The Ground Rules

Take part: comment guide

Comment on the Socrates the Younger air permit

Ohio EPA is taking public comments on draft permit P0139969 until 11:59 p.m. on Dec. 3. The draft sets the emission limits for 20 gas turbines and 4 gas engines at 3439 Clover Valley Rd.

Last checked against sources on .

The short version

  • Comments are due by 11:59 p.m. on Thursday, Dec. 3.1 How to send one
  • The draft is a 42-page PDF. The limits for each engine and turbine are on pages 23–24 and 33–34.2 Open the draft
  • A useful comment has three parts: your concern, a page of the draft, and the change you want.
  • Write it in your own words. A few sentences is enough.

The draft permit

Ohio EPA posted the draft on Sept. 22. It includes a cover letter, the public notice and a staff summary before the permit itself.2

Open the draft permit (PDF, 10 MB) Ohio EPA comment page
Permit
P0139969, a draft air permit-to-install for a new plant.2
Company
Will-Power OH, LLC – STY. The plant is called Socrates the Younger.1
Site
3439 Clover Valley Rd, New Albany, in Licking County.1
Equipment
4 Caterpillar G3520 gas engines and 20 Solar Titan 130 gas turbines, each with an oxidation catalyst and an SCR system to cut emissions. The site will also have two diesel emergency generators, a diesel fire pump and 21 small gas heaters.2
Deadline
11:59 p.m., Dec. 3, 2026.1
Hearing
None has been scheduled. The cover letter says Ohio EPA takes requests for a public hearing along with comments.2

Page numbers on this page count from the first page of the PDF. From page 8 on, they match the "Page X of 42" printed at the bottom. The table of contents on page 7 is a few pages off.

The pages that matter

Start with the staff summary on pages 3 to 5. Then read the limits for the engines and the turbines.

PagesWhat's thereWhat it says
1Cover letterA checklist marks the permit "No PSD" and "No CEMS," with modeling submitted. It also says where comments go.2
3Table 1: what the whole plant could emitIn tons a year: nitrogen oxides 148, carbon monoxide 186, fine particles (PM10 and PM2.5) 104, VOC 101, sulfur dioxide 147, ammonia 265.2
4–5Why each unit skips Best Available TechnologyEach engine and turbine is under 10 tons a year with its controls, so Ohio's BAT rule does not apply. The company asked for limits that keep the plant out of federal PSD review.2
5Air modeling and total allowable emissions24-hour PM2.5 was modeled at 114.82% of Ohio EPA's usual level at three locations, and managers approved an exception. Allowable totals: NOx 125, CO 155, VOC 102 tons a year.2
20–21Facility-wide termsNo plant-wide emissions cap. Limits are set unit by unit.2
23–24Engine limits (P001–P004)Per engine: 0.74 lb of NOx an hour, 2.46 lb per startup or shutdown, and 3.32 tons a year.2
25–26Engine operating rules and recordsNatural gas only. The controls may be bypassed during startup and shutdown, up to 40 of each a year. Yearly tons are calculated from hours run and a per-hour rate.2
27, 37Toxic air modelingResults for ammonia and formaldehyde, compared with Ohio's acceptable levels.2
29Engine testingA first stack test within 180 days of startup, then every 8,760 hours or 3 years.2
33–34Turbine limits (P005–P024)Per turbine: 1.24 lb of NOx an hour, 64 lb of CO per startup, 5.58 tons of NOx and 8.10 tons of CO a year.2
35–36Turbine operating rules, startup and monitoringThe same 40 startups and 40 shutdowns a year for each turbine. A startup lasts until the SCR catalyst is hot enough to work.2
39Turbine testingA first stack test within 180 days of startup. Later tests follow the federal turbine rule.2
More detail: what PSD, BAT and the "usual level" mean

PSD (Prevention of Significant Deterioration) is the federal review for large new sources of air pollution. The draft's limits keep this plant's potential emissions below the PSD thresholds, so that review does not apply.2 Our position on this

BAT is Ohio's Best Available Technology rule. It does not apply to a unit whose emissions are under 10 tons a year, and here every unit is under that line.2

The usual level on page 5 is what Ohio EPA calls a "Generally Acceptable Incremental Impact." It is half of the federal PSD increment, the amount of added pollution allowed in an area. Ohio EPA's modeling guide says it may grant exceptions below 83% of the increment, "provided public health will not be adversely affected."3

Questions you could ask

Pick one or two that matter to you, and name the page. These are starting points for your own comment.

  • Monitoring, pages 1 and 26The checklist says "No CEMS," and yearly tons are calculated, not measured. Should 24 units this size have continuous emission monitors?
  • Startups, pages 33–35Each turbine may start up 40 times a year with its SCR not yet working, at up to 64 lb of CO each time. How long does a startup last?
  • Fine particles, page 5Where are the three locations where 24-hour PM2.5 was modeled above the usual level? What showed that public health would not be harmed?
  • The whole plant, pages 3–4Each unit is exempt from BAT because it is under 10 tons a year, yet together they could emit 148 tons of NOx. Should the plant be judged as a whole?
  • The numbers, pages 5, 24 and 34The per-unit CO limits add up to about 175 tons a year (20 turbines at 8.10 tons, 4 engines at 3.31). Page 5 lists 155 tons. Which is right?
  • Testing, page 29After the first test, each engine is retested every 3 years or 8,760 hours of running. Is that often enough?

A worked example

A comment this short can be written in about 15 minutes. Yours should be about your own concern.

  1. Your own concern

    Say who you are and why this permit matters to you.

    Example: I live in New Albany, and my daughter has asthma. Her doctor tells us to watch fine particle levels on bad air days.

  2. A specific page or question

    Point to one part of the draft, by page number, and ask about it.

    Example: Page 5 of draft permit P0139969 says modeling found 24-hour PM2.5 at 114.82% of Ohio EPA's usual level at three receptor locations, and that an exception was approved. Where are those locations, and what showed that public health will not be harmed?

  3. The outcome you're asking for

    Say what you want Ohio EPA to do.

    Example: Please publish the receptor locations and the reasons for the exception before issuing the permit. Please set limits that bring the modeled PM2.5 under the usual level.

Please don't copy this example. Write about what worries you, in your own words. Comments may be a letter or a marked-up copy of the draft.2

Send your comment

Ohio EPA takes comments on its online form or by mail until 11:59 p.m. on Dec. 3.1

  1. Online

    Open the comment page for P0139969. The form asks who you are and for your email address. Paste your comment into the box. You can attach up to five files of 20 MB each.1

  2. Or by mail

    Ohio EPA Central District Office, P.O. Box 1049, Columbus, OH 43216-1049. Put the permit number, P0139969, on the letter. The notice does not say whether a postmark counts, so mail it early.1

  3. Ask for a hearing, if you want one

    No hearing has been scheduled. To ask for one, say so in your comment.2

Trouble with the form: Max Moore, Ohio EPA, 614-644-2160, max.moore@epa.ohio.gov.1 The comment page does not list email as a way to file a comment.

More ways to take part

Join us for a reminder before each comment deadline. To speak at a meeting instead, see the meeting guide. Other open cases are on Take part.

Sources

  1. Ohio EPA, public comment page for draft permit P0139969, "Will-Power OH, LLC - STY," viewed Nov. 8, 2026. ohioepa.commentinput.com
  2. Ohio EPA, Draft Air Pollution Permit-to-Install P0139969, Will-Power OH, LLC – STY, Sept. 22, 2026, with cover letter, public notice and permit strategy write-up (42 pages). (PDF)
  3. Ohio EPA, Engineering Guide #69, "Air Dispersion Modeling Guidance," revised Nov. 14, 2018, Questions 19 and 20, p. 13. (PDF)