Delaware Riverkeeper Opposes Proposed Pennsylvania Air Emissions Permit
Delaware Riverkeeper Network submitted comments on May 23 to the Pennsylvania Department of Environmental Protection’s (PADEP) Air Quality Bureau in Harrisburg regarding PADEP’s proposed revisions to the General Plan Approval and/or General Operating Permit for Natural Gas Production and Processing Facilities, known as GP-5. PADEP noticed the proposed revisions in March with a comment deadline of May 2 but then extended the comment period to May 23. The revisions apply to natural gas operations throughout the Commonwealth and were necessary to address changes in U.S. Environmental Protection Agency (EPA) performance standards and national emissions standards for hazardous air pollutants.
For a copy of DRN’s comments, click here.
DRN’s comment focuses on the issue of atmospheric deposition of airborne pollutants from natural gas production and processing facilities. DRN concludes that the proposed GP-5 is not effective for the protection of human health or the environment and advocates that PADEP correct the deficiencies in the proposed permit before moving ahead.
“The deposition of pollutants emitted by natural gas operations on to water will lead to water quality degradation and provides a substantial pollution pathway that PADEP does not address in the proposed GP-5," said Maya van Rossum, the Delaware Riverkeeper. “This is a huge missing piece of the air pollution puzzle that faces all Pennsylvanians because of the dangerous pollutants the gas industry emits. The problem must be solved by addressing the whole picture, not just little bits. PADEP needs to fix this and fix it now,” said van Rossum.
DRN engaged an air expert, Cherelle Blazer, MESc, of Texas to conduct a technical review of the GP-5 in regards to the issue of the deposition of air pollution on water; her report is included in the link to DRN comments above. Ms. Blazer found the proposed permit revisions to be inadequate in protecting public health and the environment because it does not go far enough in addressing the problem of deposition. Ms. Blazer recommends action be taken to analyze cumulative effects and then institute a plan to address them, to make more substantive cuts to emissions and to explore ways to prevent emissions such as restricting certain polluting activities (i.e. gas well flaring).
Ms. Blazer reviewed the scientific literature on this issue and points out that employing Best Available Control Technology (BACT), which is the primary method used in the GP-5, is simply not enough to keep air emissions from degrading the environment. In fact, the use of BACT in other parts of the country where drilling has been occurring has not resulted in effectively controlling nitrogen and sulfate, two of the dangerous air pollutants emitted by gas facilities that are deposited on to water. In Sublette County, Wyoming, where BACT is mandatory, nitrate and sulfate emissions have actually increased and there is evidence of atmospheric deposition in the water and on the land near gas fields there. Ms. Blazer points out that the proposed GP-5 permit can result in the same situation in Pennsylvania.
“Many pollutants are released by natural gas activities and they all must be stopped. Some of these toxics are deposited on land, vegetation and surface water, where they cause water quality pollution that affect millions more people downstream as well as downwind. PADEP is proposing to do the same old thing—a strictly technological fix. Well, this isn’t working anywhere in the nation. PADEP needs a new model—they need to prevent the pollution that is harming people and polluting our air and water,” said Tracy Carluccio, deputy director, Delaware Riverkeeper Network.
For more information on gas drilling, click here.
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By D. André Green II
One of nature's epic events is underway: Monarch butterflies' fall migration. Departing from all across the United States and Canada, the butterflies travel up to 2,500 miles to cluster at the same locations in Mexico or along the Pacific Coast where their great-grandparents spent the previous winter.
Millions of People Care About Monarchs<p>I will never forget the sights and sounds the first time I visited monarchs' overwintering sites in Mexico. Our guide pointed in the distance to what looked like hanging branches covered with dead leaves. But then I saw the leaves flash orange every so often, revealing what were actually thousands of tightly packed butterflies. The monarchs made their most striking sounds in the Sun, when they burst from the trees in massive fluttering plumes or landed on the ground in the tussle of mating.</p><p>Decades of educational outreach by teachers, researchers and hobbyists has cultivated a generation of monarch admirers who want to help preserve this phenomenon. This global network has helped restore not only monarchs' summer breeding habitat by planting milkweed, but also general pollinator habitat by planting nectaring flowers across North America.</p><p>Scientists have calculated that restoring the monarch population to a stable level of about 120 million butterflies will require <a href="https://doi.org/10.1111/icad.12198" target="_blank">planting 1.6 billion new milkweed stems</a>. And they need them fast. This is too large a target to achieve through grassroots efforts alone. A <a href="https://www.fws.gov/savethemonarch/CCAA.html" target="_blank" rel="noopener noreferrer">new plan</a>, announced in the spring of 2020, is designed to help fill the gap.</p>
Pros and Cons of Regulation<p>The top-down strategy for saving monarchs gained energy in 2014, when the U.S. Fish and Wildlife Service <a href="https://www.fws.gov/southeast/pdf/petition/monarch.pdf" target="_blank">proposed</a> listing them as threatened under the Endangered Species Act. A decision is expected in December 2020.</p><p>Listing a species as endangered or threatened <a href="https://www.fws.gov/endangered/esa-library/pdf/listing.pdf" target="_blank">triggers restrictions</a> on "taking" (hunting, collecting or killing), transporting or selling it, and on activities that negatively affect its habitat. Listing monarchs would impose restrictions on landowners in areas where monarchs are found, over vast swaths of land in the U.S.</p><p>In my opinion, this is not a reason to avoid a listing. However, a "threatened" listing might inadvertently threaten one of the best conservation tools that we have: public education.</p><p>It would severely restrict common practices, such as rearing monarchs in classrooms and back yards, as well as scientific research. Anyone who wants to take monarchs and milkweed for these purposes would have to apply for special permits. But these efforts have had a multigenerational educational impact, and they should be protected. Few public campaigns have been more successful at raising awareness of conservation issues.</p>
<span style="display:block;position:relative;padding-top:56.25%;" class="rm-shortcode" data-rm-shortcode-id="91165203d4ec0efc30e4632a00fdf57d"><iframe lazy-loadable="true" src="https://www.youtube.com/embed/KilPRvjbMrA?rel=0" width="100%" height="auto" frameborder="0" scrolling="no" style="position:absolute;top:0;left:0;width:100%;height:100%;"></iframe></span>
The Rescue Attempt<p>To preempt the need for this kind of regulation, the U.S. Fish and Wildlife Service approved a <a href="https://www.fws.gov/savethemonarch/pdfs/Monarch%20CCAA-CCA%20Public%20Comment%20Documents/Monarch-Nationwide_CCAA-CCA_Draft.pdf" target="_blank">Nationwide Candidate Conservation Agreement for Monarch Butterflies</a>. Under this plan, "rights-of-way" landowners – energy and transportation companies and private owners – commit to restoring and creating millions of acres of pollinator habitat that have been decimated by land development and herbicide use in the past half-century.</p><p>The agreement was spearheaded by the <a href="http://rightofway.erc.uic.edu/" target="_blank">Rights-of-Way Habitat Working Group</a>, a collaboration between the University of Illinois Chicago's <a href="https://erc.uic.edu/" target="_blank" rel="noopener noreferrer">Energy Resources Center</a>, the Fish and Wildlife Service and over 40 organizations from the energy and transportation sectors. These sectors control "rights-of-way" corridors such as lands near power lines, oil pipelines, railroad tracks and interstates, all valuable to monarch habitat restoration.</p><p>Under the plan, partners voluntarily agree to commit a percentage of their land to host protected monarch habitat. In exchange, general operations on their land that might directly harm monarchs or destroy milkweed will not be subject to the enhanced regulation of the Endangered Species Act – protection that would last for 25 years if monarchs are listed as threatened. The agreement is expected to create up to 2.3 million acres of new protected habitat, which ideally would avoid the need for a "threatened" listing.</p>
A Model for Collaboration<p>This agreement could be one of the few specific interventions that is big enough to allow researchers to quantify its impact on the size of the monarch population. Even if the agreement produces only 20% of its 2.3 million acre goal, this would still yield nearly half a million acres of new protected habitat. This would provide a powerful test of the role of declining breeding and nectaring habitat compared to other challenges to monarchs, such as climate change or pollution.</p><p>Scientists hope that data from this agreement will be made publicly available, like projects in the <a href="https://www.fws.gov/savethemonarch/MCD.html" target="_blank">Monarch Conservation Database</a>, which has tracked smaller on-the-ground conservation efforts since 2014. With this information we can continue to develop powerful new models with better accuracy for determining how different habitat factors, such as the number of milkweed stems or nectaring flowers on a landscape scale, affect the monarch population.</p><p>North America's monarch butterfly migration is one of the most awe-inspiring feats in the natural world. If this rescue plan succeeds, it could become a model for bridging different interests to achieve a common conservation goal.</p>
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