Category Archives: DEQ

Hurricane Could Devastate Pipeline Projects

A September 11, 2018 Washington Post article, Hurricane could devastate Virginia pipeline project that is already struggling with changing weather, points out that the wet summer of 2018 “has already overcome some efforts to prevent runoff and erosion” along then Mountain Valley Pipeline route, and the Atlantic Coast Pipeline will face similar problems if construction begins on that.

State officials say that even if the projects meet all construction guidelines, “those guidelines are based on standards that do not account for recent changes in weather patterns. …. In some cases, a level of rain that once may have occurred every two years has instead happened more than once in a month, staff members said. ‘There have certainly been conversations that given precipitation and climatic changes that . . . maybe there should be a different standard, but at this moment that’s what your regulation says,’ Melanie Davenport, the director of water permitting, told the [State Water Control] board.”

Department of Environmental Quality officials, their numbers reduced after a decade of budget and staff cuts, are unable to monitor the construction properly, especially given the steep and rough terrain and the many stream crossings of both the MVP and ACP.

Erosion controls have already proved inadequate for current levels of rainfall, and pipeline zones could be devastated by Florence. David Sligh, who is retired from the Virginia Department of Environmental Quality and now works with the Wild Virginia advocacy group, spoke to the Post: “‘I don’t believe they can, in some of these circumstances, do anything that would be adequate,’ he said. ‘That’s the real crime here, if I can use that word. People have known, the companies have known, DEQ has known that the pollution control measures are inadequate. The fact they’ve been allowed to go forward makes me very angry.'”

In the Neighborhood


A video about the neighborhood around the proposed compressor station.

Weigh in as Virginia officials consider the Atlantic Coast Pipeline compressor station.

Let the Virginia Air Board know that compressor stations like the one Dominion is planning for Union Hill pose health risks for neighbors and pollute the surrounding community’s air.

How to comment?  Go here.

Challenge the Compressor Station Air Permit


Send your comments to DEQ to challenge the air permit for the proposed ACP compressor station in Union Hill by September 11, 2018. Help deny the air permit for the ACP Compressor Station that would endanger and diminish the health and land values of all residents of Buckingham County and destroy the lives of the historic African American community of Union Hill. No compressor station = No ACP.  To comment, follow instructions on the Friends of Buckingham page.

The Department of Environmental Quality Public Hearing on the draft air permit for the proposed Atlantic Coast Pipeline Compressor Station will be Tuesday September 11, 2018, from 5:00 pm to 9:30 pm.

After you have sent your written comments to DEQ, please come to the September 11 public hearing and pre-hearing vigil It will be at the Buckingham County Middle School, 1184 High School Rd, Buckingham, VA 23921 (off of Hwy 60/West James Anderson Hwy).  Arrive at 4 PM to sign up to speak, and for vigil, music, snacks, press conference and materials to help you draft your comment. The sooner you arrive to sign up to comment the better!  Comments will be limited to 3 minutes, and, if possible, it would be good to have a written copy of your comments at the hearing to give to DEQ staff.

This compressor station, a giant one, even by industry standards would bring loud constant noise and release toxic poisons into Buckingham’s air and water. The health of children is particularly vulnerable to the methane, formaldehyde, arsenic, benzene, xylene and other compounds the compressor will regularly release. The compressor station would create a fire and explosion hazard completely beyond the capacity of distant volunteer firefighters. The station wold have few staff on site and would be built on a former slave plantation atop the unmarked slave graves of Union Hill ancestors.

Citizen Observers Continue to Document Violations


As construction on the Mountain Valley Pipeline ramps up again (although in some places it never actually ceased, despite the stop work order), citizen observers have and will continue to document the many and ongoing MVP violations of Erosion and Sediment Control Standards specified by the Virginia Department of Environmental Quality and its State Water Control Board.

For example, on-site in the same location that DEQ had recently inspected, the Virginia Pipeline Violations team encountered multiple, extensive mudslides, in some places thick, wet mud nearly a foot deep, washing from the construction area – in the same location where DEQ/MVP inspectors claimed on August 21 that there was no evidence of silt leaving the construction area. Concerned citizens relentlessly demanded that DEQ return, and on August 28 DEQ found violations on this location.

Guidelines for Commenting on Compressor Station Air Quality Permit

Friends of Buckingham has provided the following information on critical unanswered questions about ACP’s Union Hill Compressor Station to supplement your comments to DEQ about the air permit – along with extensive talking points for your letters.  For further information, contact Chad Oba, chado108@icloud.com, or email info@friendsofbuckinghamva.org.


The public comment period currently ends [please ask for an extension – see below] Tuesday, September 11 with a public hearing starting at 5 pm at the Buckingham Middle School.

This process is fragmented. All questions about the proposed compressor station should be considered together, but that is not allowed. In your comments, please:

1] first and foremost, ask for an extension of the comment period. The following is a letter of immediate requests sent on August 24 to David Paylor, head of DEQ.

2] Second important request: The Department of Environmental Quality should immediately complete a Quantified Risk Assessment (QRA) for the Buckingham Compressor Station prior to permitting and to work with other state agencies to conduct a Health Risk Assessment (HRA) and a Health Impact Assessment (HRI).

3] Choose a specific topic to focus on. See below for details.


Letter to David Paylor, sent on August 24, 2018:

A 30-day comment period for the air permit for Union Hill Compressor Station in Buckingham is inadequate:

  • .     We feel that our public process has been severely limited and we should be given every opportunity to comment in an informed and meaningful way that this current comment period does not provide.
  • .        Community members received access to large documents only weeks before the comment period and did not receive any technical support from state agencies. The applicant Dominion Energy Atlantic Coast Pipeline has had many months or even years, due to the failed first application on 2017, to work with their technical experts and to consult with the DEQ Air Division expertise. We deserve equal time.
  • .           The recent informational meeting (August 16) with DEQ Air Division was not sufficient for citizens to grasp the many technical aspects of the application and limited the questions that they were consequently ill prepared to ask.
  • Access to online documents is difficult if not prohibitive. A large population of impacted, elderly residents in the Union Hill/Woods Corner neighborhood do not own or are familiar with internet use. This is compounded by unreliable connectivity problems with the internet. This area of Buckingham lacks rural wifi or broadband infrastructure.
  • The impenetrable language of the hundreds of pages of air permitting documents and air modeling reports that accompany them make them incomprehensible without technical support. We have just recently been able to identify experts who will work with residents and community groups.
  • .     We deserve the right to an extension of the comment period to assure that our concerns for our health and welfare is assessed from all sides. Many residents are not convinced that our health and welfare will be adequately protected by the current modeling, monitoring and compliance, especially so as Dominion’s compliance record has proven to be faulty with other projects. This proposed Compressor Station has as yet been unproven in actual operation.

Therefore we request an additional 30 days for a total comment period of 60 days.

Thanking you in advance for your consideration,

Chad Oba, Friends of Buckingham
Jeeva Abbate, Yogaville Environmental Solutions
Pastor Paul Wilson, Union Hill and Union Grove Baptist Church
Swami Dayananda, Lotus Center for all Faiths
Dr Lakshmi Fjord, People’s Tribunal on Human Rights and Environmental Justice
Heidi Dhivya Berthoud, Buckingham: We the People



Commenters: please consider starting simply by identifying one question you want answered…as much as possible with technical relevance. You can draw from this modified question list but it is important that you have original/unique wording and not cut and paste.

DEQ Questions to use when writing your letter to DEQ about your concerns about the Draft Air Permit 8-26-18

Send it to: [and cc all]

michael.dowd@deq.virginia.gov
patrick.corbett@deq.virginia.gov
airdivision1@deq.virginia.gov

Make sure to let DEQ know the urgency of the need for information, with a deadline looming. This backs up the requests for more time and gets DEQ to answer some questions. Plus we get our questions on the record by submitting to DEQ. The emails you send can be picked up by a FOIA request at some time in the future.


Furthermore…. August 16, 2018, the DEQ provided an informational meeting at the Buckingham Administration Building where we were allowed to ask questions. We generated a list of 107 really good questions, which we sent to the DEQ. A modified list can be viewed here.

DEQ Questions to use when writing your letter to DEQ about your concerns about the Draft Air Permit 8-26-18

Below is the list of public comment areas DEQ air permit staff said they would (maybe) listen to, related to the air permit:

  • Extending 30 days of comment period
  • Inadequate compliance and monitoring plans
  • Lack of access to technical documents (online, hard to read due to technical language and lack of technical support); they said in front of us that they would leave a copy in the local library (did they?)
  • Technical aspects of air permit that they might not have considered
  • Comprehensive impacts
  • Higher radioactivity of Marcellus shale (with convincing evidence)
  • Factors that challenge their assumptions of emissions not being harmful to human health (vulnerably of low income and elderly; pre-existing medical conditions)
  • ADD: Writing daily walk throughs into the permit

Since permitting authority is too narrow and highly fragmented, community concerns fall through the cracks.

So, we demand:

  • An immediate Quantitative Risk Assessment (QRA) and Comprehensive Health Impact Assessment (CHIA) to address the complex and multifaceted concerns presented by residents of Buckingham
  • Institutionalization of Environmental Justice, public safety, and health review before permitting or construction of large-scale infrastructure in minority and low-income communities;
  • Meaningful participation by impacted populations in permitting and monitoring;
  • Evaluation of climate and environmental justice impacts in all state policies, programs, and permits;
  • Reduction of state disparity in exposure by which black and brown communities disproportionately experience harm from toxic air, unsafe water, and public safety risks;
  • Development of clean and renewable energy alternatives

Shout-Out for Pipeline CSI and Mountain Valley Watch

An August 24, 2018, article in ThinkProgress, All-volunteer groups patrol construction of gas pipeline projects in Virginia, North Carolina, explains the background of the all-volunteer groups patrolling pipeline construction projects in West Virginia, Virginia, and North Carolina. The article includes extensive quotes from Rick Webb, David Sligh, and Kirk Bowers. Both Pipeline CSI and Mountain Valley Watch were created to monitor construction of the Atlantic Coast and Mountain Valley Pipelines, with trained volunteers essentially serving as citizen regulatory agencies, since the state regulatory agencies have neither the staff nor the will to monitor the massive projects as needed.

“In some cases, these volunteer monitoring groups have gathered more information on the pipelines’ impact on the environment and private lands than the regulators that are paid to monitor the projects. The mission of these all-volunteer oversight groups is to make sure laws are obeyed and no corners are cut during construction. And if the volunteers do their jobs well enough, they hope to provide enough evidence of violations to force regulators to issue permanent stop-work orders on the projects.”

A trained group of experts are monitoring and documenting problems in water quality, erosion and sedimentation control, and runoff with sound scientific results and “evidence grade” information – information strong enough to use in court. Often the Virginia Department of Environmental Quality has been unable to get in on-site and observe problems, and only knows of violations because citizen observers are in the field doing the work with on-the-ground monitoring and aerial surveys.

“With previous construction projects, inspectors with the Virginia DEQ would, as Webb described, apologetically tell pipeline construction crews that the U.S. Environmental Protection Agency was forcing them to keep close tabs on their work. ‘Everybody blamed the EPA’ for making everyone do extra work, Webb said. With the creation of the Pipeline CSI, ‘they can blame us,’ he noted.”

Information on the Pipeline CSI here.

Information on Mountain Valley Watch here or on Facebook.