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01/18/2022 12:41 PM
Pennsylvania House of Representatives
https://www.legis.state.pa.us/cfdocs/Legis/CSM/showMemoPublic.cfm?chamber=H&SPick=20210&cosponId=36347
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House of Representatives
Session of 2021 - 2022 Regular Session

MEMORANDUM

Posted: October 18, 2021 10:54 AM
From: Representative Jim Rigby
To: All House members
Subject: Directing LBFC to study potential harmful economic impacts of DEP’s proposed biosolids permit revisions
 
In the near future, I intend to introduce a resolution directing the Legislative Budget and Finance Committee (LBFC) to study the cost and methods for permit holders to comply with the proposed revisions to DEP General Permits PAG-07, PAG-08 and PAG-09, which among other requirements, adds phosphorus index (P-Index) based application rates. The addition of a P-Index essentially mandates major changes for the permittee potentially requiring significant local investment and costs which will ultimately be passed on to the consumer.
 
To provide some background, DEP is proposing substantial revisions to General Permits (PAG-07, PAG-08 and PAG-09), which will significantly alter both the economic and environmental impacts of biosolids management across the Commonwealth. These unfunded mandates will have a cascading impact, including increased costs to the permittee and ratepayer, with little to no discernible positive impact to the environment.
 
The proposed revisions are written in a manner as to impose significant additional regulatory controls and financial constraints.  Furthermore, this permit change represents a significant enactment of public policy which has been reserved for our regulatory review process, a process which contains opportunities for legislative and public input. I believe a general permit revision of this magnitude should go through a deliberative procedure with due process, including analysis as to whether there is a discernible net environmental benefit.
 
Please join me in co-sponsoring this important resolution to better protect and serve our permittees and ratepayers.
 



Introduced as HR149