From the Executive Summary:
By assessing both public regulatory records and actual air pollution from these three facilities, we made five primary findings.
- Deliberately or not, operators and DEP have prevented facilities that likely should have been categorized as “major” polluters under Title V of the Clean Air Act from being so categorized—thereby avoiding closer government oversight and greater public scrutiny.
- Operators of large oil and gas facilities are allowed to continually expand, increase capacity, and change function without DEP’s consideration of cumulative air quality impacts.
- Emissions information provided by operators to DEP is insufficient to reflect the actual risks to air quality and health.
- Reliance on generalized emissions estimates allows operators and regulators to ignore what actually occurs at specific facilities and potential impacts on nearby residents.
- An emphasis on regional and state air quality thresholds ignores localized impacts and fluctuating emissions patterns, which can have the most negative effects on health.
To address these findings and protect air quality and public health as intended by the Clean Air Act, we make the following general recommendations:
- DEP should actively facilitate engagement of impacted residents and the public in facility oversight.
- DEP should take a comprehensive approach to facility permitting and oversight.
- DEP should vastly improve its actual measurement of pollution.
- DEP should expand and act upon its pollution measurements.
- Federal and state regulators should require leak detection and repair (LDAR).