Air Quality: Public Comment – Our GP5 Comment Submitted
Back in 2012 many of us had submitted comments on the overhauled and expanded GP5 air quality permit. At that time, the GP5 was expanded to include a larger grouping of compressor stations that were being permitted via the plan approval process. Most compressor stations were at least with regard to engines, often duplicates as a few engines were being commonly chosen by many operators. A stringent GP5 had the ability to not only hasten the permitting timetable but also provide for consistency with permitting, thus benefiting the public. Enough file reviews will detail that back in the early days, compressor stations located in Susquehanna and Wyoming Counties were not permitted with the same eye to detail when it came to permit conditions that were placed on stations located in Bradford, Sullivan and Tioga Counties. This was due to the lack of consistency between regional offices. While, at one point this changed, it was only after the public pointed out the disparity. The GP5 did away with regional offices making independent permitting conditions on compressor stations. They were now standardized. There is a definite need for more coordination from the BAQ central office as inconsistency between regional offices continues to this day.
A public comment period resulted in the some of the final permit conditions becoming more stringent than proposed. This is directly because of those that wrote detailed comments that were effective in pushing the bar of regulations. The DEP published the CRD (2013) – comment response document and it was really great to see so many regular shale dwelling folks have their comments not only singled out in the document, but have the regulation modified as a result.
Would we have liked the GP5 to have more stringent requirements? You betcha, but all in all, those of us who wrote detailed comments made a big difference on the final permit as compared to the draft. That is why your comments are so important. Generally, the GP5 would not be up for revisions/public comment for five years. But due to a Supreme Court decision this past June, the DEP needed to modify the permit. They also included some minor modifications to the permit.
Our comment has been submitted. You may read it here.
Big thanks to those who took time either during the holiday season or postponed the inevitable take the tree down to submit their comment on the modifications. We truly appreciate the time you set aside to do this. This will benefit everyone.
Those who did not submit a comment this time, please consider pledging to write a few or several comments this year when we publish an Action Alert. We really need your help this year more than ever. Thank you.
Emily Krafjack, President