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