Lower Susquehanna Riverkeeper Submits Comments on Proposed ESCGP-2
On Tuesday, March 20th we submitted technical comments to the Pennsylvania DEP on its proposed new erosion and sediment permit for oil and gas operations over 5 acres. SOLS and the Lower Susquehanna Riverkeeper have concluded that the Department’s new ESCGP-2, in its current form, provides inadequate conditions and standards for the effective protection of human health and the environment from the detrimental environmental impacts of oil and gas development and related activities. We identified three particularly deficient areas that should be addressed in the Department’s final permit: Inadequate Buffer Requirements, Deficient Application of CWA Standards, and Insufficient Monitoring and Reporting Requirements. Click here to read those comments.