Position Papers
CCNJ COMMENTS: NJDEP RULE PROPOSAL NO. PRN 2025-028, DEP DOCKET NO. 02-25-02
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 New Jersey Department of Environmental Protection (NJDEP) on NJDEP RULE PROPOSAL NO. PRN 2025-028, DEP DOCKET NO. 02-25-02, which was published in the New Jersey Register (NJR) on March 17, 2025.
CCNJ COMMENTS: NJDEP PROPOSED AMENDMENTS/NEW RULES/REPEALS TO DISCHARGES OF PETROLEUM AND OTHER HAZARDOUS SUBSTANCES RULE – N.J.A.C. 7:1E (DEP DOCKET NO. 03-24-04, PROPOSAL NO. PRN 2024-062)
Based on our detailed comments below, CCNJ/SRIN are respectfully requesting that the Proposed Rule be reconsidered and workgroup meetings with interested parties be scheduled. The last NJDEP stakeholder meeting was held on February 11, 2019 and only discussed Appendix A, de minimis, Subchapter 6, recordkeeping, renewal cycle, and revised language. There was no discussion on some of the key 2024 proposed amendments; workgroup meetings with interested parties need to be held to discuss these changes. The input developed during these meetings will better inform NJDEP’s regulatory proposal and decision-making.
CCNJ COMMENTS: NJDEP PROPOSED AMENDMENTS AND NEW RULE, STORMWATER MANAGEMENT RULES, FLOOD HAZARD AREA CONTROL ACT RULES, N.J.A.C. 7:8, 7:13 (DEP DOCKET NUMBER 08-22-10, PROPOSAL NO. PRN 2022-156)
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) on the proposed amendments and new rule regarding stormwater management and Flood Hazard Area Control Act requirements published in the New Jersey Register on December 5, 2022.
CCNJ COMMENTS: FY2023 ANNUAL FEE REPORT AND ASSESSMENT OF FEES FOR THE NJPDES PERMIT PROGRAM
On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments on the New Jersey Pollutant Discharge Elimination System (NJPDES) Fiscal Year (FY) 2023 Annual Fee Report and Assessment of Fees.
CCNJ COMMENTS: PROPOSED AMENDMENTS TO THE REGULATIONS OF THE NEW JERSEY SITE REMEDIATION PROFESSIONAL LICENSING BOARD, N.J.A.C. 7:26I (DEP DOCKET NUMBER 06-22-09, PROPOSAL NO. PRN 2022-138)
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 New Jersey Site Remediation Professional Licensing Board (SRPLB) on the proposed rule amendments published in the New Jersey Register on November 7, 2022.
CCNJ COMMENTS: NJDEP PROPOSED NEW ENVIRONMENTAL JUSTICE RULES (DEP DOCKET NO. 04-22-04, PROPOSAL NO. PRN 2022-082)
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 New Jersey Department of Environmental Protection (NJDEP, Department) on the Proposed New Environmental Justice (EJ) Rules published in the New Jersey Register on June 6, 2022 (Proposed Rules).
CCNJ COMMENTS: NJDEP PROPOSED AMENDMENTS AND NEW RULES, CONTROL AND PROHIBITION OF CARBON DIOXIDE EMISSIONS, N.J.A.C. 7:27, 7:27A, 7:27F (DEP DOCKET NUMBER 07-21-11, PROPOSAL NO. PRN 2021-117)
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) on the proposed amendments and new rules regarding the carbon dioxide (CO2) emissions requirements published in the New Jersey Register on December 6, 2021.
CCNJ COMMENTS: FY2022 ANNUAL FEE REPORT AND ASSESSMENT OF FEES FOR THE NJPDES PERMIT PROGRAM
On behalf of our members, the Chemistry Council of New Jersey (CCNJ) appreciates the opportunity to provide comments on the New Jersey Pollutant Discharge Elimination System (NJPDES) Fiscal Year (FY) 2022 Annual Fee Report and Assessment of Fees.

