I’m working on a short summary of David Stone’s key points from his three comment submissions.
One of the most important issues Stone has identified is getting an accurate baseline accounting of current Penn State emissions, because the baseline numbers influence the applicability of various air quality regulations as they relate to both the renewal of the general operating permit (TVOP 14-00003) and the specific West Campus Steam Plant project permit (TVOP 14-00003f).
Penn State has issued two separate baseline calculations in public notices – summarized here:
- 10.7.13 PSU EMISSIONS TABLE
To my knowledge, the discrepancies have not been publicly explained by either Penn State or DEP representatives.