NJ PACT Update: New Jersey Announces CO2 Emissions Limits For Stationary Sources

During the first term of New Jersey Governor Phil Murphy, his administration announced ambitious plans both to reduce emissions of greenhouse gases responsible for climate change and to change land use rules to mitigate the effects of rising sea levels and other effects of climate change. The State dubs this initiative "NJ PACT—New Jersey Protecting Against Climate Threats."

On December 6th, in the waning days of Murphy's first term and before the start of his second term, the New Jersey Department of Environmental Protection (NJDEP) proposed its most significant set of NJ PACT regulations to date, which focus on limiting emissions of carbon dioxide (CO2) from stationary sources. The proposed rule has three parts. First, it places emissions limits on CO2 from electric generating units (EGUs), i.e., the combustion or steam-generating equipment that generates electricity at power plants. These limits will become more stringent over time. Second, it creates a regulatory