NJ Assembly Environment, Natural Resources and Solid Waste Committee
Supply Chain Federation
Testimony
Good afternoon, Chair Kennedy and members of the Assembly Environment, Natural Resources and Solid Waste Committee. My name is Sarah Wiltfong, and I serve as the Chief Advocacy and Public Policy Officer of the Supply Chain Federation. We are a national, non-partisan association of business, labor, and public sector leaders dedicated to collaboration and protecting the supply chain. We are here today to express our concerns regarding A4679 – which establishes an Indirect Source Review (ISR) program by requiring certain high-traffic facilities to obtain a permit from the Department of Environmental Protection (DEP) and annually implement measures to reduce air pollution caused by the facility.
The supply chain is vital to economic stability, consumer access, affordability, and the creation of good-paying jobs. It is a complex and intricately connected system – and when even small disruptions occur, their effects are often felt quickly across a broad range of sectors, communities, and residents. Therefore, it is essential that any proposed regulation considers the broader impacts on the supply chain.
Lowering emissions for the greater good of the community is something we all support and strive for. However, we question whether ISRs are the correct path to get there.
We have seen firsthand the impact of ISR programs in California, where stringent zero-emission (ZE) mandates and high mitigation fees place a heavy burden on warehouses—disproportionately affecting small operators. The South Coast Air Quality Management District’s (SCAQMD) ISR, adopted four years ago, has created excessive administrative requirements for warehouse operators while delivering negligible emission reductions. The U.S. Environmental Protection Agency (EPA) concluded that the rule could not be used for SIP credits because it ‘did not find a sufficient basis to credit [the rule] with achieving a specific amount of emissions reductions.’[1] Further, according to SCAQMD’s own socioeconomic impact report, the rule could result in up to 100,000 job losses within the first decade. [2] While environmental groups tout this program as a success, it has amounted to little more than bureaucratic red tape with no measurable community benefits.
As currently drafted, A4679 goes beyond typical ISR programs by not only mandating zero-emission vehicle adoption and renewable energy use without accounting for market realities, infrastructure challenges, or grid capacity constraints, it grants the DEP unprecedented authority to delay or revoke permits based solely on community objections. Unlike other programs that allow for mitigation fees when infrastructure upgrades are not feasible, this law provides no such alternative. Many small operators, unable to absorb expenses associated with this program will either pass them onto consumers or relocate, merely shifting truck emissions to other regions rather than reducing them.
While we fully support emissions reduction efforts, the focus should be on creating the infrastructure investments for a smooth transition and ensuring small businesses can continue to thrive—not adding regulatory burdens. As such we encourage collaboration with stakeholders to explore proven solutions that reduce emissions without harming the economy. As a key voice in the supply chain, we are eager to contribute our insights and help shape effective policies. Please consider us a resource in this process.
Thank you for your consideration of our comments. If you have any questions, please contact sarah@supplychainfederation.com.
[1] Federal Register Air Plan Approval; California; South Coast Air Quality Management District is available here: https://www.federalregister.gov/documents/2024/09/11/2024-20349/air-plan-approval-california-south-coast-air-quality-management-district. Accessed February 2025.
[2] South Coast Air Quality Management District Socioeconomic Impact Report can be viewed here: https://www.aqmd.gov/docs/default-source/planning/fbmsm-docs/pr-2305-draft-socioeconomic-impact-assessment.pdf?sfvrsn=8
