Thank you all for taking the time to comment about the air permit for the proposed Buckingham compressor station [BCS]. Below is information on who, where to send comments, and background information, questions, concerns and guidelines that we suggest for best impact. You can send more than 1 comment. You don’t have to live in Virginia to comment,
UPDATE: the comment period has been extended to September 21, [August 8- September 21]. We believe this is thanks to our request to have a hard copy of the air permit at the Buckingham Public Library, which did not show up until August 24.
All questions about the proposed compressor station should be considered together. This process is fragmented; does not look at the whole relevant picture. Please scroll for updates to this post, comments from David Sligh, Wild VA on what the agency’s legal obligations are to us. Also, videos of the public hearing on September 11 have been added to this post below.
In your comments, please:
1] First and foremost, ask for a 30 day extension of the comment period [update: the 11 days extension is not enough]. Below is a letter of immediate requests sent to David Paylor, head of DEQ, on August 24.
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. Please consider starting simply by identifying one question you want answered…as much as possible with technical relevance. Please use the rich resources immediately below to inform you.
Please do look at this excellent list of questions. This includes comments from the Southern Environmental Law Center, [SELC]. Gratitude goes to a collaboration of contributors.
Critical Unanswered Questions about ACP/Dominion Energy’s Union Hill Compressor Station. For four years, we have tried to get state agencies to answer key questions: here are 106 unanswered questions. Deep thanks to a collaboration of contributors.
Buckingham Compressor Station Questions We Need Answered (1) 9-2018
Comments regarding the air quality permit from the VDEQ State Air Pollution Control Board for an Atlantic Coast Pipeline Compressor Station, by Larysa Dyrszka, MD, August 28, 2018.
Dyrszka air permit comments 08-27-2018 (1) 32 pages, 1.1 MB
Send comments to: [and cc all]
Let DEQ know the urgency of the need for information, with a deadline looming. This backs up Chad’s request for more time [see letter below] 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.
FoB Letter sent to DEQ:
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
Please reply to: email@example.com
571 Woods Rd
Buckingham, Va 23921
434 806 6332
UPDATE: DEQ and APCB have a legal obligation to consider a wider array of input than they initially informed us.
Important excerpt from David Sligh’s blog at Wild Virginia
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: [from Code of Virginia § 10.1-1307.E.]
- 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.
Read more at: David Sligh’s blog at Wild Virginia
The various air permit documents are here:
ACP May 25, 2018 Updated BCS Permit Application 171 pages, 14 MB
ACP Buckingham-Response to VADEQ Data Request 06252018 40 pages, 2.4 MB
ACP – Buckingham Compressor Station – Air Modeling Report 07-10-2018 85 pages, 8.2 MB
BCS Engineering Review Buckingham Air Permit August 2018 14 pages, 393 KB
Many Ways to Comment:
When: Tuesday, Sept 11, 5-9:30 PM***
Where: Buckingham County Middle School
1184 High School Road, Buckingham, VA 23921
(off of Hwy 60/West James Anderson Hwy)
Join Union Hill and Buckingham residents to pack the room at the ACP Buckingham Compressor Station Air Permit Public Hearing! On September 11th tell DEQ NO COMPRESSOR STATION! NO PIPELINE!
*** Arrive at 4 PM for Circle of Protection vigil, music, snacks, press conference and materials to help you draft your comment. The sooner you arrive to sign up to comment the better! Our Air, Our Lives!
Go to the DEQ site for the details of how to comment, addresses, schedules, etc.
Comments can be mailed to:
Virginia Department of Environmental Quality
Piedmont Regional Office
Buckingham Compressor Station
4949-A Cox Rd
Glen Allen, VA 23060
or submitted by email to:
You can cc:
Remember: You can send more than 1 comment. You don’t have to live in Virginia to comment, but making it relevant is helpful.
Videos from the public hearing on September 11 at the Buckingham Middle School
From David Martin:
David Neal, SELC about at 47:30 min
From Kay Ferguson, Artivism Water is Life. Protect it. Our Air Our Lives: We shall not be moved
Further questions? Please send to: firstname.lastname@example.org