Rebecca Rubin, an environmental consultant, was a member of the Virginia Air Pollution Control Board from 2014 to 2018.
On Tuesday, the Virginia State Air Pollution Control Board — the citizen board charged with regulating air pollution and, to be hoped, enhancing air quality in the commonwealth and all its communities — is scheduled to vote on whether to grant an air permit for a proposed compressor station to be sited in the community of Union Hill in Buckingham County. The Buckingham compressor is one of three stations that would ensure a flow of natural gas for the Atlantic Coast Pipeline as a whole, and it would be the only compressor in Virginia.
Calls for the commonwealth’s commitment to environmental justice have rightly been a focal point of extensive public testimony, and how the air board votes will help determine whether the commonwealth’s stated commitment to environmental justice should be taken seriously.
A first set of concerns has centered on the historically black community of Union Hill, the community immediately affected by the station’s proposed siting. Some of those whose ancestors were freed by the 13th Amendment now believe themselves disenfranchised — in the words of one Union Hill resident giving public testimony opposed to the compressor station, “abandoned to a process that does not consider me or my human rights.” What has become clearer through the public hearing process, including exceptionally careful documentation of demographics compiled by an anthropologist, is that the siting would disproportionately affect a minority community, a classic environmental justice issue. In fact, Union Hill was named “one of Virginia’s most endangered historic places” by Preservation Virginia in 2016 because of the proposed Atlantic Coast Pipeline’s proximity to the area.
Proponents argue that the same air quality standards would be applied regardless of location; that is, that the air emissions would be the same if the station were to be sited in, say, Arlington. This ignores the larger issue of environmental justice: a siting may be deemed inequitable if a population begins at a disadvantage, as is certainly the case for the Union Hill community. A thorough, accurate and comprehensive quantitative health risk assessment taking into account pathways, receptors, proximity and acute and cumulative effects has yet to be undertaken.
As important, any decision on the compressor station one way or the other would not relieve the commonwealth of its duty to contemplate prospectively the broader effects of a pipeline as a whole on air quality in Virginia. The Buckingham compressor station is just one component of the much larger Atlantic Coast pipeline — a pipeline being considered at a time when our nation is imperiled by the effects of catastrophic climate change. Yet, there is to date no comprehensive analysis that looks at the carbon, methane and other greenhouse gas emissions that would be released year-on-year by the pipeline as a whole. In June 2017, the commonwealth proudly joined the U.S. Climate Alliance, citing the commonwealth’s decision on reducing its carbon emissions. To fully uphold its commitments, the commonwealth must now follow through and comprehensively analyze the proposed pipeline’s overall greenhouse gas emissions.
Taken together, the commonwealth’s treatment of these two key issues will create important foundations and precedents for the future — and help determine whether the commonwealth’s commitment to both environmental justice and air quality is written in granite or in soapstone.