Proposed Revisions to PA General Permit GW-8 Sacrifice Watershed Protection in favor of Easy Permit Approvals
in November 2013, DEP published notice in the Pennsylvania Bulletin of its proposal to significantly modify the Chapter 105 General Permit 8 (GP-8). Currently authorizing only temporary road crossings of streams and wetlands, the proposed and expanded permit would authorize the construction and removal of temporary pipelines that could remain in place for up to two years. It would also allow large-capacity (up to 24 inches in diameter) pipelines to carry “pollutional materials,” a term that is not defined but presumably would include fracturing and flowback fluids.
The proposed GP-8 would allow pipelines to be constructed through an unlimited number of wetlands and streams, including Exceptional Value waters, with no restrictions on the length or area of wetland or stream impacts. Like all General Permit registrations, GP-8 activities would not be published in the Pennsylvania Bulletin, thus greatly reducing the opportunity for public review and input. This all means that the Susquehanna River Basin, which is already experiencing significant degradation of its headwaters streams and wetlands due to intensive shale gas related industrial development, would be further compromised by yet another “sanctioned” method of pollution.
Because the proposed GP-8 seems intended to satisfy industry’s wish for expedited approvals at the expense of water resource protection we submitted this technical comment letter illustrating proposed GW-8′s deficiencies. Waterways, wetlands and communities of the Susquehanna deserve better than the proposed GW-8 permit.