EEN Comment to Pennsylvania DEP

The Pennsylvania Department of Environmental Protection is accepting comments on natural gas regulations. EEN believes that PA should limit emissions and strengthen the proposed regulations. Read our full comment below and be sure to submit your own by June 5. 

Revisions to the Existing General Operating Permit for Natural Gas Compressor Stations, Processing Plants and Transmission Stations (BAQ-GPA/GP-5 or GP-5) and General Operating Permit for Unconventional Natural Gas Well Site Operations and Remote Pigging Stations (BAQ-GPA/GP-5A or GP-5A)

We are grateful to Governor Wolf and Pennsylvania’s Department of Environmental Protection (DEP) for their creation-care leadership in submitting General Permit standards, GP-5 and GP 5a, and appreciate the opportunity to offer this comment.  With some suggested improvements (see below) these regulations will help defend our children, both born and unborn, from the threats that fugitive methane emissions from new sources pose to them.  An essential next step is the regulation of existing sources, which Gov. Wolf has promised to do.

As pro-life evangelicals, we have a special concern for the unborn.  We want children to be born healthy and unhindered by the ravages of pollution.  The medical community has long known of the environmental impacts on our unborn children.  Studies have shown that smog, VOCs, and air toxics have a disproportionate impact upon life in the womb.  A recent study by researchers at the University of Pittsburgh found evidence of low birthweight babies associated with proximity to unconventional Gov. Wolf in Butler County, PA,[1] and another study in 2015 linked birth defects to methane production.[2]  The authors admit more research is needed, but the initial conclusions in of themselves demand action to reduce natural gas releases.

These leaks in our natural gas infrastructure also spew out smog precursors, adding to our failing air quality.  Pennsylvania has over 300,000 children with asthma according to the American Lung Association, and much of Pennsylvania’s air exceeds limits for both ozone (smog) and particulates (soot) emissions, making the need to stop natural gas leaks urgent.  There is simply no way for Pennsylvania’s air quality to improve with the vast amounts of methane spewed by thousands of natural gas installations across the commonwealth, both old and new.  

Further exacerbating our children’s health is that Pennsylvania Department of Environmental Protection recently released new industry data that fugitive methane emissions have increased by 28% in 2015. As a result, York County where our ministry is based has up to 2000 additional asthma attacks resulting from methane leaks.  

This pollution also adds to climate disruption. We want our loved ones, the unborn, and those yet to be born, to inherit a world free of climate change.  Yet today from our natural gas infrastructure large amounts of methane are being released, a climate pollutant 86 times stronger than carbon dioxide at trapping heat over a 20 year timeframe – and it is these next 20 years that will determine whether our struggle to overcome climate change will be won or lost.  That is why reducing methane is morally strategic.

For these reasons, nearly 40,000 pro-life Christians from PA have called for strong action to reduce methane emissions.  Their request states:

As pro-life Christians, we want the air that we breathe to be safe for our children. Leaks in our natural gas infrastructure spew out toxic pollutants, cancer-causing agents and climate pollution that place God's creation and our families - especially children, pregnant mothers, and the unborn - in harm's way. That's why we call on our elected officials to support strong regulations to cut this pollution from both new and existing leaks from our natural gas infrastructure. Our children deserve nothing less.

As you can see, not only do we want leaks from new infrastructure to be prevented as GP-5 and GP-5a begin to do, but we ask Gov. Wolf to fulfill his pledge to reduce pollution from existing natural gas infrastructure.  This is absolutely essential, as the current level of pollution is totally unacceptable.

Finally, these proposed regulations could be strengthened in three ways: (1) have leak detection and repair done monthly, not quarterly; (2) don’t reward companies who don’t find leaks with lower leak detection requirements, and; (3) require tanks, dehydrators, and pigging operations to meet a lower threshold for leaks/emissions.

[1] Stacy SL, Brink LL, Larkin JC, Sadovsky Y, Goldstein BD, Pitt BR, et al. (2015) Perinatal Outcomes and Unconventional Natural Gas Operations in Southwest Pennsylvania. PLoS ONE 10(6): e0126425. doi:10.1371/journal.pone.0126425, downloaded September 28, 2015, http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0126425

[2] Lisa M. McKenzie, Ruixin Guo, Roxana Z. Witter, David A. Savitz, Lee S. Newman, and John Adgate, Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural Colorado, Environmental Health Perspectives doi:10.1289/ehp.1306722. downloaded September 28, 2015, http://ehp.niehs.nih.gov/1306722/#tab3

[3] Austin L. Mitchel, et.al, Measurements of Methane Emissions from Natural Gas Gathering Facilities and Processing Plants: Measurement Results, Environ. Sci. Technol. 2015, 49, 3219−3227. Downloaded on September 28, 2015, http://pubs.acs.org/doi/pdf/10.1021/es5052809

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