the proposed rule would allow the DEP to issue waivers to environmental rules in cases in which two or more rules conflict. However, the DEP’s own “one-stop-shop permitting group” of air, water, and soil departments already coordinate with one another and have flexibility within existing environmental rules to ensure that they do not conflict with one another.

The Waiver Rule is an invitation to abuse of power. The DEP should not be allowed to pick and choose who gets to follow the rules and who doesn’t. New Jersey’s strong environmental rules have been adopted to protect the health and welfare of all New Jersey residents.

Those rules rely on science, are open to the public for comment when proposed, and are required by law to be reviewed every five years to ensure that they are fair and efficient and that they protect the environment.

With our industrial history and dense population, New Jersey needs tough environmental rules to make sure we clean up the problems of the past and ensure that we have enough clean water for our families to drink and healthy air to breathe. Don’t let the DEP allow those with the right political influence to skirt their environmental responsibilities.

Please join us in telling the DEP to stand up for the environment and strike down the Waiver Rule at a public hearing on Thursday, April 14 at 3 p.m. at the DEP’s first floor hearing room at 401 East State Street, in Trenton.

Jennifer Coffey

Coffey is the policy director of the Stony-Brook Miullstone Watershed Association (www.thewatershed.org).

#b#More on Geriatrics#/b#

To fully “rethink geriatrics,” as Dr. David R. Barile advised in his March 30 letter to the editor, there is more to ponder beyond his call to improve communication between patients and providers. Geriatrics can also benefit from important financial reforms, as well as further research on the comparative effectiveness of therapies.

Barile argued that the relatively high volume and intensity of hospital services consumed by seniors in New Jersey did not necessarily make those seniors healthier or more satisfied than others from different states. In this situation, Barile saw a problem of insufficient alignment between the provider’s therapies and the patient’s goals. However, such an alignment rests upon the availability of studies comparing feasible therapies for the patient.

Between large groups of subjects randomized to receive either a placebo or one of various therapies for the same health condition as the patient, what was the rate of negative outcomes in each group? How large was the average gain in benefits?

Unfortunately, the answers to these questions are often missing or unreliable because high quality studies on comparative effectiveness are inherently labor-intensive and usually expensive. But without reliable answers, aligning treatments to goals becomes more conjecture than science. To support the work of Barile and his New Jersey Goals of Care program, both patients and providers should also support the continuation of national public funding for comparative effectiveness research.

Furthermore, it is worth exploring ways to reform the fee-for-service model of care. In the current system, even if patients are able to make a well-informed choice to receive fewer or less-intense therapies, can clinics survive without raising prices?

Aligning the financial interests of the provider with those of the patient will help pave the way towards aligning therapies with goals of care.

Barile discussed the Dartmouth Atlas, which is guiding the development of alternatives to the fee-for-service model — such as the accountable care organization. When improvements in communication are joined by innovations in finance and research, geriatrics can be profoundly transformed.

Nora Wong MPH

Wong, a graduate of West Windsor-Plainsboro High School South, studied public health at the Dartmouth Institute for Health Policy and Clinical Practice in Lebanon, NH, and is now preparing to enter law school.

#b#Correction:#/b# An item in the Management Moves section of the April 6 edition incorrectly stated that Jeff Plamondon, the former general manager of the Princeton Marriott Hotel, now runs his own business. Plamondon actually is the general manager of the Renaissance Newark Airport Hotel.

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