Based on the Air Quality General Permit 5 (“AQ GP 5”) application by EGTS to the Pennsylvania Department of Environmental Protection (“DEP”) for the JB Tonkin Compressor Station and Exhibit F-I of the Resource Report submitted to the Federal Energy Regulatory Commission ("FERC") by EGTS, granting this permit to EGTS would not be in the public convenience and necessity. The Appalachian Reliability Project ("ARP") would severely pollute the air in Murrysville with increased quantities of criteria air pollutants, hazardous air pollutants (“HAPs”), carbon dioxide, and noise, creating a severe impact on the surrounding community that EGTS has not proposed to adequately mitigate.

Based on the permit application by Eastern Gas Trans & Storage Inc (“EGTS”), granting this permit would violate the Air Pollution Control Act (“APCA”), violate the constitutional rights of Pennsylvanians, and result in an unreasonable degradation, diminution, and destruction of Pennsylvania’s natural environment and airborne resources.
 

To summarize, the permit application proposes that EGTS should be permitted to significantly increase the Compressor Station’s emissions of nitrogen oxides by 34% to 95.08 tons per year (“tpy”), carbon monoxide by 16% to 31.40 tpy, sulphur dioxide by 29% to 1.40 tpy, all particulate matter by 49% to 13.41 tpy, hazardous air pollutants (HAPs) by 18% to 14.19 tpy, and CO2 equivalent emissions by 328% to 128,495.79 tpy.

This is despite the Department’s decision to downgrade the Compressor Station from a major source of air pollutants to a minor source of air pollutants in 2022. That decision ignored failures to comply with emission testing standards at the Compressor Station that indicated asserted emissions levels could be lower than actual potential levels of air pollutant emissions. Though this testing failure was detailed in a 2022 comment by the Clean Air Council (CAC), the Department did not heed the CAC’s warning at the time. The Department has another opportunity now to fix its mistake and prevent a radical increase in air pollution in Westmoreland County.
 

Pennsylvania residents are directly exposed to methane pollution and regulatory standards need to be
in place to protect them. Roughly 1.2 million Pennsylvania residents live within a half-mile of an
active oil or gas wellsite.
Those residents are vulnerable to developing serious health conditions.
Additionally, this pollution disproportionately impacts low-income and vulnerable populations,
as these are the communities most likely to live near oil and gas wells. By cutting methane
emissions, we also cut air pollution, and we stand the chance to cut down hardships faced by our
residents.

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Photo credit: Farm in Washington County, PA by Karen Kasmauski, Environmental Integrity Project

We understand the intention of this proposed rulemaking is to streamline the process for responding to unauthorized discharges. However, the proposed rule creates a process of self regulation that leaves open multiple avenues for operators to err on the side of self-interest, rather than operating in a way that protects the people and resources of the commonwealth.

Protect PT urges the PA DEP to expand their current ambient air monitoring in areas of increased industrialization and shale gas development due to known health effects from said infrastructure. Other recommendations include increasing the quality of monitors and standardizing the chemicals measured from one monitor to another to allow for comparison.

The health of Pennsylvania’s environment, waterways, and people are important to Protect PT and 3WRK. We recommend changes and revisions to the updated erosion and sediment permit process. We believe these changes will better protect the environment and ensure that the Department of Environmental Protection is fulfilling their mission to guarantee Pennsylvanians their constitutional rights to a clean and healthful environment.

Protect PT wrote a letter to PA Governor Shapiro to call out undemocratic government proceedings and demand change.

Protect PT and partners wrote to PEMA and Vernon Land Use LLC about the 2023 update of the PEMA State Hazard Mitigation Plan.

Protect PT wrote to the DEP to deny the renewal of the Tonkin gas compressor station.

Protect PT wrote a letter to deny the application for a leachate evaporator at the Westmoreland Sanitary Landfill.

Protect PT and partners wrote a letter to the DEP regarding commenting on Sunoco's Mariner East pipeline. Image Credit: FracTracker

Protect PT wrote a letter to PA DEP to request the denial of the drill and operate permits for the 1H and 7H wells. Several organizations signed on.

Protect PT wrote to the PA DEP requesting them to stop CNX operations near the Beaver Run Reservoir to protect the source water area. 

Protect PT commented during the hearing for the Invenergy proposed Allegheny Energy Center 639 megawatt combined-cycle natural gas-fired power plant, permit number 0959-I001, in Elizabeth Township, Allegheny County

The 2024 EPA methane rule would prevent 58 million tons of methane emissions from 2024 to 2038, helping

to avoid the worst effects of climate change. Pushing back compliance deadlines only undermines any progress already made by industry towards improved efficiency and will slash any protections and benefits promised to residents. Delaying compliance for the methane rule

shows a blatant disregard for the health of our communities.
 

Therefore, Protect PT is opposed to the EPA’s Extension of Deadlines in Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for

Existing Sources in the Oil and Natural Gas Sector and requests that the EPA reconsiders this compliance delay immediately.

We urge the AI Horizons Summit Planning Committee to promote discussion through plenaries on diversifying energy sources for AI and considering community impacts in
future summit events. We know that this year’s summit features some renewable energy-focused speakers, which is encouraging, but there is room for greater inclusion of both
renewable energy speakers and community representatives. AI Horizons can foster true innovation by connecting renewable energy leaders, who are creating some of the fastest growing and least expensive energy on the market, with AI developers.

Along with 14 of our partner organizations, we urge the Pennsylvania PUC Chairman and Commissioners to exercise the utmost caution,
care, and restraint in integrating data centers and other large load customers. Hyperscale data
centers are profoundly different from other customers and present numerous, wide-ranging
impacts on other ratepayers and Pennsylvania residents as a whole.

Commenters request that DEP hold a public hearing for Blue Moon’s Draft Permit due to numerous complaints from local residents of the Facility and how it disrupts their homelife and
health. Since starting operations around 2017, residents around the Facility experience health
symptoms that include burning eyes and trouble breathing.

The Environmental Integrity Project, alongside Protect PT, found several errors in the Draft Title V Renewal Permit (“Draft Permit”) issued by the Allegheny County Health Department (“ACHD”) for the Monroeville Landfill, operated by Chambers Development Company Inc. (hereinafter “CDC”). This comment letter explains the errors and asks that they be addressed.

Protect PT and 6 other environmental groups attended a press conference in front of the Southwestern PA DEP Office to ask Governor Shapiro to direct DEP to improve its regulations by increasing distance between the waters of the Commonwealth and fracking operations. 

Protect PT wrote a letter to the Pennsylvania DEP to deny the issuance of the Delmont North Pipeline Erosion and Sedimentation Control Permit to Hyperion Midstream, LLC.

Protect PT wrote a letter to deny the Erosion and Sedimentation Control General Permit - 3, proposed in December 2022.

Protect PT wrote to the DEP to deny the permitting of the Level Green and Lyons Run pipelines.

Protect PT wrote to the EPA to deny a permit for Sedat 4A Underground Injection Well.

Protect PT and Three Rivers Waterkeeper wrote a letter to the Bureau of Waste Management to address the inadequacies of Draft General Permit WGMR163. Image credit: FracTracker.

Protect PT wrote a letter to PA DEP about the Drakulic Well Pad in Penn Township requesting a public hearing on two new well permits. Photo Credits: Jason Cohn (Pittsburgh Foundation)

Protect PT wrote to the Murrysville Planning Commission regarding the pipeline near the Titan Well Pad.

Protect PT and Environmental Health Project co-wrote a letter to the PA DEP Southwest Regional Director Jim Miller to follow up on requests made by residents during a community meeting in March.

The EPA 2009 Endangerment Finding was a necessary update to the Clean Air Act that enabled us to more effectively and accurately fulfill the goal of protecting public health and
welfare. On April 2, 2007, in Massachusetts v. EPA , the Supreme Court found that greenhouse gases are air pollutants covered by the Clean Air Act. The Court held that the EPA Administrator must determine whether or not emissions of greenhouse gases from new motor vehicles contribute to air pollution that endangers public health, or whether the science is too uncertain to make a reasoned decision. The science was clear.
 

Removing the EPA’s ability to

regulate greenhouse gas emissions will only undermine existing progress to improve industrial efficiency, adapt our economy, protect public health, and mitigate the wide-ranging and severe effects of climate change. As the rest of the world moves forward, America will lag behind, choosing to regress and stagnate instead of forging a better future. For the sake of our nation, we urge the EPA not to repeal the Endangerment Finding.

We are writing to express our appreciation to your office and the Department’s Southwest Regional Office for their discovery of a series of willful, severe violations found at EQT Prod. Co.’s Porter Well Pad in Allegheny Township, Westmoreland County. We write further to formally request that the Department follow these violations with a consent assessment of civil penalty or an assessment of civil penalties to EQT Prod. Co. of an amount at least equivalent to the gross profits resulting from EQT’s refusal to delay fracking operations at the Porter Well Pad from July 10, 2025 to July 28, 2025 to conduct environmental remediation in compliance with the law in order to deter willful, knowing, and severe violations of Pennsylvania law and the degradation of Pennsylvania’s environment.

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Photo credit: PA DEP inspection report

Protect PT submitted comments to oppose the Fish and Wildlife Service’s proposal to remove the definition of “harm” from federal regulations without any replacement definition due to concerns for endangered species. If the agency wishes to revise the meaning of "harm," it should do so after a fully considered analysis by engaging in a study of the foreseeable impacts of this regulation as required by the National Environmental Policy Act. It should not, under any circumstances, eliminate the meaning of "harm.”

The PA DEP should only consider renewing the Title V permit for the WSL when WSL, LLC can show that it can meet its obligations under Pennsylvania’s Article 1 Section 27 rights to clean air and water, comply with its existing regulatory obligations and agreements with the DEP, and refrain from unequally and unlawfully infringing on the rights, health, and safety of Pennsylvania’s citizens living in the surrounding communities.

Protect PT submitted comments regarding the Mamont 12 site and the pending Erosion & Sedimentation plan due to concerns about erosion and sedimentation at this facility and the impact this facility can have
on the community both in regards to the environment and the health of nearby residents, especially noting that this is an environmental justice area.

Protect PT and 17 other groups collaborated on a letter to DEP regarding concerns that DEP's proposed policy does not
have the ability to create actual change and improve the environmental pollution
impacts in EJ communities.

FairShake Environmental Legal Services wrote a letter to the Mayor of Monroeville regarding the mishandling of Monroeville Council's Public Hearing on April 4, 2023.

Protect PT wrote a letter to deny the Erosion and Sedimentation Control General Permit - 2 proposed in November 2022. 

Protect PT wrote to the DEP to deny the permitting of Lyons Run Pipeline.

Protect PT wrote to the EPA to deny a permit for Sedat 4A Underground Injection Well.

Protect PT partnered with other organizations from Pennsylvania to write a comment on the renewal of permits for Sunoco's Chapter 102 permits.

Fair Shake Environmental Legal Services wrote to the US EPA on behalf of Protect PT to advocate for the revocation of the Sedat 3A Injection Well Permits. PC: FracTracker Alliance

Protect PT and partner organizations wrote to the US Coast Guard and the US Army Corps of Engineers to request them to not allow fracking waste to be barged on the 3 rivers.