Dear Friend, In 2017, the Southeastern Pennsylvania Transportation Authority (SEPTA) received an air pollution permit for a natural gas and fuel oil-fired combined heat and power plant (CHP) to supply heat and electricity to its Roberts Complex in the Nicetown neighborhood of Philadelphia. There was major community opposition to the siting of a facility that would emit more air pollution in an already-burdened environmental justice community. The Roberts Complex consists of the Midvale Bus Depot, the Roberts Train Yard, and the Liberty Yard. Over 35,000 Philadelphians live within a mile of the Roberts Complex, 51% of which live under the federal poverty line and 83% of which are people of color. The City’s Air Management Services (AMS) permitted the facility as a “synthetic minor.” In order to qualify as a “synthetic minor,” SEPTA voluntarily committed to specific operating limitations to keep the facility’s nitrogen oxide (NOx) and volatile organic compound (VOC) emissions below 25 tons per year, each. NOx and VOCs impact public health and contribute to ground-level-ozone (smog) formation. The City of Philadelphia currently does not meet federal ozone standards and, in its 2021 Air Quality Report, AMS concluded that smog is increasing in the city, raising the risk of respiratory damage and other health effects. In January 2022, during a required test of emissions from the facility’s largest pollution source, it was determined that one of the heat and power generation units was emitting pollution above permitted levels. The malfunction was repaired and the facility paid a fine. It is unknown how long this equipment was malfunctioning for and how much unpermitted air pollution was released over time. Since the facility is so close to the limits for NOx and VOCs, this malfunction likely caused this facility to surpass the 25 tons per year (TPY) pollution limits for those pollutants. SEPTA is now seeking to renew this air pollution permit and residents should demand increased air monitoring and testing requirements at this facility to ensure its actual air pollution complies with its permit limits at all times. The current air permit and proposed renewal only requires that the two large heat and power generation units at the site be tested every 8,760 hours of operation or every 3 years, whichever comes first. This is clearly inadequate and risks that equipment could be malfunctioning for years without repair, creating unpermitted, dangerous air pollution. Please tell AMS to increase air pollution monitoring and testing at SEPTA’s CHP plant in Nicetown. | |
Joseph Otis Minott, Esq.
Executive Director and Chief Counsel | |
