Tell Virginia DEQ: Send the Lambert Compressor Station permit to the Air Board!

Use the tools below to generate a public comment, ask for the issue to be elevated to the Air Pollution Control Board and learn more about the proposed Lambert Compressor Station, a 27,756-horsepower fossil fuel facility that would emit carbon monoxide, nitrogen oxides and formaldehyde into the air.

Normally, we would create an action for you to sign and send, but for this specific comment period, your unique comment is most effective!

Attend the March 4 Comment Writing Party!

How to Submit Comments:

Send your email to: anita.walthall@deq.virginia.gov (note: if you use this link, your comment will also be shared with Appalachian Voices)

Subject: Mountain Valley Pipeline Lambert Compressor Station Draft Air Permit

Include your name, mailing address and telephone number with your comment. When requesting a public hearing, you must also include:

  1. The reason why a public hearing before the full Air Board is requested.
  2. A brief, informal statement regarding the nature and extent of the interest of the requester or of those represented by the requestor, including how and to what extent such interest would be directly and adversely affected by the permit.
  3. Specific references, where possible, to terms and conditions of the permit with suggested revisions.

Use the sample talking points below to help you write your letter:

Sample talking points:

Lack of information regarding Hazardous Air Pollutants (HAPs)

  • The only hazardous air pollutant that is subject to hourly and yearly emission limits in the draft permit is formaldehyde.
  • There were several other hazardous air pollutants listed during the Environmental Impact Statement process including benzene, toluene and xylenes that can cause adverse health effects but are not listed in this air permit.
  • Factoring in the emission levels of hazardous air pollutants generated by the two Transco compressor stations, the cumulative impact from those and the proposed Lambert facility would be more than 25 tons per year and would require a Clean Air Act Title V major source air pollution permit. MVP assumed this location would be acceptable because they could blend their emissions in with the existing compressor stations. However, the Lambert facility would put the nearby community over the limit in terms of risk of adverse health effects.

Health concerns

  • Formaldehyde in the air can lead to nasal and skin irritation as well as breathing problems. Formaldehyde can also increase complications of existing COPD and asthma. Higher concentrations of it can lead to tumor formation and pulmonary edema.
  • MVP predicts that the Lambert Compressor Station will emit almost 9 pounds of formaldehyde an hour, on top of the background rate of 19 tons/year emitted by the Transco compressor stations 165 and 166.
  • The proposed Lambert station would increase the emissions of particulate matter in the area by almost 30%.
  • The percentage of people over the age of 64 in the nearby community is significantly higher than the state and national average. Older people are more vulnerable to particulate matter pollution, especially with increased rates of cardiorespiratory mortality and hospitalization.
  • Chronic levels of air pollution also can increase the rates of respiratory tract infections such as pneumonia.
  • In the Environmental Impact Statement, MVP projected that the Lambert compressor station would emit over 69 pounds of benzene annually. Acute chronic exposure (0.1 to 0.5 ppm) to benzene can reduce white blood cell counts, which is the most common indicator for leukemia risk.

Environmental Justice concerns

  • The permit’s EJ Screen was conducted by census tract, not the more accurate census block data and therefore, the project’s real impact may be under-estimated.
  • There are serious discrepancies between the information MVP’s consultant provided in the EJ Analysis Report, and what MVP ultimately communicated in its final permit application.
  • Four EJ communities were identified within a 3-5 mile radius of the proposed compressor station site. MVP’s September 2020 revised permit application to DEQ used data from a 1-mile radius only, even though the consultant’s report on MVP accepted screening within a 3-mile radius.
  • There are serious and significant discrepancies between the information provided in the EJ Analysis Report conducted for MVP, and what MVP ultimately communicated in their final version of the permit application.

Noise pollution concerns

  • MVP has applied to have weekly startups and shutdowns for both the station’s turbines, which would result in 208 events per year. Each event would create spikes in air pollution emissions, as well as significant noise impacts.
  • It is unclear how MVP plans to coordinate with the two existing Transco compressor stations in order to stagger these events so as to reduce the amount of air and noise pollution and harm on nearby communities.

Cumulative Impact Concerns

  • DEQ should take cumulative impacts and existing levels of air pollution into consideration when evaluating the suitability of the proposed location for the Lambert Compressor Station.
  • If this facility were to be built next to the two existing Transco compressor stations, the combined emissions would be equivalent to a Clean Air Act Title V air polluting facility for carbon monoxide, nitrogen oxides, volatile organic compounds and potentially hazardous air pollutants.
Title V Combined Emissions(tons/year) Transco 165/166(tons/year) Lambert (Air Permit)
NOx yes 628.91 616.85 12.06
CO yes 408.5 391.48 17.02
VOC yes 112.358 109.48 2.878
PM 45.98 35.97 10.01
PM 10 45.98 35.97 10.01
PM 2.5 46.418 35.97 10.448
SOx 19.1 13.9 5.2

Procedural concerns

  • Owing to the current Covid health crisis, DEQ’s notification processes are increasingly reliant on electronic outreach. This is inappropriate as many of the impacted localities do not have consistent internet access.
    Outreach to impacted communities should have occurred earlier in the process, as the accelerated timeline of review and approval is inconsistent with the appropriate outreach encouraged by Virginia’s 2020 Environmental Justice Act.
  • During the public information session on Jan 7, 2021 regarding the timeline for approval, members of the public flagged that the timeline seems set by the applicant. As the project is missing a major state level permit (a Clean Water Act 401 water certification from North Carolina), DEQ staff acknowledged that they possibly should NOT be moving forward.
  • The completion rates for construction of the mainline MVP project that the developer included in the draft permit are significantly overstated, and could unfairly influence decision makers reviewing the permit.
    MVP does not use “full to restoration” percentage complete, instead relying on any preconstruction or ground-disturbing activity to inflate numbers.
  • Among other legal challenges, the MVP mainline is currently unable to cross many miles of water bodies and MVP has announced to Va. DEQ that they will file for an individual permit which would add substantial delay.

Air Permit Documents and Reference Info from the VA DEQ
Listen to the Jan 7 DEQ Info session recording

Send your email to: anita.walthall@deq.virginia.gov (note: if you use this link, your comment will also be shared with Appalachian Voices)

Have you submitted a comment?
Share it with ridge@appvoices or jessica@appvoices.org!

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