We know which way the wind blows. Testimony on air quality

Atlantic Sunrise Pipeline
Air Quality Permit Application
statement to the Pennsylvania Department of Environmental Protection
by William A Lochstet, Ph.D.
Board Member, Pennsylvania Interfaith Power & Light

Bill was Speaker 31 at the DEP hearing in Lancaster on August 14, 2017, and was quoted in Lancaster Online’s article about the hearing.

The Transcontinental Gas Pipeline Company (Transco) is expecting to release 105.4 to 133.5 tons of NOx during the construction of the Atlantic Sunrise Pipeline in Lancaster County. Since this is a non-attainment area for the ozone National Ambient Air Quality Standards (NAAQS), such emissions would exacerbate already excessive ozone concentrations. As a person of faith, I find that many traditions proclaim some form of the rule that we should all do unto others as we would like to be treated. And so, Transco is proposing to offset the impact of these emissions by transferring 106 tons of NOx Emission Reduction Credits (ERC) from Harford County MD.

Because of activity in Harford County, the air contains less NOx, and when it comes here, it can cancel the ozone creating effect of the emissions from the pipeline construction activity. This cleaner air is carried by the wind, whose average directions can be determined by a wind rose from Millersville University for Harrisburg International Airport (attached)[1]. This diagram divides the circle into 16 segments with 3 segments from the more or less proper southwest directions to bring air from Harford County to Lancaster County. Each of these segments represents about a 3% probability, so that we could expect the clean air to arrive about 9 or 10% of the time. Thus we would expect that of the 106 tons of ERC that only 11 tons would arrive in Lancaster County.

Another approach would be to examine the data in the Atlantic Sunrise Plan Approval Application[2]. Environmental Resources Management found 60 days for which the ozone concentrations at the Lancaster monitor exceeded NAAQS. They were able to identify 14 days for which the air quality at the Lancaster monitor was affected by air parcels that passed through the Baltimore area. Then the probability of air moving from Harford County to Lancaster County is 14/60, or 23%, so that we would expect 23% of 106 tons, or 25 tons of ERC to reach Lancaster County.

These calculations predict that Lancaster County will benefit from an offset of eleven (11) to twenty five (25) tons of the ECRs which would   not offset 105 tons of NOx. It does not meet the rule of “Do unto others as we would like to be treated.” A statement in the Air Quality Technical Report[3] is:

Transco’s approach to use ERCs to offset the complete, conservatively estimated                   amount of NOx emissions from Lancaster County will present a net benefit to air quality environment in the local area.

This statement cannot be true. Furthermore, the Code of Federal Regulations requires that the offset have the result “that there is no net increase in emissions of that pollutant.”[4] This requirement is not met. Thus this Air Quality Plan cannot be approved.

Notes
[1]. Available at: http://www.atmos.millersville.edu/~wic/climo/local_WindRose_MDT.jpg
[2]. Available at:     http://files.dep.state.pa.us/ProgramIntegration/PA%20Pipeline%20Portal/AtlanticSunrise/ASR%20GC%20Plan%20Approval%20Application%202017%200711.pdf
Appendix E; Memorandum from Mark Garrison, ERM, 6 December 2016.
[3]. Available at http://files.dep.state.pa.us/ProgramIntegration/PA%20Pipeline%20Portal/AtlanticSunrise/ASR%20GC%20Plan%20Approval%20Application%202017%200711.pdf
Attachment C; Atlantic Sunrise Air Quality Technical Report, P. 9, bottom of page
[4]. At 40 CFR § 93.158(a)(2), and also 40 CFR § 93.158(b)(2)