Tag Archives: DEP

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)

DEP Hearings: Rev. Alison Cornish

Rev. Cornish is the Executive Director of PA IPL.  She testified at the PA DEP listening session in Philadelphia County on September 30, 2015.  Alison headshot

Good Afternoon.  I am the Reverend Alison Cornish, and I serve as the Executive Director of Pennsylvania Interfaith Power & Light, a community of congregations, faith-based organizations and individuals of faith responding to climate change as a moral issue.  Through advocacy, energy conservation, energy efficiency and the use of clean, renewable energy, we help people of faith be model stewards of Creation.  We are the Pennsylvania affiliate of Interfaith Power & Light, a national religious response to the threat of climate change.  We see climate change as a moral issue.

We recognize that the Clean Power Plan is the single biggest and most ambitious action the U.S. has ever taken to tackle climate change. It sets the first-ever limits on Continue reading

DEP Testimony: Rev. Bill Thwing, Johnstown

31664_10150197269130105_5950125_nThank you Secretary Quigley and  DEP for holding these hearings and encouraging us citizens to exercise our democrat responsibilities to envision the future…together

Good morning, my name is William Thwing.  I am a Pastor at St Paul’s United Church of Christ, here in Johnstown. I’m an active member and former president of Pennsylvania Interfaith Power & Light,  a founding member and former Western PA coordinator of the Pennsylvania Council of Churches , Interfaith Global Climate Change Campaign.   I’m also a former Military Intelligence Officer who served in combat  Vietnam and I’ve been studying Climate Change since I returned from that formative experience – you might say that I’ve been a military intelligence in the servant of the Creator God ever since.    Continue reading

DEP hearings: Joy Bergey

JoyBergeyJoy Bergey is a former PA IPL board member.  She testified at the PA DEP listening session in Marcus Hook, Philadelphia County on September 30, 2015.  

My name is Joy Bergey, and I speak as director of the Environmental Justice Center of Chestnut Hill United Church. Based in Philadelphia, the Center is a multi-religious program working with congregations to address issues of environmental injustice.

We thank Secretary Quigley and DEP for holding these listening sessions. We you to create a strong plan to meet EPA’s emissions reductions targets under the Clean Power Plan. In fact, we urge DEP to exceed these targets.

In light of DEP’s own startling new report, Pennsylvania’s temperatures are predicted to rise 5 to 6 degrees in mere decades.

Given the deeply inspiring messages delivered by His Holiness Pope Francis just a few miles from here last weekend, we must take strong action to limit carbon pollution. It’s a moral imperative.

We at the Center have recently become aware of a significant source of carbon dioxide that EPA has included as a potential compliance option under the Clean Power Plan: wood-burning Continue reading

DEP hearings: Rev. Bill Thwing, Pittburgh

31664_10150197269130105_5950125_nRev. Thwing is a past president of the PA IPL board.  He testified at the PA DEP listening session in Pittsburgh on September 21, 2015.  

Good evening.  My name is William Thwing.  I am a Pastor in Johnstown, PA;  the father of 4 children, grandfather of 5 and a geneaologist – which means that I can trace my family tree back many generations.  My ancestors who worked  so hard and sacrificed so much  enable the emergence of my generation today, would be appalled if they realized that all their prayers and hopes and efforts could be wiped out within a couple of generations by the chaos of the climate changes detailed in part in the most recent “Pennsylvania Climate Change Assessment”.   I fear for my grandchildren  and the generations to come, that we, in our shortsighted self-serving generation, will leave them nothing more than an  ‘immense pile of filth” as Pope Francis puts it in his Encyclical, Laudato Si. Now is the time to act decisively.  Now is the time to make the sacrifices necessary to insure our grandchildren’s survival and the survival of our nation.

I thank the DEP for holding these hearings and giving Pennsylvania citizens an opportunity to envision together a plan to insure our common welfare and survival. I Continue reading

DEP hearings: Peter Winslow

peterwinslowPeter Winslow is a PA IPL board member.  He testified at the PA DEP listening session in Philadelphia County on September 30, 2015.  His oral remarks are followed by a longer written submission.

My name is Peter Winslow.  I wish to express our appreciation to Gov. Wolf, Sec. Quigley, and the DEP staff for:

  • Embracing the Clean Power Plan rather than resisting the EPA’s rulemaking authority,
  • Working to develop a Pennsylvania Plan instead of waiting for imposition of a federal plan,
  • Endeavoring to submit our PA plan by September 9, 2016 without requesting an extension of time in which to comply with the Rule, and
  • Holding these listening sessions for the public to provide input on a timely basis.

Continue reading