Emergency Letter to Paylor on Air Board

Chesapeake Climate Action Network announced this extraordinary emergency note from justice and environmental groups that was delivered to David Paylor and Governor Northam’s staff on December 18, 2018, asking DEQ director David Paylor to recommend that the State Air Board reject the draft permit for the Buckingham compressor station.

December 18, 2018

David K. Paylor
Director, Department of Environmental Quality
P.O. Box 1105
Richmond, VA 23218
David.Paylor@deq.virginia.gov

Dear Mr. Paylor:

Given that state regulators have just rejected Dominion Energy’s forecast for future energy use in Virginia, Dominion’s justification for the need for the Atlantic Coast Pipeline (“ACP”) and the related Buckingham County compressor station has fallen apart. As a result, we the undersigned groups call on the Virginia Department of Environmental Quality (“DEQ”) to inform the Air Pollution Control Board of recent regulatory developments and advise the Board to reject approval of the Draft Permit for the compressor station.

For the first time in Virginia’s history, state utility regulators have rejected Dominion Energy’s long-term energy plan. In an Order issued December 7, 2018, the State Corporation Commission (“SCC”) expressed “considerable doubt regarding the accuracy and reasonableness of the Company’s load forecast for use to predict future energy and peak load requirements.” This load forecast has provided the justification for Dominion Energy’s plans to build the highly controversial, $7-billion ACP. Dominion has argued to regulators that the natural gas pipeline is necessary to meet the commonwealth’s growing demand for power. With the SCC’s rejection of Dominion’s “overstated” load forecasts, this justification completely falls apart.

The Virginia Air Pollution Control Board is preparing to take action on a Draft Permit for the Buckingham Compressor Station, Registration Number 21599, on December 19, 2018. The proposed Buckingham Compressor Station is one of three that would provide compression of natural gas along the proposed 600-mile ACP and the only compressor station in Virginia. As part of its review of the Draft Permit, the Air Pollution Control Board shall consider “facts and circumstances relevant to the reasonableness of the activity involved . . . including . . . [t]he social and economic value of the activity involved.” This statutory mandate requires the Air Board to consider the need for the ACP as a whole. If the ACP is unnecessary based on lack of future energy demand, as indicated by the recent SCC Order, then so too is the Buckingham Compressor Station.

Based on the SCC’s Order rejecting Dominion Energy’s overstated load forecasts (which was issued after the close of the public comment period), coupled with our well-documented concerns about the environmental justice, climate, ecological, and public health impacts of the compressor station, the undersigned groups call on the Virginia Department of Environmental Quality to immediately take the corrective steps outlined above.

Sincerely,

Harrison Wallace, Virginia Director, Chesapeake Climate Action Network
Kate Addleson, Director, State Chapter Virginia Sierra Club
Peter Anderson, Virginia Program Manager, Appalachian Voices
David Sligh, Conservation Director, Wild Virginia
Joni Grady, Chair of CAAV, Climate Action Alliance of the Valley
Mindy Zlotnick, Buckingham: We the People
Rev. Siva Moore, Executive Director, Satchidananda-Ashram Yogaville
Lorne Stockman, Senior Research Analyst, Oil Change International
Del McWhorter, State Governing Board Chairperson, Virginia Organizing
Eleanor Amidon, Pipeline Education Group
Betsy Nicholas, Executive Director, Waterkeepers Chesapeake
April Pierson-Keating, Mountain Lakes Preservation Alliance
Helen Kimble, President, Friends of Nelson
Chad Oba, Chair, Friends of Buckingham

cc: Governor Ralph Northam
Michael Dowd, Director of Air Division, Virginia Department of Environmental Quality