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Thank you for the opportunity to comment on the draft General Permits for unconventional natural gas operations, GP-5 and GP5-A, recently issued by the Pennsylvania Department of Environmental Protection (DEP).

Earthworks greatly appreciates DEP’s work in developing these permits, which are necessary to limit the methane pollution that harms air quality and health in the Commonwealth, as well as the global climate. It is encouraging to see Pennsylvania joining other states (in particular Ohio, California, and Colorado) in adopting methane control measures.

Requiring operators to find and repair methane leaks in their equipment is a common sense measure that would both reduce pollution and save energy resources. Currently, Pennsylvania operators waste more than $20 million worth of natural gas every year, enough to supply 65,000 homes.

At the same time, according to data from the DEP emissions inventory, methane emissions from the oil and gas industry rose an astonishing 28% between 2014 and 2015. This is more than double the rate of increase in production (12%).

Please accept these comments on behalf of Earthworks, a national nonprofit organization committed to protecting communities and the environment from the impacts of mining and energy development while seeking sustainable solutions. For more than 25 years, we have fulfilled our mission by working with communities and grassroots groups to reform government policies, improve corporate practices, influence investment decisions and encourage responsible materials sourcing and consumption.

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