[brief] II.  [...] ARBITRARILY IGNORED REASONABLY FORESEEABLE IMPACTS TO WATER QUALITY FROM THIS PROJECT’S CONTRIBUTION TO CLIMATE CHANGE AND THE ADDITION OF IMPERVIOUS SURFACES.  (Aa001)  [...] argued that the “Appellants focus on concerns about climate change and impervious surfaces, but neither are relevant under the WQMP rules. ”  [...] at 17, emphasis added.  Nothing could be further from the truth.  The WQMP rules required the [...] to take a broad and searching look at how this Project might be consistent with the relevant WMP.  Again, [...] has focused too narrowly in its consistency assessments here and, sadly, it has failed to meet its obligations under the law.  Considering [...]’s admissions that climate change and newly constructed impervious surfaces are increasingly and specifically damaging Highlands water resources, it is impossible to understand how the [...] can rest its decision on an argument that those impacts are irrelevant and must be ignored under the WQMP rules.  It is truly bizarre that [...] would rely only on its septic density rules under the Highlands regulations to make an overall determination of consistency with the areawide WQMP.  As the Environmental Appellants argued in their Initial Brief in this matter, at pages 35-37, [...]’s regulations implicate a much broader requirement for the [...] to review and consider potential impacts to water quality under the instant consistency determinations, beyond how many gallons of water get flushed into the septic system on a daily basis.  See N.J.A.C. 7:15-3.2 and N.J.A.C. 7:38-9.2.  [...] argued that “…as contemplated by the WQPA and the WQMP rules, [...]’s other regulatory programs, such as the New Jersey Pollution Discharge Elimination System (“NJPDES”) program, separately address stormwater and any applicable total maximum daily load (“TMDL”) requirements. ”  [...] at 18-19.  But this is more nonsense from the [...] because the consistency assessment is a prerequisite that comes before any permit can be issued.  Under the Water Quality Planning Act, all projects “shall be developed and conducted in a manner consistent with the adopted areawide plan. ”  N.J.S.A. 58:11A-10.  [...]’s own rule says the Consistency Assessment must precede the permit.  N.J.A.C. 7:15-3.2(a).  Compliance with potential NJPDES permits during and after construction of the project does not satisfy the requirement to determine if the project is consistent with the Areawide WQM Plan before the project is built.  The same is true of any other permit which might implicate TMDL requirements.  Future permits may regulate the conduct of the facility, but not its development in the initial planning stages, which is precisely when the WQPA and implementing regulations require the [...] to assess broadly all potential impacts to water quality.  The purpose of the [...]’s regulations is frustrated here because the [...] permitted the construction of a facility when the discharges and corresponding permits that will be required in the future could be incompatible with the WQPA.  Entirely absent from the record is [...]’s consideration of whether the many water bodies surrounding this Project, including a nearby drinking water reservoir, will be adversely impacted by the additional impervious surfaces and additional stormwater runoff from this Project.  See Aa0037, Aa0039, Aa0178, and Aa0194 for visual representations of the numerous and varied water bodies surrounding this Project.  [...] is located approximately 1,200 feet east of the location of the compressor station.  Aa0066.  III.