By: Rachel Meyer, Ohio River Valley Field Organizer
Date: July 22, 2026
About: Docket No. EPA-HQ-OAR-2025-1212-0001
To: U.S. Environmental Protection Agency
My name is Rachel Meyer, and I am the Ohio River Valley Field Organizer for Moms Clean Air Force, a community of more than 1.6 million parents and caregivers working to protect children’s health from air pollution, climate change, and toxic chemicals. I live in Southwestern Pennsylvania, amid a network of facilities primarily serving the petrochemical industry.
Whether they are minor or major, the public must have a say in new facilities proposing to move into their communities. The New Source Review program is one of the only tools communities have to protect public health and ensure careful analysis happens before a new pollution source is built and they are locked in to decades of added health risks. This proposal would sabotage that protection by undermining the vital public participation process that enables communities to weigh in on health impacts.
It’s important to consider that minor source pollution can add up. Some facilities start as minor sources and then, once established, expand to major sources. The critical time for public participation was when the facility was first proposed, even as a minor source. Another form of piecemeal permitting happens when companies continue to propose individual minor source facilities in close proximity to each other.
Furthermore, many of the petrochemical facilities in our region claim they will emit the maximum amount allowable as a minor source, not accounting for the inevitable malfunctions that will push their emissions to major source levels. During an eight and a half month period, the Revolution Cryogenic Gas Processing Plant in Washington County, PA allowed visible emissions from the flare for periods that exceeded a total of 5 minutes during any 2 consecutive hours, with exceedances occurring during l07 distinct observation periods. This same facility is expanding and currently seeking a minor source permit with a stated potential to emit 49.5 tons per year of VOCs, 0.5 tons from the major source threshold in the county. Only about a mile away is the Harmon Creek Cryogenic Gas Processing Plant also prone to malfunctions and violations. Its PTE is 49.5 tons per year as well.
It is important context that the community where these facilities are located already suffers from high rates of asthma, heart disease, and cancer. It is a designated environmental justice area and bears a disproportionate burden from a massive amount of petrochemical build out even beyond the gas processing plants. And there are families with children stuck in the middle of it. Minor sources impact lives. The opportunity for public participation is clearly needed here and should be part of all New Source Review plans including for minor sources.
Moms Clean Air Force strongly opposes EPA's proposal to gut Minor New Source Review Program Air Permitting Public Participation Requirements for State Implementation Plans. There is too much at risk. Families must be guaranteed the opportunity to participate in decisions that affect the air they breathe.