Pipelines and “Environmental Justice”

“Environmental Justice” has been a much bigger rallying cry in the pipeline controversies out west than here in Virginia.

As I was perusing the federal court ruling on the Sierra Club vs. FERC lawsuit (see previous post), I encountered a realm of administrative law with which I was entirely unfamiliar: environmental justice. I’d heard of the concept, of course; I just didn’t realize that it had insinuated itself into environmental impact statements (EISs) for pipelines, transmission lines, and the like.

The majority opinion explained the relevance of the concept this way: “The principle of environmental justice encourages agencies to consider whether the projects they sanction will have a ‘disproportionately high and adverse’ impact on low-income and predominantly minority communities.”

In this particular instance, involving the EIS for the Southeast Markets Pipeline Project, the Sierra Club argued that FERC had failed to adequately take the principle into account. According to the EIS, 83.7% of the pipeline complex’s proposed routes would cross through, or within one mile of, environmental-justice communities.

However, an adverse impact on a minority/low-income community is not necessarily a deal killer. FERC, the court opined, simply must “take a hard look” at the effect on minority/low income areas when drafting an environmental impact statement, and disclose relevant information to the public. And that the commission did. FERC concluded that feasible alternative routes would affect a comparable percentage of environmental-justice populations, the court said. “FERC’s decision to directly compare the proposed alternatives to one another, rather than to some broader population, was reasonable under the circumstances.”

“Environmental justice” has been a rallying cry out west, most prominently in the Dakota Access Pipeline controversy. We don’t hear much of it in Virginia, but I was curious: How does the proposed Atlantic Coast Pipeline rate according to environmental justice criteria?

Here are the numbers, as extracted from the ACP environmental impact statement: In Virginia the percentage of minorities census tracts within one mile of the ACP pipeline and related facilities varies from 0.2% to 100%. In ten of the 63 census tracts, the percentage of minority population is meaningfully greater than that of the county in which it is located. But in 53 tracts, it is not. In other words, it appears that minorities are less impacted than whites.

Likewise, 11.5% of all Virginians live below the poverty line. Thirty-four of 63 census tracts in Virginia within a one-mile radius of ACP facilities have a higher percentage of persons living below the poverty line. In other words, despite the fact that pipelines don’t run through urban areas and suburbs where incomes tend to be highest, but through rural areas where incomes are lower, only 54% of the census tracts affected by the pipeline have a higher poverty rate.

The primary adverse impacts on environmental-justice communities would be temporary increases in dust, noise and traffic from construction work. But, according to the ACP environmental impact statement, “these impacts would occur along the entire pipeline route and in areas with a variety of socio-economic backgrounds.”

These numbers undoubtedly explain why pipeline opponents have not made environmental justice an issue here in Virginia.

It’s not as if the engineers working for Dominion Energy, the managing partner of the pipeline, were especially socially conscious. Rather, in selecting a route, they were threading the needle between national parks, the Appalachian Trail, conservation easements, and other environmental, historical and cultural assets, any one of which could have spiked the project. That the pipeline had so little impact on minorities and low-income Virginians was the luck of the draw.

Sometimes infrastructure projects like highways, natural gas pipelines and electric transmission lines will disproportionately affect minorities and the poor, as it happened with the Southeast Markets Pipeline Project, and sometimes they won’t. Route selection is driven mainly by geography, terrain, market considerations, and economics; the socioeconomic impact is incidental and random.

For all practical purposes, the closest thing to a social-justice issue in Virginia is landowner rights — justice for the propertied class. Are landowners getting fair compensation for the loss of value to their land? That’s a fair question, but if it doesn’t affect the poor and minorities disproportionately, it’s not a matter of “social justice.”

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18 responses to “Pipelines and “Environmental Justice”

  1. The key word is “community”, no aggregate numbers.

    consider how the path of I-95 through Richmond was done..

    There has been an abundant history of things like power plants, sewage treatment plants, and other high impact infrastructure including roads being sited where there is less chance for effective, well-financed opposition.

    or how a proposed powerline in NoVa is opposed vociferously by folks with high dollar homes.. which then drives the utility to look for routes with less effective opposition…

    But the thing about EIS is that it’s not a process where something that is damaged by a proposal stops the project – the main purpose of the EIS law is to FORCE the information about what will be impacted to be documented – as opposed to not acknowledging it at all.. just pretend something is not there or not impacted.. which is what motivated that law to be passed ..

    it only forces the applicant to document and consider.. you can a terrible impact but it’s allowed as long as it was considered and there are no other less damaging , less expensive, etc routes available…

    and what typically happens that allows the SC and other opportunities in court is simple stuff.. that the impacts were not documented/not considered.. which if you think about it is pretty dumb.. but applicants do it all the time in hopes that the opposition cannot really sustain a legal challenge.

    as time has gone by – the EIS law has been the target of industry and legislative and POTUS in recent years.. with TRUMP making clear he’s going to undermine it even more if he can..

    • “opposed vociferously by folks with high dollar homes.. which then drives the utility to look for routes with less effective opposition…”

      Easy Killer, don’t believe everything you read in the papers (or on Bacon’s Rebellion). All of the routes were vociferously opposed by folks with high dollar homes, middle dollar homes, low dollar homes and pop up campers somewhere out on the back 40. That a particular “affluent” neighborhood (which is not particularly affluent in that zip code drove Dominion to move the route to a less affluent one is a myth (in truth the Carver community has higher average values), one created and fostered by Domnion as part of their strategy of subterfuge and misinformation to drive the final route back to I-66 option, just not the hybrid option.

      • is that like NIMBY with a noble cause against the big bad, lying their butt off..Dominion?

        i’m familiar with the proposed powerline all heck breaks lose along it’s path.. conundrum… it kinda works the same way.. whoever shouts the least.. loses.. right?

        • I would generally agree with you but not in this particular case as the NIMBY defense does not apply to a singular neighborhood but rather an area of roughly 60 square miles encompassing dozens of neighborhoods and more than ten proposed routes.

          Most of the residents, regardless of where they lie within that area, understand that the final route isn’t the final route until the first towere is actually erected and that until that point in time, no one is safe from any of the proposed routes, SCC final order be damned.

          Dominion didn’t bother to check the demographics of the region and as a result didn’t just whack a hornets’ nest but did so inside a dark closet.

          Despite Dominion’s best efforts, the residents have remained strong in their position that its the hybrid option or no option. In response, Dominion has equivocated, blame-shifted, intimidated and outright lied, getting caught and cataloged at every turn.

          The somewhat unusual twist is that the County is now openly supporting the residents’ efforts (after some early missteps attributed to the now former pinhead County CXO) both directly and financially.

          The manner in which this drama has played out (Dominion is now two years behind schedule and counting) and the likelihood that this will ultimately be heard before the Supreme Court has Dominion (and I suspect the three SCC judges) in a near panic.

          I would wager you lunch and a frosty beverage that this won’t be over until the Supreme Court issues a landmark precedent, one that neither Dominion nor the SCC will find palatable.

          Dominion’s institutional arrogance finally caught up to them as they finally picked on an area loaded with organized, ill-tempered A-type personalities well-versed in the workings of governments at all levels and tenacious enough to see this through to the bitter end. Some are actually enjoying the ride.

          • trying to understand how this really differs much from other powerline proposals.. is Dominion doing something fundamentally wrong in their process or is it that people don’t like the way that Dominion does things in general and especially so when it affects them?

            I would not expect the court to actually intervene in what route… but rather what process Dominion is following.. no ?

            As you know.. I’m no fan of Dominion.. I agree they are arrogant and “my way or the highway” in how they conduct themselves whether it’s pipelines or powerlines over the James.. but at the end of the day – they do have some fairly significant power and authority to decide where they need more power and more infrastructure to support it which I assume is actually needed rather than they just randomly picking neighborhoods to crap on just for the fun of it.. the courts normally don’t choose paths.. they either accept that the principal proposing it knows their business .. and did not violate a law or rule.. in carrying it forward.. no?

          • Joker as a personal icon.

            “Easy Killer, don’t believe everything you read in the papers (or on Bacon’s Rebellion).”

            “The somewhat unusual twist is that the County is now openly supporting the residents’ efforts (after some early missteps attributed to the now former pinhead County CXO) both directly and financially.”

            “I would wager you lunch and a frosty beverage … ”

            Damn it, Mom … where the hell have you been? Since you left the comments on this blog have been nothing short of digital Ambien.

            Don’t be a stranger, Mom.

  2. You need to look at the submissions of Lakshmi Fjord. The social justice impact of the ACP is strongly contested. The data used in the EIS underplay the situation and thus the report ignores social justice.

    The worst part is that for the Buckingham Compressor Station the ACP bought the former “plantation house” property from white absentee owners for a huge sum of money. However, the direct descendants of the freed slaves who obtained their land and have passed it down, live in the properties immediately surrounding the compressor station. The large majority of people living around the site are African American and many are also elderly and living on limited incomes (the EIS does not include that subgroup). There are also far more people living in that area than the data used reflect.

    Pastor Paul Wilson, who leads the two historic African American churches immediately near the compressor station can give you even more information. Those who “only” live next to the compressor station are not going to get any money from an easement. However, they are the ones will will have the most exposure to the toxic pollution from the compressor station. Their properties have already lost significant value, as shown by the one that was immediately sold by a family that chose to leave when the project was announced. These people are not compensated at all!!!

    This information was submitted to the record, however FERC did not address it in the EIS. It would be very hard to have a more significant social justice situation than the one at Union Hill where the compressor station is sited.

    When you compare the data for the affected communities with Virginia as a whole, lower income of all races, minority and older people are disproportionately affected. However, the EIS and other documents ignore that fact.

  3. Historically landfills, heavy industry, and other undesirable developments have been unfairly sited in poorer areas. And of course for business reasons of maximizing profits, normally the landfills take in enormous amounts of waste from large regions of the Country. So this is where the concept of environmental justice traditionally comes into play.

    The Golden Rule should apply, in that we should make facilities as clean, safe, and of a scale of size that would be acceptable anywhere. Examples of environmental injustice in my past (NJ), if a power plant was to be constructed in North Jersey, it would be ultra clean, modern, zero pollution natural gas, whereas South Jersey got the coal and nuclear plants.

    I have a little trouble seeing where the concept fits into pipeline construction, but it should be a consideration.

  4. How does the placement of Wind and Solar Farms fit within the matrix of these laws of Environmental Justice?

    • The EIS law usually only applies to govt agencies.. or projects that need permits approved by govt agencies not the private sector..

      visual impacts are the lowest level of impact.. impacts have to be material and measureable.. like DBs on a noise meter.. or air pollution.. etc

      this is how you can have a business wipe out a historic site.. but not a Federal or state agency.. or a business that needs Federal or State permits.

  5. What has become relatively apparent is that Dominion has upped their game and not in a good way. Not content with arrogance and intimidation, Dominion has added a new tactic.

    If one looks at the Waxpool and Cannon Branch applications which are very similar to the Haymarket application, one will find that each has as its a basis a request for a block load of power in the form of a commitment letter from a data center to Dominion. Dominion then ascribes an immediate need to the block load and buldozes it way to construction of the transmission line on the backs of the ratepayers, purporting ancillary benefits in the form of additional reliability, redundancy, economic development, etc. that otherwise would not support initiation of the project. Following along so far.

    Then, when the projects are complete and the ratepayers are saddled with the construction costs as well as the environmental and aesthetic impacts, the data centers don’t deliver on their commitments leaving transmission lines without their purported immediate needs in their wake.

    As a cynical SOB, I would suggest that Dominion is using or colluding with the Data Centers to expand their infrastructure with projects that otherwise wouldn’t pass muster, while protecting its bottom line by passing all costs on to the ratepayers. Of course for this to work for Dominion it requires a complicit or incompetent lot of SCC Judges, but that is a topic for another day.

    • “Of course for this to work for Dominion it requires a complicit or incompetent lot of SCC Judges, but that is a topic for another day.”

      Let’s see … The Imperial Clown Show in Richmond rakes in money from Dominion and then elects the SCC Commissioners who regulate Dominion. To nobody’s surprise those commissioners mollycoddle Dominion so that the circle of graft can continue. The commissioners serve 6 year terms and my be re-elected (as far as I can tell, indefinitely). Good commissioners who turn a blind regulatory eye to Dominion get re-elected. Commissioners who actually try to regulate in the interests of the ratepayers are “one and done”.

      • You forgot that in order to be eligible for an appointment by the Imperial Clown Show, one must demonstrate a proven relationship with Dominion, see Judge Christie, former Dominion legal counsel on such regulatory matters.

  6. well yes… but isn’t this essentially the same tactic with the pipeline and powerlines across the James.. more power plants.., etc?

    I’ve yet to see them stopped so far….

  7. yes, very interesting and apparently not the same examiner for the James River crossing:

    ““This case boils down to a determination of whether the added cost of an underground option is reasonable in light of the impact of the proposed 115 kV overhead route would have on the viewshed, economic development and public safety,” he wrote.”

    thanks for the link!

  8. Thank you for raising the omission of environmental justice from critiques and filings made during the Atlantic Coast Pipeline process. We have been doing so and been completely ignored throughout the filing process by our state government, FERC, and now VDEQ. It has been exceptionally difficult to get public and media attention to focus on the location chosen by Atlantic for the only Virginia compressor station, a mega-sized one in an historic, majority African American community of Union Hill, Buckingham County, VA. I attach below the relevant portions of my VA DEQ 401 water permit comment of August 22, 2017, to exemplify the grave EJ problem and total lack of response by everyone involved to date.

    Re: Comments on Draft 401 Water Quality Certification (No. 17-002) for Construction and Operation of the Atlantic Coast Pipeline
    On behalf of residents of the county of Buckingham Virginia, in particular, Union Hill, a majority African American historic former slave and Freedmen community into the center of which Atlantic plans to locate the only Virginia compressor station (CS 2), I respectfully submit the following comments on draft Certification No. 17-002, the draft section 401 water quality certification for construction and operation of the Atlantic Coast Pipeline. I comment as a Friends of Buckingham Steering Committee member and anthropologist whose specialization is the public health and environmental justice impacts of human-made disasters and their prevention, such as the potential harmful impacts on Union Hill posed by the location of Virginia’s only ACP compressor station. Specifically, these 401 comments point to fracked gas infrastructure’s known and publicly documented vulnerabilities to major leaks and breaks, with the potential for large-scale public health harms to Union Hill’s drinking water, surface water, nearby rivers and streams, as well as a wetlands area lying close to the proposed engine houses of the CS 2 facility site in an environmental justice community. I urge the Department of Environmental Quality (DEQ) to recommend denial of the Clean Water Act Section 401 Water Quality Certification to the State Water Control Board for the Atlantic Coast Pipeline (ACP).

    The Southern Environmental Law Center (SELC) represents Friends of Buckingham in public comments, to increase public awareness that people of Union Hill now face unjust and disproportionate burdens of hazardous risks and harms from planned 24/7 365 emissions of environmental pollutants, certain methane leaks, and all-too-frequent ‘accidental’ blow-downs. At Union Hill, designated by Atlantic as “CS 2,” the existing 4-pipeline Transco Corridor would intersect below ground with the proposed 2-pipeline ACP; 14 gas fired turbines would be pressurized to highest allowed pressure to transmit fracked gas 200 miles in each direction; with 2 underground and 1 above ground storage tanks and a gas metering station. No where else on the ACP would such a complex of fracked gas infrastructure exist.

    I. Atlantic’s 401 water permit application unjustly and disproportionately burdens an environmental justice community with ACP’s highest per capita risks to drinking water.

    The U.S. public recently learned about the drinking water contamination scandal of Flint, Michigan, where state and local government made disastrous decisions about the sources of drinking water that most harmed the city’s poorest, most often minority residents. Similarly, we argue, the combined and cumulative hazards of exposure to 6 fracked gas pipelines and their transmission, pressurizing engines, and storage infrastructure at Virginia’s ACP CS unjustly burdens Union Hill residents with the highest per capita ACP risks to a single community. This infrastructure taken together geometrically raises the risk of contamination of Union Hill’s sole water source individual wells, surface water streams and rivers, including the wetlands on the CS 2 site.

    FERC’s EIS reports “Union Hill is an environmental justice community.” This is correct according to a recent door-to-door household study that I designed, oversaw and analyzed the data, in which we found Union Hill to be both 85% African American and the majority living below the poverty line in an impoverished Virginia county. Yet, FERC asks nothing of Atlantic to address this breach of the National Environmental Policy Act (NEPA). Over one-third of Union Hill residents are known descendants of slaves enslaved either nearby in Buckingham County or at the proposed CS site, part of the former Variety Shade plantation that Atlantic purchased for Virginia’s ACP Compressor Station.

    In Atlantic’s application filings and FERC’s DEIS and EIS, the cultural resources, the slave plantation and Freedmen history of Union Hill, are completely erased. Unlike for every other Virginia county, where Atlantic reports pages and pages of historic records and cultural resources, for Union Hill there was zero, as for Buckingham County in general. This follows a long history in Buckingham County and elsewhere in the South to erase or whitewash the history of slavery – vigilantes burned the Buckingham Courthouse by arson on the day the 15th amendment passed in 1869, giving former slaves the right to vote. The intent was to destroy the legal records of enslavement in wills, in bills of purchase of their freedom from named former masters, as the then black population was over twice the number of whites. In Buckingham now, there have been reprisals against African Americans speaking out in public hearings against the ACP Virginia compressor station location in Union Hill.

    Since the recent violent and racist events of August 12th in Charlottesville, Virginians ask ourselves: how and where does racism manifest itself here in present day social systems and institutions? I would argue that from a civil rights and human rights perspective, it is environmental racism in action for the ACP to locate the only Virginia mega-compressor station in an historic Freedmen community, on the grounds of a former slave plantation. And, it is environmental racism akin to that of the state and local officials in Flint, Michigan to lay the greatest burden of harm from contaminated drinking water on people of color who are poor.

    Actual population numbers of Union Hill residents and family visitors found in our door-to-door household study data (details below) heighten concerns about public health drinking water disasters such as occurred in Flint, which The Safe Water Drinking Act (SWDA) is meant to address. Under which “each state is required to develop and implement a Wellhead Protection Program to identify the land and recharge areas contributing to public supply wells and prevent the contamination of drinking water supplies” (ACP FEIS, 4-78).

    VDEQ in its 401 water permit certification process needs to address the fact that the sole water source for 100% of Union Hill households is from individual residential wells, as it is in Buckingham County generally. According to EPA, a “sole source aquifer” is defined as “one that supplies at least 50% of the drinking water consumed in the area underlying the aquifer, where contamination of the aquifer could create a significant hazard to public health; and where there are no alternate water sources that could reasonably be expected to replace the water supplied by the aquifer” (EPA, 2016 in FEIS, 4-78).

    Nowhere in Atlantic’s filings or FERC’s FEIS is this sole water source information about the Virginia compressor station’s community made public. This omission alone constitutes grounds for VDEQ to reject Atlantic’s water permit application as woefully incomplete at best, if not erroneous to the point of reckless and endangering at worst.

    Further, why is the wetlands area located close to the engine houses as shown on Atlantic’s site drawing for the Union Hill compressor station not mentioned at all in Atlantic’s application or FERC’s FEIS for prevention efforts? Yet, it plainly exists, even in ACP’s own rendering. I urge VDEQ to raise alarm bells about the erasure of this wetlands from ACP’s compressor station construction plans. This is the only rational, scientific, and public health invested response to the unfolding disasters of wetlands destruction from the Rover Pipeline’s egregious water-body violations before it is even fully on-line and operational. As Atlantic claims for the ACP and MVP, Energy Transfer Partners (ETP) claimed they would construct Rover using “best in class” technologies and expertise. Now, Rover has already destroyed vital surface water natural resources in Ohio leading to a stop action (see https://www.usnews.com/news/best-states/ohio/articles/2017-04-20/pipeline-firm-cited-for-2m-gallon-spill-of-drilling-mud).

    Bringing water violations by purported pipeline construction “experts” closer to home, a report from West Virginia on ETP’s continuous string of water violations exemplifies exactly why VDEQ needs to watch and learn what not to do when fracked gas transmission developers pressure state DEQs in their haste for the higher returns of interstate gas transmission, yet without proper capabilities to deliver on, vague now known to be unfounded claims of “highest” expertise. “Just weeks after ordering a temporary halt to construction of part of the Rover Pipeline in Doddridge County, West Virginia inspectors discovered more water pollution violations at Rover construction operations in two other counties, according to records obtained under the state Freedom of Information Act. . . .
    Department of Environmental Protection inspectors found the violations of state water quality rules at Rover construction sites in Hancock and Marshall counties and issued a notice of violation at each site, according to the records. DEP inspection reports indicate the agency found that some erosion control devices were not in place, that other sediment controls were incorrectly installed, and that mud and dirt from the pipeline work had left the construction sites and entered streams, in violation of West Virginia water quality standards. The company had not reseeded some areas where seeding had failed to germinate adequately, the DEP found” (see Charleston Gazette:
    http://www.wvgazettemail.com/news/20170819/more-water-violations-found-on-rover-pipeline-construction-sites ).

    Because lawsuits will follow these violations, would it not be best for VDEQ to reject the ACP draft 401 water permit for being woefully lacking in necessary details for exactly how and with what skilled workers, construction materials and plans, with which detailed plans for preventive measures in place, Atlantic will prevent such disastrous impacts all along its 600 mile route through steep slopes, under the seasonally flooding James River between Buckingham and Nelson counties, for just two key examples?

    II. Erroneous if not reckless minimization of Union Hill population serves Atlantic’s economic benefit; relevance to 401 water permit issues

    Atlantic, FERC and the VA DEQ have all failed to acknowledge that the proposed Virginia ACP compressor station site is as densely populated as many suburban towns, not sparsely populated as Atlantic claims in its application documents and FERC in its FEIS. Atlantic claims and FERC accepts that the location for proposed CS 2 has the same population as Buckingham’s census averaged – 29.6 people per square mile. Ignoring the statistics on actual community numbers filed by SELC and myself in our DEIS comments, FERC hands Atlantic an enormous economic advantage.

    By claims that Union Hill is “rural,” sparsely populated, Atlantic will save a considerable amount of money on construction costs within the pipeline classification system based on population density (urban-centric, as it gives highest protection to places with buildings of 4 or more stories). Rural density classification allows Atlantic to use thinner walled pipes with greatest distances allowed between shut-off valves. Factual population density of Union Hill would require the use of Class 3 or Class 4 pipes with closer valve distances, and alert VDEQ to the higher levels of risk to greater numbers of people’s water and health from living in close proximity to Virginia’s ACP compressor station. Do the scientists of VDEQ know if rural classifications and their construction materials play any role as contributory causes of the growing number of disastrous fracked gas spills from the Rover in Ohio and West Virginia?

    To counter the total omission of required cultural resource reports and to correct the erasures of Union Hill’s community and population in Atlantic’s original ACP applications, including CS 2, we undertook a door-to-door household study of every residence in a 1 mile radius of the CS site. All of this area is within the community of Union Hill, which extends even further. The study goal was to uncover number of households, persons resident, self-identified race(s), ages, family histories in this community as slaves and Freedmen, and existing health conditions known to be exacerbated by the toxic emissions, VOCs and particulate matter applied for in Atlantic’s VDEQ air permit for Union Hill’s proposed compressor station. Our study data was arrived at by following HIPA protocols and NIH research integrity standards.

    Our study teams reached residents in 63 of the 99 households in a 1-mile radius. For this 66% of total households, we found 158 resident persons living between 150 ft. to 1 mile of the 68-acre facility. With just two-thirds canvassed, Union Hill’s population is 500% higher than reported by Atlantic and FERC in public filings. FERC did not address this true population data in their FEIS — although SELC and I had separately filed this data and other relevant Union Hill demographic data in our DEIS comments. We know FERC read both comments because the FEIS responded to our cultural report questions. Additional population data we included in DEIS comments were members of congregations of the two African American churches within 1 mile radius – Union Hill Baptist formed in 1868 (.5 miles from CS 2), and Union Grove Missionary Baptist (1 mile) formed in the 1920s, with combined congregations of over 250 members; the Red Oak Hunt Club (.3 mile from CS facility, 50 members). Thus, bi-weekly and bi-monthly gatherings, along with once-yearly enormous Freedmen family reunions increase the numbers of potentially impacted African American persons from Union Hill’s close proximity to CS 2 far higher still.

    Atlantic applied for a “minor source air permit to VDEQ. Atlantic cited the “higher than normal ambient air quality” of this site for why they should be allowed to emit toxic pollution up to the highest thresholds, particularly of NO2. Do the scientists of VDEQ know the effects on aquifers used for wells, on surface water, rivers and streams, and wetlands of these toxic air emissions and the large projected amounts of fine particulate matter that surely will rain down on surface water and enter aquifers?

    To my VDEQ comment, I attached maps of the 3 roads that closely surround the proposed VA ACP compressor station triangle on all sides. Dots for each household mapped in place tell a stark tale of potential devastating public health impacts with a population not only primarily African American but also at higher than average older ages and also the very young. This has been a place that young African American families who have had to commute long distances to good jobs often leave their youngest in the care of grandparents and great grandparents during the week. These maps reveal how densely clustered are households on every side.

    Even the gas industry recognizes the obvious problems with such a CS location. Best practices for siting even small compressors stations 1/7th the size of ACP’s proposed Union Hill compressor station were mentioned in a study promoted by FERC in its FEIS, conducted by the National Fuel Gas Supply Corporation. “Identified commonalities” in all seven New York State places with small compressor stations were their sites “on large land parcels and set back from the road; natural and constructed buffers were utilized; and compressor station sites were generally in rural areas removed from higher density development.”

    We in Buckingham County ask the VDEQ and Water Control Board’s water pollution scientists and public heath prevention experts to closely examine why Atlantic’s ACP business model, which requires the ACP to intersect at Union Hill with the existing 4-pipeline Transco corridor, should over-ride considerations related to public health, safety, and population density that have guided compressor station siting for decades? Oughtn’t VDEQ follow NEPA guidelines to stop building new toxic emitting infrastructure in minority and poor communities? Instead, Atlantic sites Virginia’s sole very large compressor station in a populous, environmental justice community, facing its facility on a major road that bisects Union Hill.
    Thank you,
    Lakshmi Fjord, Ph.D.

    • Just a couple of questions. Is the term “environmental justice community” defined somewhere in a statute or regulation? I’ve read quite a bit about environmental justice cases, but have not heard the term “environmental justice community.” When was it defined? And by which federal agency?

      Thank you.

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