There is still time for you to tell the Virginia Air Pollution Control Board to deny Dominion’s application for a permit to release air pollution that will threaten the health and well-being of residents in the Union Hill neighborhood and beyond. The public comment period has been extended to September 21, 2018, so don’t wait – let your voice be heard.
Buckingham Compressor Station for the
Atlantic Coast Pipeline Air Quality Permit
Public Comment Period Ends 9/21/18
Submit your comments to:
DEQ, Piedmont Regional Office
Re: Buckingham Compressor Station
Piedmont Regional Office
4949-A Cox Rd.
Glen Allen, VA 23060
What is the concern?
The draft permit prepared by the Department of Environmental Quality (DEQ) is woefully deficient, failing to provide the analyses and the levels of protection the law requires.
Dozens of people spoke at a public hearing on September 11th, most explaining technical and legal problems with the proposal and opposing issuance of the permit. Please add your voice to that strong message, to let the citizen members of the Air Board know you oppose this illegal and unethical proposal to victimize citizens for private profit.
What to say?
Even if you lack technical expertise, you can raise important issues the Board is legally-obligated to consider.
- The Atlantic Coast Pipeline (ACP) is not needed to supply energy to the areas Dominion claims would be served and
- DEQ has failed to properly consider whether the placement of the facility is appropriate or to acknowledge the violation of environmental justice principles.
DEQ officials have stated that the Department and the Board lack authority to consider issues related to the need for the project and proper siting of the station. State law explicitly contradicts this position. The State of Virginia not only has that authority, it has a solemn obligation to exercise it.
The Air Board, in approving permits, “shall consider facts and circumstances relevant to the reasonableness of the activity involved,” including:
- The character and degree of injury to, or interference with, safety, health, or the reasonable use of property which is caused or threatened to be caused;
- The social and economic value of the activity involved;
- The suitability of the activity to the area in which it is located; and
- The scientific and economic practicality of reducing or eliminating the discharge resulting from such activity.
Code of Virginia § 10.1-1307.E.
No Need for the Pipeline and Compressor Station
A mountain of evidence proves that Dominion’s claims about the need for gas to be supplied by ACP are untrue. Importantly for this permit review, DEQ has refused to acknowledge this information or to incorporate it into its analysis of Dominion’s application for the air permit.
This deficiency is directly pertinent to the “reasonableness of the activity involved” and the “social and economic value of the activity involved,” which the Air Board must consider. Code of Virginia § 10.1-1307.E. Weighing against the lack of need for the project are the social and economic costs that will be imposed on the communities directly affected by the compressor station.
Unfair Targeting of Communities of Color and Impacts to Vulnerable Populations
The disproportionate impacts the compressor station would have on the African American community in and around Union Hill are clearly shown. The Federal Energy Regulatory Commission (FERC) relied on incorrect and incomplete information about the local community to dismiss environmental justice and siting concerns. The Air Board must demand that DEQ provide and analyze correct data on these issues and must reject this permit unless and until the Department does so.
The Air Board is required to consider these facts in an analysis of the “character and degree of injury to, or interference with, safety, health, or the reasonable use of property which is caused or threatened to be caused” and the “suitability of the activity to the area in which it is located.” Code of Virginia § 10.1-1307.E. The Board must reject the draft permit prepared by DEQ and require that all pertinent siting considerations be investigated and analyzed before it considers the proposal further.
FERC relied on incorrect data from Dominion to conclude in its final environmental impact statement on the ACP that, on average, there are 29.6 people per square mile in the area surrounding the pipeline’s path in Buckingham—that number was provided by the U.S. Census Bureau. However, a survey of the community by Friends of Buckingham showed that FERC’s number was off by about 500 percent.
Even worse, FERC failed to acknowledge the certain impacts to the Union Hill community. As reported in a news article at Cville.com, Compressor anxiety: Historic African American community alleges environmental racism:
“Members of the anti-pipeline group Friends of Buckingham went door-to-door to survey the Union Hill area. They spoke with 64 percent of the people living in the 99 households within that square mile, and of those 158 residents, 85 percent are African American.”
“The FERC report didn’t mention Union Hill, where a third of the residents are descendants of the freedmen community that was once enslaved there, and where there are freedmen cemeteries and unmarked slave burials on the site where Dominion wants to build its compressor station, according to Yogaville resident and cultural anthropologist Lakshmi Fjord.”
DEQ has also failed to account for the fact that these areas have unusually large percentages of elderly people and children, both of which are especially sensitive to the kinds of air pollutants the compressor station would emit.
Recently, Governor Northam’s Advisory Council on Environmental Justice (ACEJ) found evidence that ACP would have “disproportionate impacts for people of color and for low-income populations due to gas infrastructure expansion.”
Based on that and other findings, the ACEJ recommended the “Governor direct DEQ to suspend the permitting decision for the air permit for the Buckingham compressor station pending further review of the station’s impacts on the health and the quality of life of those living in close proximity.” See ACEJ letter, dated August 16, 2018, at Environmental Justice Review of Virginia’s Gas Infrastructure. The ACEJ also recommended Governor Northam convene an Emergency Task Force on Environmental Justice in Gas Infrastructure. See article about the ACEJ’s action at Governor’s Advisory Council Call for Moratorium on Atlantic Coast and Mountain Valley Pipelines, Global Justice Ecology Project, August 29, 2018.
Where to Learn More?
- Are the Atlantic Coast Pipeline and the Mountain Valley Pipeline Necessary?, Synapse Energy Economics, Inc., September 12, 2016. (“The region’s anticipated natural gas supply on existing and upgraded infrastructure is sufficient to meet maximum natural gas demand from 2017 through 2030. Additional interstate natural gas pipelines, like the Atlantic Coast Pipeline and the Mountain Valley Pipeline, are not needed to keep the lights on.”)
- IEEFA Update: Atlantic Coast Pipeline Risk Is Being Borne Not by Dominion and Duke, but by Their Customers, Institute for Energy Economics and Environmental Analysis, September 8, 2017. (“For both Dominion and Duke, Actual Electricity Consumption Has Been Essentially Flat for the Past Few Years, leading the utilities recently to be less optimistic about growth.”)
- Natural Gas Industry Admits New Pipelines Aren’t Needed, Natural Resources Defense Council, February 5, 2018. (“a spokesman for Williams, owner of the Transco pipeline, a would-be competitor of ACP, indicated ‘the infrastructure is in place right now to meet the current demand.’”)