FINAL_HOR_Attachment_AthruC2-Northampton_Compressor_Station

Hearing Officer’s Report and Recommendations

Northampton Compressor Station Public Hearing
November 15, 2017
Garysburg Town Hall
Garysburg, NC

SUPPORTING
ATTACHMENTS

Attachment A: List of Acronyms
Attachment B: Audio Recording of the November 15, 2017, Public Hearing
Attachment C: Speakers at Public Hearing and All Written Public Comments (including pictures)
Attachment D: Registration Forms from November 15, 2017, Public Hearing
Attachment E: Supplemental Information Received from Applicant
Attachment F: Air Quality Permit Application Review Documents
Attachment G: Notices of Public Hearing

ATTACHMENT A: List of Acronyms
BACT Best Available Control Technology
Btu British thermal unit
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
CO Carbon Monoxide
DAQ Division of Air Quality
DEQ Department of Environmental Quality
EJ Environmental Justice
EPA Environmental Protection Agency
FR Federal Register
GHG Greenhouse Gas
HAP Hazardous Air Pollutant
hp Horsepower
MACT Maximum Achievable Control Technology
MWh Megawatt-hour
mmBtu Million Btu
NCAC North Carolina Administrative Code
NESHAP National Emission Standards for Hazardous Air Pollutants
NOX Nitrogen Oxides
NSPS New Source Performance Standard
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
PM2.5 Particulate Matter with Nominal Aerodynamic Diameter of 2.5 Micrometers or Less
ppmv Parts per million by volume
PSD Prevention of Significant Deterioration
RRO Raleigh Regional Office
SO2 Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound

Attachment B – Audio Recording of November 15, 2017, Public Hearing for
Northampton Compressor Station Air Quality Permit

The audio file can be found online at:
Northampton Compressor Station - November 15, 2017 Public Hearing Audio.wma

Attachment C – Comments Received During the Comment Period

Attachment Content Page
C.1 List of Commenters that Spoke at November 15, 2017, Public Hearing in
Garysburg, NC and any Written Comments Received
C.1-1
C.2 Unique Comments Received via Email Opposing the Northampton Compressor
Station
C.2-1
C.3 Unique Comments Received via Email Supporting the Northampton Compressor
Station
C.3-1
C.4 Form Letters Received via Email Opposing the Northampton Compressor Station C.4-1
C.5 Form Letters Received via Email Supporting the Northampton Compressor Station C.5-1
C.6 General Comments Received via Email Opposing the Atlantic Coast Pipeline C.6-1
C.7 General Comments Received via Email Supporting the Atlantic Coast Pipeline C.7-1
C.8 Comments Received after the Close of the Comment Period C.8-1

Attachment C.1
Speakers at November 15, 2017, Public Hearing in Garysburg, NC and any Written Comments Received
A list of speakers from the Public Hearing in Garysburg, NC on November 15, 2017 is presented in Table C-1. The
audio recording of the hearing is included as Attachment A. If the commenter submitted written comments, the
page number is provided.
Table C.1-1. Speakers at November 15, 2017, Public Hearing in Garysburg, NC
Name Representing Page
Barbara Exum Self NA
Gary Brown Northampton County Economic Development
Commission
C.1-2
Hope Taylor Clean Water for North Carolina C.2-465
Tom Clark NA
Tom Betts NA
Doug Hughes NA
Paul Heaton General Contractor Local NA
Lib Hutchby NA
Elnora Richardson NA
Gary Grant NA
Joshua Pair Chaplain NA
Dave Hoque NA
Catherine Glover Glover Construction Co., Inc. NA
Christie Ethridge NA
Terese Vick Blue Ridge Environmental Defense League C.2-478
David Neal C.2-17
C.2-499
John Wagner C.2-11
Karen Bearden C.2-30
Fannie Greene NA
Andy Warner ERM NA
Belinda Joyner C.2-45
Richard Worsinger City of Rocky Mount C.7-18
Marvin Winstead Jr. Self NA
Brian Murphy NA
Tony Burnette NA
Ericka Faircloth Clean Water for NC NA
Matt Glover Glover Construction Co., Inc. NA
Lucinda Cook NA
Lola Ausby NA

Good evening. I'm Gary Brown, economic development director here in
Northampton County and a resident of the county. Thank you for the
opportunity to comment on the draft air � permit for the Atlantic
Coast Pipeline compressor station to be located here in Northampton.
Permitting of this type is not unusual in this county or North Carolina.
Currently, there are, by my count, 37 permits issued by the Department -
--minor, synthetic, Title V ---active in Northampton County.
So the permit application by the Atlantic Coast Pipeline for the
Northampton County compressor station is not unusual ---either for
Northampton County, or Wake, or New Hanover or Buncombe.
Perhaps what is unusual is the proposed compressor station site ----more
than 6100 feet from the nearest commercial structure and more than
7000 feet from the closest residence.
That's quite a buffer ---particularly for a minor source permit.
1
Page C.1-2
Attachment C.1. Speakers at November 15, 2017, Public Hearing in Garysburg, NC and any Written Comments Received
A buffer of that scale isn't at all necessary, but is an example of the steps
taken to minimize any potential for impacts.
Whether it be residential, agriculture, commercial or industrial
development, there are consequences to human activity. Our objective
here in Northampton County has been to manage that development
responsibly. In doing so, we have assessed those options through a
realistic prism.
For the past 25 years I've been the economic development director here
in Northampton County ---and during those years our focus has been on
creating sustainable, higher-wage employment opportunities for the
people who live and work here, and for the next generation, our children,
so they can stay here.
We've had success, and have done that responsibly. Since 2000, the
rate of private sector job creation here has exceeded that of the state and
nation by more than 20 percent. Personal per capita income and
private sector wages have also grown at a rate greater than that of the
state & nation.
2
Page C.1-3
Attachment C.1. Speakers at November 15, 2017, Public Hearing in Garysburg, NC and any Written Comments Received
But, still, we have a long way to go. About three weeks ago, we
submitted site proposals for two new �ts ---a total of
$410 million in private investment, 850 jobs ----wages with one
company will average $55,000 a year and a phenomenal $87,500 with
the other.
Both companies want to bring the projects out of the ground in the next
18 months, and this County is right in their sweet spot for logistics,
workforce, proximity to markets, really good sites and interstate access.
Earlier today, we submitted revised proposals, which we believe will
eliminate us from the competition. We did that because Piedmont
Natural Gas advised that they can't meet the natural gas demand
necessary for either project.
The Northampton County Planning Board, the Northampton County
Economic Development Commission and the Northampton County
Board of Commissioners have all unanimously endorsed this project.
We encourage your favorable consideration of the air quality permit
application submitted by the Atlantic Coast Pipeline. And we thank you
for your consideration and for your service.
Page C.1-4
Attachment C.1. Speakers at November 15, 2017, Public Hearing in Garysburg, NC and any Written Comments Received
Gary Brown
Executive Director
Northampton County
Economic Development Commission
9495 NC-305 Highway
PO Box 685
Jackson, NC 27845
4
Page C.1-5
Attachment C.1. Speakers at November 15, 2017, Public Hearing in Garysburg, NC and any Written Comments Received

Attachment C.2
Unique Comments Received via Email Opposing the Northampton Compressor Station
Of the 2,328 written comments received that expressed opposition to the air quality permit for the
Northampton Compressor Station, 92 of these comments were unique comments. These commenters are
identified in Table C.2-1. Copies of the comments are also included in this section.
Table C.2-1. List of Commenters that Submitted Unique Comments
From Subject Received Page
Kadesia Owens "ACP/DAQ" 11/20/2017 C.2-4
Fatimah Wilson "ACP/DAQ" 11/20/2017 C.2-6
Jonathan Sheline ACP comments 11/20/2017 C.2-8
Marsh Hardy Ara/Risk ACP vs UN Indigenous and Tribal Peoples Convention of
1989
11/19/2017 C.2-10
John Wagner ACP/DAQ 11/21/2017 C.2-11
Elizabeth Sasser ACP/DAQ 11/20/2017 C.2-15
Adele Tatta ACP/DAQ 11/20/2017 C.2-16
David Neal ACP/DAQ 11/20/2017 C.2-17
Karen Bearden ACP/DAQ 11/20/2017 C.2-30
Jeannie Ambrose ACP/DAQ 11/20/2017 C.2-32
Ryan Emanuel ACP/DAQ 11/20/2017 C.2-35
Valerie Reynolds ACP/DAQ 11/20/2017 C.2-36
Andrea Emanuel ACP/DAQ 11/20/2017 C.2-38
Cathy Scott ACP/DAQ 11/19/2017 C.2-41
Scott Weir ACP/DAQ 11/19/2017 C.2-43
Belinda Joyner ACP/DAQ 11/19/2017 C.2-45
Laura Manigrasso ACP/DAQ 11/19/2017 C.2-46
Lars Nyland ACP/DAQ 11/19/2017 C.2-47
Rebecca Ewing ACP/DAQ 11/19/2017 C.2-48
Francine Stephenson ACP/DAQ 11/18/2017 C.2-49
Keely Wood ACP/DAQ 11/17/2017 C.2-50
Isabel Geffner ACP/DAQ 11/17/2017 C.2-51
Christine Ellis ACP/DAQ 11/16/2017 C.2-52
John Runkle ACP/DAQ 11/16/2017 c.2-54
Lauren Nyland ACP/DAQ 11/16/2017 C.2-459
Patience Vanderbush ACP/DAQ 11/16/2017 C.2-460
Martha W Girolami ACP/DAQ 11/15/2017 C.2-461
Tracy Raines ACP/DAQ 11/6/2017 C.2-464
Hope Taylor ACP/DAQ Clean Water for NC Comments on ACP
Compressor Station draft permit
11/20/2017 C.2-465
Felysha Jenkins ACP/DAQ - Deny Draft Permit 11/19/2017 C.2-469
Cary Rodgers ACP/DAQ - Public Comments 11/8/2017 C.2-471
Louis Zeller ACP/DAQ AIR QUALITY PERMIT #10466R00 11/20/2017 C.2-474
Page C.2-2
Table C.2-1. List of Commenters that Submited Unique Comments

From Subject Received Page
Therese Vick ACP/DAQ Draft Air Permit Number 10466ROO for the
Proposed Northampton County Compressor Station,
Atlantic Coast Pipeline
11/20/2017 C.2-478
Seth Harris ACP/DAQ Northampton 11/17/2017 C.2-487
Celena Bunn-Bissette ACP/DAQ regarding permit #10466R00 11/19/2017 C.2-488
Andrews Weathercenter ACP/DAQ: Deny the Air Quality Permit for the Atlantic
Coast Pipeline
11/20/2017 C.2-491
Keely Wood ACP/DEQ 11/8/2017 C.2-493
Janet Wooten Compressor station in Northampton County 11/19/2017 C.2-494
Maple Maryann
Osterbrink
Compressor Station Northhampton 11/20/2017 C.2-496
Sharon Garbutt NC DEQ/DAQ: Please deny permit for the ACP
Northampton Compressor Station until ACP guarantees
protection of all citizens and the environment
11/20/2017 C.2-497
David Neal RE: ACP/DAQ 11/20/2017 C.2-499
Harvey Richmond RE: ACP/DAQ 11/16/2017 C.2-501
Rachel Karasik Re: DEQ PERMIT #10466R00 for the Northampton
Compressor Station Facility ID 6600169
11/20/2017 C.2-502
Liz Adams Subject: ACP/DAQ 11/20/2017 C.2-503
Steven Norris Why the Northhampton compressor station and the ACP
should not be built
11/20/2017 C.2-513
Normandy Blackman "ACP/DAQ NO COMPRESSOR STATION(S) 11/20/2017 C.2-514
Normandy Blackman "ACP/DAQ" -NO ACP/DAQ PERMITS 11/20/2017 C.2-515
Normandy Blackman "ACP/DAQ*=ACP%2FDAG 11/20/2017 C.2-516
Harriett Gray ACP / DAQ 11/12/2017 C.2-517
Normandy Blackman ACP%2FDAQ--- NO TO ACP COMPRESSOR STATIONS 11/20/2017 C.2-518
Amanda Ibarra ACP/DAQ 11/20/2017 C.2-519
Julia Haslett ACP/DAQ 11/20/2017 C.2-521
Ryan Williams ACP/DAQ 11/20/2017 C.2-522
Nancy Jacobs ACP/DAQ 11/20/2017 C.2-523
Cheri DeRosia ACP/DAQ 11/20/2017 C.2-524
douglasnorton21 ACP/DAQ 11/20/2017 C.2-525
Janine Latus ACP/DAQ 11/20/2017 C.2-526
Becca Zerkin ACP/DAQ 11/20/2017 C.2-527
Hamilton, Darlene ACP/DAQ 11/20/2017 C.2-528
Edith Braginton ACP/DAQ 11/19/2017 C.2-529
lauralkuebler ACP/DAQ 11/19/2017 C.2-530
Brett Sheppard ACP/DAQ 11/18/2017 C.2-531
Valerie Williams ACP/DAQ 11/18/2017 C.2-532
Stuart ACP/DAQ 11/18/2017 C.2-533
[e-mail] ACP/DAQ 11/17/2017 C.2-534
Chris Chato acp/daq 11/16/2017 C.2-535
Susan Weaver ACP/DAQ 11/14/2017 C.2-536
Page C.2-3
Table C.2-1. List of Commenters that Submited Unique Comments

From Subject Received Page
Betsey Granda ACP/DAQ 11/14/2017 C.2-537
Benjamin Bundy ACP/DAQ 11/14/2017 C.2-538
Michael Mitchell ACP/DAQ 11/13/2017 C.2-539
Emily Trentham ACP/DAQ 11/13/2017 C.2-540
Tymber Felts ACP/DAQ 11/13/2017 C.2-541
Robert Van Der Drift ACP/DAQ 11/13/2017 C.2-542
Cameron Howard ACP/DAQ 11/13/2017 C.2-543
Donna Bullock ACP/DAQ 11/12/2017 C.2-544
Tamara S ACP/DAQ 11/7/2017 C.2-545
[e-mail] ACP/DAQ 11/7/2017 C.2-546
Jo Ann Amey ACP/DAQ 11/6/2017 C.2-547
Pam Frome ACP/DAQ 11/6/2017 C.2-548
Shawn O'Neill - Print Plus ACP/DAQ 10/18/2017 C.2-549
Helen Furr ACP/DAQ 10/11/2017 C.2-550
Gary Wiggins ACP/DAQ comments 11/20/2017 C.2-551
Pamela Culp ACP/DAQ PLEASE RECONSIDER 11/20/2017 C.2-552
june wollett Air quality 11/19/2017 C.2-553
steve roberts Compressor Station 11/17/2017 C.2-554
Valerie Williams DEQ/DAQ 11/20/2017 C.2-555
Melanie Raskin I oppose the Atlantic Coast Pipeline Compressor Station 11/14/2017 C.2-556
Bob Dietz Northhampton County Compressor Station 11/20/2017 C.2-557
Mary Honeycutt Opposition to the Atlantic Coast Pipeline & the
Compressor Station
11/14/2017
C.2-558
Normandy Blackman Re: "ACP/DAQ" -NO ACP/DAQ PERMITS 11/20/2017 C.2-559
Delicia Blackman Re: ACP/DAQ 11/20/2017 C.2-560
Julie Nye Stop the Atlantic Coast Pipeline 11/9/2017 C.2-561

From:Kadesia Owens
To:SVC_DENR.publiccomments
Subject:[External] "ACP/DAQ"
Date:Monday, November 20, 2017 3:25:10 PM
Attachments:msbennett.docx
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attachment to [e-mail].
Ms. Betty Bennett
Physical Address: 106 Grant Street
Garysburg, N.C. 27831
Mailing Address: P.O. Box 48
Garysburg, N.C.
Page C.2-4
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
TO Whom It May Concern:

When it comes to race what is the percentage of Black/White jobs that will be available? Have you
contacted any black contractors/builders, workers, etc? Yes there will be jobs, but for those who spoke
at the meeting and most of all they usually bring their own workers with them, which most of them are
whites making a fortune off of our poor community. Later afterwards, there will be hardly anyone hired
just using jobs as a “clutch” to get the project in our area.
I have a program “I Can Excel” and have had “free” tutorials for children for a total of 37 years and had
nothing to worry about so that our children can live as others that are outside of our community, and
not have to worry about sickness, injuries, and health problems. I’ve won numerous awards such as the
Governor’s award, Channel 11 Neighborhood recognition “as neighborhood hero, Community College
Black Hero Award, Chamber of Commerce recognition honor, Humanitarian award-volunteer services,
two Angel Awards, a letter from the State Department as a Unique Gem for helping to prevent drop-out
prevention. I’ve worked hard in Garysburg at 106 Grant St. I am now 73 years old and would like to live
the rest of my life without having to worry about serious problems in the future from the pipeline.
Blacks already have enough to worry about instead of having to go back to “slavery” again because of
others “gain”. Leave us alone and let us relax in our homes.

We don’t need to take a chance in areas where the extent of damage to poverty, serious injury or death
are significant in case of a rupture or a significant leak. The area I live in is in that High Consequence or
Blast Zone, including Roosevelt, Grant, Lincoln, Monroe, Wilson, Washington, Madison and Truman. This
is the areas where we live.

This is my personal beliefs about the pipeline situation that will affect my community.

Thanks in Advance,
Ms. Betty Bennett
Page C.2-5
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Fatimah Wilson
To:SVC_DENR.publiccomments
Subject:[External] "ACP/DAQ"
Date:Monday, November 20, 2017 8:46:14 AM
Attachments:Compressor Station Letter.pdf
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attachment to [e-mail].
Please see attached
Page C.2-6
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Page C.2-7
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Jonathan Sheline
To:SVC_DENR.publiccomments
Subject:[External] ACP comments
Date:Monday, November 20, 2017 9:41:29 PM
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attachment to [e-mail].
Dear Sirs:
I am writing to express my strong opposition to the Atlantic Coast Pipeline (ACP). Studies I have seen
call into question whether there is any need for increased supply of natural gas in the states through
which the pipeline will pass.
I am especially concerned about the compressor stations which would need to be built. According to
an Oct, 2017 study by the Southwest Pennsylvania Environmental Health Project, every compressor
station they studied routinely releases large volumes of chemicals associated with a variety of
diseases and disorders. Nearby residents experience higher respiratory, cardiovascular and
neurological problems, and report elevated stress levels due to 24/7 noise.
Concerns about Air Quality Permit for Northampton Compressor Station
A review of the permit application shows that DEQ lacks a great deal of information needed to
properly regulate this facility, and doesn’t take into account the impact of other nearby major
polluters. This facility would only have to submit a complete emissions listing 90 days prior to
expiration of the 5 year permit before renewal. That’s five years after the facility would start
operating! Visual emissions, representing high particulates, are limited to an average of 20% opacity
measured over a 6 minute period, but 6 min periods averaging up to 87% can occur each hour or 4
times in 24 hours! With all of its compressor engines bigger than 500 horsepower, this should trigger
more air controls, but the permit only requires the facility’s operators to control emissions “to the
extent practical, consistent with good air pollution control practice for minimizing emissions”. This is
an unenforceable requirement. Initial performance testing is only required within the first year, then
every three years thereafter. There is no acknowledgment of the impact of total air emissions from
other polluting facilities nearby, including another compressor station in Pleasant Hill, the Georgia
Pacifica facility just above the VA border, and the huge Enviva Wood Pellet plant a few miles to the
southwest. Regional modelling and increased monitoring must be required. Formaldehyde is an
irritant and toxic compound released at high levels by compressor stations as well as wood
processing facilities, but it’s not limited in the permit! Pollutant emissions like nitrogen oxides and
sulfur dioxide are regulated by the amount of pollutants released per million BTU input. That is, the
more heat used, the greater pollution allowed! There are no clear monitoring requirements in the
permit for Volatile Organic Compounds or Hazardous Air Pollutants. The facility is only required to
ensure “within the limits of practicality” that the equipment is operating at or near maximum rate.
This is unenforceable and unclear in its purpose. There is no enforcement for failure to give 15 days’
notice to regional office to observe testing. The facility is only required to notify DAQ if there are
excessive emissions for FOUR OR MORE HOURS, as a result of malfunction or abnormal conditions.
Notification may wait until 9:00 AM next business day! Dust (particulates) control and odor control
are completely “complaint driven”
—
The facility is supposed to avoid causing “substantive complaints”, excessive odors or visible
emissions beyond the boundary of the facility. If there are “substantive complaints” (not defined) or
Page C.2-8
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
excessive dust outside facility, the facility MAY be required to submit an adjusted control plan! NO
monitoring requirements. The facility is required to “implement management practices and install
and operate odor control equipment as needed to prevent odorous emissions that cause or
contribute to objectionable odors beyond the boundaries of the facility.” Unenforceable, and there
is no monitoring required.
Instead of investing all this time and money into the ACP – which will mainly benefit the OWNERS of
the gas and the pipeline – i.e. Duke Energy, why not invest in renewable energy? The Clean Path
2025 plan, by NCWARN and Bill Powers, lays out very clearly how this could be done, and would
generate far more jobs in North Carolina than would the ACP!!
Sincerely,
Jonathan L. Sheline, MD
111 Pinecrest Road; Durham, NC 27705
Sent from Mail for Windows 10
Page C.2-9
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Marsh Hardy ARA/RISK
To:SVC_DENR.publiccomments
Subject:[External] ACP vs UN Indigenous and Tribal Peoples Convention of 1989
Date:Sunday, November 19, 2017 12:46:11 AM
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attachment to [e-mail].
Dear Sir or Madam:
As members of Amnesty International, Raleigh Chapter, we consider the proposed Atlantic Coast Pipeline (ACP)
fraught with potential human rights violations. We are greatly concerned about the forced loss of land and sacred
grounds for many Native American and other families through the use of eminent domain, and for the benefit of for-
profit companies. The ACP appears to violate Articles 7 and 13-19 of Convention 169, UN International Labour
Organization: The Indigenous and Tribal Peoples Convention, 1989.
http://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:C169
Native American communities in counties expected to be most impacted by the APC construction were not ever
consulted by Dominion-Duke. Even though landowners affluent enough to hire good attorneys may be able to make
good deals with the companies, many in the impacted communities are low-income and may lack the substantial
financial resources needed to ensure adequate compensation and defend their basic human right to their land and
water.
The potential for severe human rights violations for populations in these communities, should the ACP become
approved, is unacceptable. Therefore, we stand against the ACP.
Respectfully,
Amnesty International - Group 213 - Raleigh, NC
following vote to do so, submitted by member...
-- M. B. Hardy, statistician
work: Applied Research Associates, S. E. Div.
8537 Six Forks Rd., # 6000 / Raleigh, NC 27615-2963
[phone], fax: [phone]
home: 1020 W. South St. / Raleigh, NC 27603-2162
[phone]
Page C.2-10
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:[e-mail]
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Tuesday, November 21, 2017 12:17:11 AM
Attachments:ACP DAQ Permit - Public Comments Nov 20 2017 - John Wagner.docx
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attachment to [e-mail].
NC DEQ, Department of Air Quality, and Charles McEachern,
Attached are some brief comments to be added to the comments which I made at the
Northampton Compressor Station hearing.
Thank you,
John Wagner
Page C.2-11
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Public Comments on the Northampton County Compressor Station
for the Atlantic Coast Pipeline
November 20, 2017
John Wagner
The NC DEQ fact sheet for the Northampton compressor station gave the
following emissions profile:

This profile provides a very poor indication of the extent of the emissions that will
be released for several reasons.
1. The permitted pollutants are a very small subset of the toxic releases that
will be emitted annually.
2. The “Expected Actual Emissions” are actually the best-case assumptions of
what the compressor is likely to produce.
3. The total tons per year – even if they are correct – mask the exposure to
extremely high emissions that compressor stations for methane pipelines
give off during operation.
In my comments, I will very briefly address these issues. However, the third point
is the most often overlooked point and is essential to understanding the effect on
human health. This is something that the NC DEQ will be completely unable to
monitor and which will have tremendous health impacts on those residents living
within several miles of the station.

Range of Toxic Chemicals and Compounds Released
Many studies of compressor station emissions have shown a very wide range of serious air
contaminants are released. For example, the independent lab results from air samples taken at
Page C.2-12
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Dish, Texas on September 15th, 2009 found a wide range of toxins. Of those that were found
exceeding Texas’s Effect Screening Levels were:
benzene
dimethyl disulfide
methyl ethyl disulphide
ethyl-methylethyl disulfide
trimethyl benzene
diethyl benzene
methyl-methylethyl benzene
tettramethyl benzene
naphthalene 1,2,4-trimethyl benzene
m&p xylenes
carbonyl sulfide
carbon disulfide
methyl pyridine
dimethyl pyridine
The NC DEQ permit does not mention or give expected tons per year for any of these.
Release estimates represent best case compressor conditions
Evidence from other compressor stations suggest that fugitive emissions
will increase over time as machinery begins to wear. Given Duke Energy’s past records, this is a
particularly important issue for Northampton County. As DEQ and EPA records have shown,
the scrubbers at several of Duke Energy’s coal fire power plants did not perform adequately over
time. Although the newly installed scrubbers performed according to specifications, the
maintenance and replacement schedules were not maintained, and the performance deteriorated
as the equipment wore out.
DEQ only gave the annual expected tons per year for the compressor station, and did not take
into account aging equipment performance over time. This is especially significant when Duke
Energy’s aging equipment is poorly maintained and not replaced as needed
Compressor stations do not release a constant level of emissions, and ambient
averages are not adequate for representing the extremes that are experienced.

Compressor stations emissions vary during normal operation. Ambient
measurements in tons per year are common and are the typical values used by
DEQ. However, these do not capture the very high peak values that are
experienced during blowdowns, accidental or planned pressure releases, equipment
failures, valve leakage or other episodes that release sudden high levels of the
toxins.
Page C.2-13
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
In October, 2017, I spoke briefly with Mike Abraczinskas. I asked him if DAQ
was planning to add any mobile air testing units to supplement the regional
ambient air monitoring equipment that is currently being used by the department.
He stated that the equipment was too expensive and that they had no plans to work
to obtain mobile units.
Without fence-line monitoring DAQ has no capability to determine what levels of
toxins the Northampton community is experiencing during peak releases and
blowdowns from the station. Duke Energy’s criminal convictions and recent
interference and financial influencing of what were supposed to be independent
scientists and scientific reports clearly show that Duke should not be permitted to
do self-monitoring of the compressor station emissions. It would be immoral for
DEQ and DAQ to approve a compressor that it has no plans or capability to
monitor.
Please deny the air permits for Duke, Dominion and the ACP Pipeline Compressor
Stations.
Thank you,
John Wagner
Page C.2-14
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Elizabeth Sasser
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Monday, November 20, 2017 10:14:35 PM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
Dear NC DENR,
I'm writing to express my opposition to the Atlantic Coast Pipeline (ACP) compressor station.
I oppose the pipeline for these four reasons.
1. In the event that the ACP ruptures or explodes, it will endanger homes, families, and
property in North Carolina.
2. Farmland and wilderness will be both temporarily and permanently damaged when the
pipeline is installed.
3. Additional natural gas capacity is not needed.
4. The ACP will cost nearly $5 billion, and ratepayers will bear the burden of the cost.
Please do not build the ACP.
Sincerely,
Elizabeth Sasser
--
Elizabeth Sasser
[e-mail]
919-260-6444
Page C.2-15
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Adele Tatta (adtatta)
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Monday, November 20, 2017 8:07:15 PM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
I oppose the Atlantic Coast Pipeline (ACP) and the air compressor station which would be located
on the North Carolina-Virginia border in Northampton County, NC for the following reasons:
1. The ACP will cross more than 1300 parcels of land in NC, and is near enough to thousands of
homes that, in the event of a rupture or explosion, it will endanger both homes and families in
them, as well as farm animals and pets.
2. Although I hear on the ads that promote approval, the falling shale gas supply and high future
prices make this a risky promise.
3. Solar power brings far more jobs that are long lasting in the US
4. The ACP, which will cost about $5 billion, will increase the price of electricity. As a regulated
monopoly Duke Energy is by law guaranteed a hefty profit on anything it builds.
Sincerely,
Adele Tatta
1117 Mount Carmel Church Rd.
Chapel Hill, NC 27517
Page C.2-16
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:David Neal
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Monday, November 20, 2017 4:55:38 PM
Attachments:SELC_et_al_comments_ACP_Northampton_CS_air_permit.PDF
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
To Whom it May Concern:
Attached are comments to the North Carolina Department of Environmental Quality’s Department
of Air Quality regarding draft permit No. 10466ROO for the Northampton Compressor Station of the
Atlantic Coast Pipeline. These comments are submitted on behalf of:

North Carolina State Conference of Branches of the NAACP
Haliwa-Saponi Indian Tribe
North Carolina Environmental Justice Network
Sierra Club
Natural Resources Defense Council
Concerned Citizens of Tillery
North Carolina Conservation Network
Clean Air Carolina
North Carolina Council of Churches
North Carolina Interfaith Power and Light
350 Triangle
Rachel Carson Council
Southern Environmental Law Center

Please let me know if you have any questions.

Sincerely,
David Neal

David L. Neal
Senior Attorney
Southern Environmental Law Center
601 West Rosemary Street, Suite 220
Chapel Hill, North Carolina 27516-2356
Phone: [phone]
Fax: [phone]
SouthernEnvironment.org

This email may contain information that is privileged and confidential. Unless you are the addressee (or authorized
to receive email for the addressee), you may not use, copy, or disclose this email or any information therein. If you
have received the email in error, please reply to the above address. Thank you.

Page C.2-17
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Disclaimer
The information contained in this communication from the sender is confidential.
Page C.2-18
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station

Charlottesville • Chapel Hill • Atlanta • Asheville • Birmingham • Charleston • Nashville • Richmond • Washington, DC
S OUTHERN E NVIRONMENTAL L AW C ENTER

Telephone [phone] WEST ROSEMARY STREET, SUITE 220
CHAPEL HILL, NC 27516-2356

Facsimile 919-929-9421

November 20, 2017

VIA E-MAIL
North Carolina Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
3800 Barrett Drive, Raleigh, NC, 27609
[e-mail]

RE: Comments on Draft Air Permit No. 10466ROO for the Northampton
Compressor Station (Facility ID# 6600169) of the Atlantic Coast Pipeline
Dear Mr. McEachern:
The Southern Environmental Law Center offers the following comments on the draft air
permit for Atlantic Coast Pipeline, LLC’s (“Atlantic”) proposed Northampton Compressor
Station for the Atlantic Coast Pipeline (“ACP”). These comments are submitted on behalf of the
Southern Environmental Law Center, North Carolina State Conference of Branches of the
National Association for the Advancement of Colored People (“NAACP”), the Haliwa-Saponi
Indian Tribe, North Carolina Environmental Justice Network, Sierra Club, Natural Resources
Defense Council, Concerned Citizens of Tillery, North Carolina Conservation Network, Clean
Air Carolina, the North Carolina Council of Churches, North Carolina Interfaith Power and
Light, 350 Triangle, and the Rachel Carson Council.
These organizations respectfully request that the North Carolina Department of
Environmental Quality’s (“NCDEQ”) Division of Air Quality (“DAQ”) withdraw this draft
permit, complete a thorough environmental justice and health assessment of the community that
would be subject to the air pollution from this facility, and seek additional information from
Atlantic. As set forth in more detail below:
• The draft permit does not follow DEQ’s Environmental Equity Policy
• Compressor station pollution threatens the health of the surrounding community and
requires additional scrutiny
Page C.2-19
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 2

• Errors in the Air Toxics permitting process require withdrawal of the draft permit
• Considering other sources of nearby pollution, DAQ must require modeling and ambient
monitoring prior to issuing a permit
• As a major source of greenhouse gas emissions, the Northampton Compressor Station
should be subject to greater scrutiny from DAQ
• Atlantic needs to supplement its application for an air permit with additional information
• DAQ should consider more stringent emissions controls

The Northampton Compressor Station Would Add a New Pollution Source in an Area
Already Burdened by Air Pollution
Atlantic has proposed three compressor stations as integral parts of the ACP. Compressor
stations are large, polluting facilities that use gas-fired turbines to maintain pressure in and allow
gas to move through the pipeline. The proposed compressor station in Northampton County,
North Carolina would be powered by three large turbines, capable of generating 22,000
horsepower.
According to the permit application, the Northampton Compressor Station would emit
19.2 tons per year of nitrogen oxide (NOx), 18.4 tons per year of particulate matter (PM), nearly
130,000 tons per year of carbon dioxide equivalent emissions (CO2E)—largely in the form of
methane—and a number of different hazardous air pollutants.1 It would also emit a significant
amount of volatile organic compounds (VOCs) and ammonia. VOCs can cause serious health
effects, including eye, nose and throat irritation, headaches, loss of coordination, nausea, damage
to liver, kidney and central nervous system, and cancer.2 Formaldehyde, one of the particular
VOCs that would be emitted from the Northampton Compressor Station, is both an irritant and
probable carcinogen.3 Under North Carolina regulations, these VOCs and ammonia are listed as
toxic air pollutants.4
The area around the proposed location of the compressor station, in the northwestern
section of Northampton County, North Carolina, approximately two miles east of US 301 and

1 Atlantic’s Supplemental Application to DAQ for an Air Permit for the Northampton
Compressor Station (July 20, 2017),
https://files.nc.gov/ncdeq/Energy%20Mineral%20and%20Land%20Resources/DEMLR/Atlantic-
Coast-Pipeline/ACP%20Air%20Permit%20Application%20Part%202.pdf. 2 Environmental Protection Agency, Volatile Organic Compounds Impact on Indoor Air
Quality, https://www.epa.gov/indoor-air-quality-iaq/volatile-organic-compounds-impact-indoor-
air-quality. 3 Agency for Toxic Substances and Disease Registry (ATSDR), Toxic Substances Portal,
Formaldehyde, https://www.atsdr.cdc.gov/substances/toxsubstance.asp?toxid=39. 4 15A N.C. Admin. Code 02Q .0711.
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 3

just south of the Virginia border, is already heavily burdened by multiple sources of air pollution.
The Northampton Compressor Station would be located approximately seven miles northeast of
the Enviva Wood Pellets facility (a major air pollution source); two miles northeast of the
Pleasant Hill Compressor Station (a major air pollution source); approximately 1.75 miles east-
southeast of the Georgia Pacific plywood manufacturing facility in Virginia (currently idled, but
a permitted major air pollution source that could resume operations). There is also a gas-fired
combined cycle power plant under construction in Greensville County, Virginia and an existing
gas-fired power plant in Brunswick County, Virginia, each less than 30 miles from the site of the
proposed compressor station. Mobile source air pollution comes from Interstate 95 and CSX rail
lines that cut through the northwestern section of the county. In addition, the community would
be at added risk of air pollution from gas-fired combustion facilities that might tap into the ACP
in the future.
The Draft Permit Does Not Follow DEQ’s Environmental Equity Policy
Consistent with NCDEQ’s long-standing Environmental Equity Policy5 and its
obligations under Title VI of the Civil Rights Act of 1964, DAQ is required to consider the
project’s environmental harms to minority and low-income communities in permitting decisions
regarding the Northampton Compressor Station. We appreciate DAQ’s decision to hold a public
hearing in Garysburg to allow the community to voice its concerns about this new source of air
pollution. But more is required to comply with DAQ’s obligations under NCDEQ’s own
Environmental Equity Policy and under federal law. In addition to using demographic data to
determine whether there is a need for greater outreach, DAQ should use that information to
determine whether there are “special health risks based on the nature of the population” and
assess “the cumulative effects of permitted facilities.”6
The demographic data demonstrate that this facility would most directly affect a
predominantly African American community, many of whose residents live in poverty. The
Northampton compressor station would be located in census block group 6 (a subset of census
tract 9203). Within that census block group, 79.2 percent of the population is African American.
Within census tract 9203, 32.3 percent of the population lives at or below the federal poverty
line, nearly double the state average.
The Northampton Compressor Station would be located in an area where people are
already struggling with health challenges that are exacerbated by air pollution. The local health
department reports that a high percentage of Northampton County citizens suffer from chronic

5 NC DENR Environmental Equity Initiative (October 19, 2000).
6 Id.
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 4

diseases and that hospitalizations for asthma are higher than the state average.7 22 percent of
surveyed residents reported having been diagnosed with asthma and 64 percent report high blood
pressure. The three leading causes of death in Northampton County are cancer, diseases of the
heart, and chronic lower respiratory disease, all conditions that are aggravated by air pollution.
The Northampton Compressor Station would be built on ancestral lands of the Haliwa-
Saponi Indian Tribe, and just about 13 miles from the closest section of the Haliwa-Saponi State
Designated Tribal Statistical Area.8 There are enrolled tribal citizens who live outside the
designated statistical area and are even closer to the proposed compressor station, some of whom
work in Northampton County. DAQ’s environmental justice review should also consider the
possible effects on human health of members of the Haliwa-Saponi tribe. In addition, it would
be inappropriate to issue a final permit to Atlantic before DAQ has engaged in meaningful
government-to-government consultation with the Haliwa-Saponi Indian Tribe.9
The Environmental Equity Policy recognizes the potential for disproportionate
environmental burdens to be imposed on low-income communities and communities of color.
Given the other significant, polluting facilities close to the proposed Northampton Compressor
Station, and given the high concentration of African American, low-income, and other
vulnerable communities near the project site, DAQ needs more information about the effects of
this pollution and the characteristics of the affected community before it can issue a permit. As
will be shown in more detail below, DAQ should require modeling of the expected air pollution
from this facility and monitoring of existing, nearby major sources of air pollution. These steps
are necessary to ensure that low-income communities, Indian tribes, and people of color are not
placed at risk of disproportionate, cumulative, harmful health effects from the added air pollution
of this facility.
Until DAQ has completed an environmental justice and health assessment of this
community, it should withdraw the draft permit.

7 Northampton County Health Assessment, Northampton County Health Department (2015),
https://www.northamptonhd.com/images/Northampton_County_2015_Community_Health_Asse
ssment__51215.pdf. 8 Haliwa-Saponi State Designated Tribal Statistical Area, https://www.census.gov/geo/maps-
data/maps/block/2010/aianhh/dc10blk_sdtsa.html. 9 The Haliwa-Saponi Indian Tribe made a formal request for such consultation as part of DEQ’s
Division of Water Resources 401 Clean Water Certification process, but no such consultation has
yet occurred. Comment Letter from Haliwa-Saponi Indian Tribe to DEQ’s Division of Water
Resources Regarding 401 Certification (Aug. 18, 2017),
http://edocs.deq.nc.gov/WaterResources/0/doc/573440/Page1.aspx?searchid=1864239e-bfcf-
4168-9d20-e591886f72c4.
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 5

Compressor Station Pollution Threatens the Health of the Community and Requires
Additional Scrutiny
Pollution from this facility would likely lead to adverse health effects to the surrounding
population. In its Environmental Impact Statement for the ACP, the Federal Energy Regulatory
Commission (“FERC”) recognized the health risks from pollution from the ACP’s compressor
stations, which:
include carbon monoxide (CO), carbon dioxide (CO2), methane,
and nitrous oxide (NOx); volatile organic compounds (VOCs); and
particulate matter with an aerodynamic diameter less than or equal
to 2.5 microns (PM2.5). These air pollutants are known to increase
the effects of asthma and may increase the risk of lung cancer….
When considering the health impacts associated with compressor
station emissions, increased rates of lung cancer were identified
associated with the compounds emitted by compressor station
operations. Studies have shown that several different cancer-
related compounds and chemicals are present in the air in
proximity to construction and operation of compressor stations,
and that some of these have documented health effects on the
general and vulnerable populations.10
The studies cited by the FERC found elevated concentrations of dangerous pollutants from
samples collected near compressor stations. These include volatile organic compounds
(“VOCs”), fine particulate matter, and gaseous radon. Some VOCs, such as benzene and
formaldehyde, are carcinogens.
According to a recent report from Physicians for Social Responsibility, a “growing body
of scientific evidence documents leaks of methane, toxic volatile organic compounds and
particulate matter throughout [our country’s natural gas] infrastructure. These substances affect
[human] health.” 11 People living near compressor stations suffer from a “range of symptoms
ranging from skin rashes to gastrointestinal, respiratory, neurological and psychological

10 Atlantic Coast Pipeline, Final Environmental Impact Statement, at 4-513 to 514. 11 Too Dirty Too Dangerous: Why Health Professionals Reject Natural Gas, Physicians for
Social Responsibility (Feb. 2017), http://www.psr.org/assets/pdfs/too-dirty-too-dangerous.pdf
[“Too Dirty Too Dangerous”]. This report compiled new scientific studies that indicate
additional potential pollution from natural gas infrastructure, including compressor stations.
Page C.2-23
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 6

problems.”12 Air samples collected around compressor stations have revealed elevated
concentrations of many of the dangerous substances associated with gas extracted from hydraulic
fracturing operations, or fracking. The ACP would transport such gas into Virginia and North
Carolina from the Marcellus shale. These dangerous substances include “volatile organic
compounds, particulate matter, and gaseous radon.”13 The federal Agency for Toxic Substances
and Disease Registry examined air quality near a natural gas compressor station in Pennsylvania
and discovered PM2.5 at dangerous levels.14 Just this month, the NAACP, in cooperation with
the Clean Air Task Force, released a new report about the threats to the health of communities of
color from oil and gas infrastructure, including the proposed Atlantic Coast Pipeline and
compressor stations.15
Though Atlantic’s application reported likely emissions in averages, compressor stations
have been observed to have highly variable emissions, including large spikes of VOC
emissions.16 One compressor station in Pennsylvania emitted dangerous amounts of
ethylbenzene, butane, and benzene on some days and hardly detectable amounts on other days,
resulting in averages that did not appropriately indicate the compressor station’s threats to human
health.17

12 Id. (citing Brown, Weinberger, & Weinberger, Human exposure to unconventional natural gas
development: A public health demonstration of periodic high exposure to chemical mixtures in
ambient air, Journal of Environmental Science and Health, Part A, 50:5, 460-472 (2015).
https://www.ncbi.nlm.nih.gov/pubmed/25734822). 13 New York State Department of Health (2014). A public health review of high volume
hydraulic fracturing for shale gas development.
http://www.health.ny.gov/press/reports/docs/high_volume_hydraulic_fracturing.pdf. 14 Id. (citing Agency for Toxic Substances and Disease Registry, Health Consultation: Exposure
Investigation, Natural Gas Ambient Air Quality Monitoring Initiative Brigich Compressor
Station, Chartiers Township, Washington County, Pennsylvania (Jan. 29, 2016); Agency for
Toxic Substances and Disease Registry, Health Consultation: Brooklyn Township PM2.5,
Brooklyn Township, Susquehanna County, Pennsylvania. U.S. Department of Health and Human
Services, Atlanta, GA. (April 22, 2016). 15 Lesley Fleischman (Clean Air Task Force) & Marcus Franklin (NAACP), Fumes Across the
Fence-Line: The Health Impacts of Air Pollution from Oil & Gas Facilities on African American
Communities, p. 7 (Nov. 2017), http://www.naacp.org/wp-content/uploads/2017/11/Fumes-
Across-the-Fence-Line_NAACP_CATF.pdf. 16 Southeast Pennsylvania Health Project, Summary on Compressor Stations and Health Impacts
(Feb. 24, 2015), http://www.environmentalhealthproject.org/files/Summary%20Compressor-
station-emissions-and-health-impacts-02.24.2015.pdf.
17 Id., at p. 2.
Page C.2-24
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 7

Communities that are downwind and downhill from compressor stations likely suffer
from elevated exposure to methane and related pollutants. This was the conclusion of a recently
published analysis of methane emissions from compressor stations in New York and
Pennsylvania, which found highly elevated levels of methane coming from those facilities.18 In
one example, the study authors found:
This data indicates that the areas downwind of compressor stations
…will be exposed to methane plumes, and any other co-emitted
pollutants released by compressor stations. Residents and
properties downwind under prevailing wind conditions will likely
be subjected to a disproportionate burden of contaminants from
compressor stations, especially those closer to the station under
light prevailing wind conditions.19
As discussed above, in the case of the Northampton Compressor Station, these health
effects would be felt most by nearby communities that are disproportionately African American.
In the Final Environmental Impact Statement for the ACP, FERC acknowledged that “‘African
Americans have one of the highest rates of current asthma compared to other racial/ethnic
groups’” and that “[p]revalence [of asthma] in children is highest in African Americans when
compared to other racial/ethnic groups.”20 Black Americans are more than twice as likely as
white Americans to live near sources of harmful pollution and suffer disproportionate respiratory
sickness as a result.21 Yet the FERC did not consider how the proposed Northampton
compressor station would likely harm the predominantly African American community that
surrounds the facility. DAQ cannot rely on the cursory environmental justice review that was
included in the Final EIS when evaluating the health risks on this population from the facility.
Errors in the Air Toxics Permitting Process Require Withdrawal of the Draft Permit
1. Ammonia emissions require air toxics permit and air dispersion modeling.

18 Bryce Payne, Jr., et al, Characterization of methane plumes downwind of natural gas
compressor stations in Pennsylvania and New York, Science of the Total Environment, Vol. 580,
pp. 1214–1221 (Feb. 2017). 19 Id.
20 Final EIS at 4-513 (quoting American Lung Association, 2010) and at 4-514 (citing Center for
Disease Control and Prevention, 2013).
21 See, e.g., Emily Badger, Pollution is segregated, too, The Washington Post (April 15, 2015),
https://www.washingtonpost.com/news/wonk/wp/2014/04/15/pollution-is-substantially-worse-
in-minority-neighborhoods-across-the-u-s/?utm_term=.07c703f92dc0.
Page C.2-25
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 8

DAQ determined that an air toxics permit was not needed for the facility’s ammonia
emissions because it used the emission rates for facilities “where all emission release points
are unobstructed and vertically oriented,” pursuant to 15A N.C. Admin. Code 2Q.0711(b). But
DAQ identified sources of toxic air pollutants from sources at the facility that would likely be
obstructed or non-vertically oriented, such as storage tanks. Atlantic did not include diagrams in
its application that would show the emissions points from storage tanks. DAQ cannot assume
that such emissions points from storage tanks are vertically oriented or unobstructed. Thus, the
facility should have been subject to the 2Q.0711(a) regulations, which have lower thresholds of
toxic air pollutants and apply to “any facility where one or more emission release points are
obstructed or non-vertically oriented . . . .” The Atlantic facility’s projected emissions of 2.83
pounds per hour of ammonia, for example, are far above the .68 pounds per hour threshold for
requiring a toxic air permit under subsection (a). By the same token, the facility’s anticipated
formaldehyde emissions would be over the subsection (a) limits.
Regardless, even if all emissions release sources are unobstructed and vertically oriented,
the emissions from the three turbines (2.83 lb/hr) are a mere .01 pound per hour below the
emission rate threshold for ammonia (2.84 lb/hr) for a source subject to 15A NCAC 2Q.0711(b).
When a source is so close to the limit, and given the real-world uncertainty of the actual
emissions, including any possible fugitive ammonia emissions from the storage tank, DAQ
should have required an air toxics permit for ammonia.
2. Atlantic’s Permit Application reveals sources of benzene emissions other than from
combustion, requiring an air toxics permit.
In its revised permit application, Atlantic reported that the only source of benzene would
be from natural gas combustion from turbines and that the heat input value for those engines
would be less than 450 million British thermal units (“BTUs”) per hour. DAQ accepted the
company’s conclusion and applied the regulation that exempts combustion sources below that
heat input “that are the only source of benzene at the facility” from requiring an air toxics permit.
15A N.C. Admin Code 2Q.0702(25) (emphasis supplied).
But the company’s application shows that there is at least one additional source of
benzene emissions at the facility, and thus, the cited exception should not have applied to this
facility. One of the storage tanks—listed as “I-TK-2—hydrocarbon waste storage tank” in the
draft permit—is listed as a source of toxic air pollutants. In the revised permit application,
Atlantic reports that this tank will also emit benzene.22 This tank would store used oil on the

22 Tank 1 Emissions, p. 3, Atlantic’s Revised Northampton compressor station air permit
application (July 20, 2017).
Page C.2-26
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 9

facility, a known source of benzene.23 Benzene is a known carcinogen that has been linked to a
number of other blood disorders and reproductive and developmental toxicity.24 Because there is
a source of benzene emissions other than the combustion turbines, the exception in 2Q.0702(25)
does not apply, and DAQ should have required an air toxics permit for the facility.
DAQ Must Require Modeling and Ambient Monitoring Prior to Issuing a Permit
DAQ also has an independent obligation to limit the potential for adverse health effects
from this facility, taking into account emissions from other nearby sources.25 DAQ has not
performed the analysis necessary to make this determination, and given the numerous other
major sources of air pollution nearby, must do so before it can issue a permit. Given the air
toxics issues identified above, DAQ should require air dispersion modeling as part of the air
toxics permit. Atlantic supplied modeling data to FERC for the Northampton compressor
station, but that information was not submitted to DAQ in Atlantic’s permit application.
Importantly, that modeling was itself flawed in that it did not include background levels of air
pollution from this community, but instead from monitoring stations as far away as Roanoke,
Charlottesville, and Harrisonburg Virginia.26 Background levels for hazardous or toxic air
pollutants were not considered at all. New modeling should be performed that includes accurate
information about the background sources of existing pollution in the relevant area.
As a Major New Source of Greenhouse Gas Emissions, the Northampton Compressor
Station Should Be Subject to Greater Scrutiny
The compressor station would be a major new source of greenhouse gas pollution, with
nearly 130,000 tons per year of carbon dioxide equivalent emissions (significantly over the
100,000 tons per year threshold for major source review). It is not clear from the draft permit
whether DAQ considered additional methane emissions from leaks and blowdowns, which can
be more frequent and less predictable than indicated in the application. The draft permit should
be withdrawn and those additional methane emissions considered in the total carbon dioxide
equivalent calculations.

23 One of the reasons used oil is regulated is because it contains harmful contaminants, such as
benzene. See, e.g., Transportation Environmental Resource Center, Used Oil,
http://www.tercenter.org/pages/oilused.cfm. 24 EPA Fact Sheet, Benzene, https://www.epa.gov/sites/production/files/2016-
09/documents/benzene.pdf. 25 15A N.C. Admin. Code 2D.1107.
26 Final EIS, p. 4-560.
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 10

Given Governor Roy Cooper’s commitment to addressing the present danger to North
Carolina from climate change and his decision to join the U.S. Climate Alliance, DAQ should
hold the permit to greater scrutiny given that it would be a major new source of greenhouse gas
pollution.
Additional Issues in the Draft Permit Require Atlantic to Supplement Its Application
According to Atlantic’s revised application, this facility would release at least 21.2 tons
per year of VOCs. In its first application, however, it indicated that the facility would release
nearly twice that amount of VOCs, 41.1 tons per year. DEQ should require further verification
of whether the previous number was more accurate.
The facility would also emit formaldehyde, which DAQ regulations consider to be
merely an “acute irritant,” not a carcinogen. As a consequence, the Department places a
maximum hourly limit for formaldehyde, but does not regulate total annual exposure from
sources such as the Northampton compressor station. Particularly given the other sources of
formaldehyde pollution nearby—including from another compressor station in Pleasant Hill—
the department should ensure that the community is not going to be exposed to dangerous levels
of this carcinogen on an annual basis.
The draft permit contains a requirement for Atlantic to control odor, prohibiting the
company from operating the facility “without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility
from causing or contributing to objectionable odors beyond the facility’s boundary.” But there is
nothing in the permit application indicating how the company will comply with this requirement.
The draft permit should be withdrawn and Atlantic should be required to demonstrate its
management practices or control equipment that will prevent odorous emissions from the
facility.
DAQ Should Inquire About the Possibility of More Stringent Emissions Controls
Atlantic purports to use “best in class” emission controls for the compressor station’s
turbines. The company proposed using Selective Catalytic Reduction (SCR) to control nitrogen
oxide (NOx) emissions. Oxidation catalysts are proposed to control carbon monoxide (CO) and
formaldehyde. According to the draft air permit, the applicant’s SCR will have a control
efficiency of 80 percent for the Centaur 40 turbine, but would drop to 44 percent for the Centaur
50L and Taurus 70 turbines.
The term “best in class” is a relative term and should not be confused with “Best
Available Control Technology” or “BACT.” BACT reflects the best demonstrated control
Page C.2-28
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
N.C. Department of Environmental Quality
Division of Air Quality
Attn: Charles McEachern
November 20, 2017
Page 11

technology subject to economic and technical constraints, and was not required by DAQ. If
BACT had been required, it is likely all the SCR for all three turbines would be approximately
80 percent, and as a result, would improve local air quality. In addition, BACT analysis may
have led to the identification of more efficient oxidation catalysts to control carbon monoxide
and formaldehyde. Even if not required for this facility, the Department should seek further
information from Atlantic about the possibility of improved emissions control technologies for
the Northampton Compressor Station.
Conclusion
Because of the errors in the draft permit, unanswered questions about risks to human
health, carbon pollution, and environmental justice, the Department should withdraw the draft
permit and require supplemental information from Atlantic.
Sincerely,
David L. Neal
Senior Attorney
Southern Environmental Law Center

On behalf of:
North Carolina State Conference of Branches of the NAACP
Haliwa-Saponi Indian Tribe
North Carolina Environmental Justice Network
Sierra Club
Natural Resources Defense Council
Concerned Citizens of Tillery
North Carolina Conservation Network
Clean Air Carolina
North Carolina Council of Churches
North Carolina Interfaith Power and Light
350 Triangle
Rachel Carson Council
Southern Environmental Law Center

Page C.2-29
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Karen Bearden
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Monday, November 20, 2017 4:46:41 PM
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11/16/17
For the many reasons people have talked about and written about the health
dangers, climate impacts, environmental injustice, water and air issues of the
PROPOSED Atlantic Coast Pipeline, I respectfully ask NC DEQ to DENY the
permit for the Northhapmton Air Compressor Station!
Just this week, two studies have been released that are connected to the
proposed ACP pipeline and compressor station. The study, Fumes Across the
Fence-Line: The Health Impacts of Air Pollution from Oil and Gas Facilities on
African American Communities, was published Tuesday by the Clean Air Task
Force and the National Association for the Advancement of Colored People.This
Is an Emergency’: 1 Million African Americans Live Near Oil, Gas Facilities.
Link to study:
http://catf.us/resources/publications/files/FumesAcrossTheFenceLine.pdf
Link to article about study:
https://insideclimatenews.org/news/14112017/african-americans-exposed-oil-
gas-wells-refineries-health-risks-naacp-study
Exposure to air pollution is known to cause a vast array of respiratory health
problems, but in a new study, researchers at Columbia University's Mailman
School of Public Health have determined that air pollution can also weaken bones.
The paper, published in The Lancet Planetary Health, is the first to document
high rates of hospital admissions for bone fractures in communities with
elevated levels of ambient particulate matter (PM2.5).
Risk of bone fracture admissions is greatest in low-income communities. In the
U.S., air pollution is especially high in poorer communities.
Link to study: http://thelancet.com/journals/lanplh/article/PIIS2542-5196(17)30143-
2/fulltext#.WgWVqgG-zJg.twitter
Link to article about the study: https://www.ecowatch.com/osteoporosis-air-pollution-
2509102676.html?xrs=RebelMouse_fb&ts=1510607481
Let’s stop wasting time on building more fossil fuel infrastructure and move
SWIFTLY in NC to a fossil free and just transition to 100% renewable energy
NOW!!!
Page C.2-30
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Thanks! Peace and love for our beautiful Earth,
Karen Bearden
1809 Lakepark Drive
Raleigh, NC 27612
[e-mail]
Page C.2-31
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Jeannie Ambrose
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Monday, November 20, 2017 4:31:59 PM
Attachments:Public Comments on ACP Compressor Station-JA, Nov. 20, 2017.docx
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Here are my public comments on ACP/DAQ permit.
Thank you.
Jeannie Ambrose
Page C.2-32
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Public Comments on ACP Northampton Compressor Station Permit

Over the past seven years, I have been concerned about the harmful global impacts
to climate change that is due to fracking of natural gas shale. From reading the 2012
NCDENR study and closely following the proceedings of the Mining and Energy
Commission and its subcommittees, I became aware of the many problems
associated with natural gas operations and its transmission infrastructure.

Even when you don’t live in close proximity to the proposed route of the ACP and
compressor station(s) or other air polluting sources, people living downwind are
inhaling toxic fumes that are released or leaked. They may not even be aware of
poor air quality conditions if they can’t smell noxious or acrid odors. When toxic
gases are odorless, its release is often undetectable without using FLIR thermal
imaging cameras. Repeated exposure to high, short-term doses of toxic gases such
as, formaldehyde and VOCs, put individuals with compromised lung function at
greater risk. The anecdotal reports of health symptoms due to inhalation of air
toxins from compressor stations or fracking sites may vary by age but are
consistent. We are unlikely to know the full effect of the synergistic combinations of
toxic air emissions from various sources, or how the bio-accumulative, long- or
short-term exposure will impair human health or the environment. Although no
comprehensive epidemiological studies on health impacts from compressor stations
have been conducted, there are a few publications that are starting to address this.1

Here are my reasons for opposing the permitting of the ACP compressor station(s):

1. Economic benefits and environmental justice review. The proposed
compressor station at Northampton will be a permanent structure located in a rural,
mostly low-income, minority community. Its presence will not provide direct
economic benefits to local residents in the long run. After the initial construction
phase is completed, only a few permanent jobs are needed to routinely monitor and
maintain the facility. The compressor facility, typically operating 24/7, will be a new
source of air pollution and will only add more harmful air emissions (in tons/year)
to the total emissions that are currently released regionally.2 What non-polluting,
clean businesses would be attracted to relocating in this area to provide much-
needed, good job employment to this community?
The local community will be exposed to excessive noise levels,3 dust particles (fine
particulate matter), and odor problems from the compressor station. High levels of
toxic air emissions (spikes) are episodic: fluctuations in levels make it more difficult
to assess the potential health risks to individual residents. Fugitive emissions from
1 Southwest Pennsylvania Environmental Health Project. 2015. Summary on Compressor Stations and Health Impacts,
http://www.environmentalhealthproject.org/files/Summary Compressor-station-emissions-and-health-impacts-
02.24.2015.pdf; 2017. Russo and D.O. Carpenter. Health Effects Associated with Stack Chemical Emissions from NYS Natural
Gas Compressor Stations: 2008-2014. Technical Report of the SWPA Environmental Health Project.
2 2017. Lisa Sorg. Opponents, Supporters turn out in force over air permit for the Atlantic Coast Pipeline,
http://pulse.ncpolicywatch.org/2017/11/17/opponents-supporters-turn-force-air-permit-atlantic-coast-
pipeline/#sthash.ZenyuUcu.kaUN
3 2017. Jane Hoppin. A Pilot Study to Assess Residential Noise Exposure Near Natural Gas Compressor Stations,
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC5378322/
Page C.2-33
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
connectors and other components may occur as well. Leakage from failure of
mechanical components under high pressure can be expected over time. Current air
quality monitoring method needs to be revised to account for episodic air emissions.
More advanced air quality modeling studies are needed.

2. Safety hazards and environmental contamination. Scheduled or accidental
blowdowns can last up to three hours or more. The actual concentration of
contaminants in the plume will depend on makeup of natural gas constituents at the
time of the event. Although a nationwide or state inventory of compressor station
accidents is not available, explosions and fires at compressor stations are reported
in the news. Is there adequate funding for local emergency response staff to handle
and contain explosive situations? Are people aware of living within or close to a
blast zone?

3. Lack of public trust in energy corporations and EPA. Based on recent news
investigations, Duke Energy Progress has been reported to edit independent coal
ash science reports from two UNCC professors.4 Likewise, in frequent ads for the
proposed ACP, claims of need and benefits to NC’s economy does not ring true to
affected property owners.5 Eminent domain is a real issue–threatening the property
rights of long-time landowners–and is considered as a taking of land. Also, how will
Dominion Energy’s plans to extend the ACP pipeline into South Carolina (for the
LNG export market?) alter the design requirements for this permit?
In March of 2017, EPA Administrator Scott Pruitt announced a withdrawal of its
Information Collection Request from the oil and gas sector to respond to the EPA
survey of methane pollution from existing sources to identify sources of methane
emissions and develop and apply standards.6 In the prevailing political climate, any
federal studies to identify and correct air emission regulatory gaps and strengthen
enforcement are not likely.

Additional information is needed for DEQ to consider in its review of the
Northampton natural gas compressor station permit. Protect the air we breathe.
Reject the air permit.

Thank you for the opportunity to submit public comments on the ACP/DAQ Air
Quality Permit.

Jeannie Ambrose
675 Lichen Trail
Pittsboro, NC 27312
4 2017. WBT Investigation: Duke Energy Edited ‘Independent’ Coal Ash Report, http://wfae.org/post/wbtv-investigation-
duke-energy-edited-independent-coal-ash-report?utm_source=dlvr.it&utm_medium=twitter
5 2017. Erica Hellerstein. Indy Week, Duke Energy Wants to Build a $5 Billion Pipeline Through Eastern NC. They’ll Have to Go
Through Marvin Winstead First, https://www.indyweek.com/indyweek/duke-energy-wants-to-build-a-5-billion-pipeline-
through-eastern-north-carolina-theyll-have-to-go-through-marvin-winstead-first/Content?oid=8681735.
6 2017. EPA. Controlling Air Pollution from the Oil and Natural Gas Industry. Background on the Information Request for the
Oil and Natural Gas Industry. https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/background-
information-request-oil-and
Page C.2-34
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Ryan Emanuel
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Monday, November 20, 2017 4:25:11 PM
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attachment to [e-mail].
I wish to submit the following comments, specific to the proposed Atlantic Coast Pipeline's
Northampton County Compressor Station. I have many other air quality concerns related to
this project, but I limit my comments to the application at hand. Please contact me if you
require further clarification or would like to discuss my other concerns. I am happy to lend my
expertise in boundary layer meteorology and trace gas transport.
CO2 equivalent emissions of approximately 111,000 tpy (Table 3.9) are the equivalent
emissions of approximately 23,000 average automobiles. Please ask applicant to address how
these emissions fit into North Carolina's recent membership in the US Climate Alliance.
Please require the applicant to demonstrate compliance using continuous monitoring rather
than annual stack testing. Stack testing requires assumptions and extrapolations beyond tested
conditions. Continuous monitoring is more expensive, but that should be of little consequence
given the overall scope of this project.
Sincerely,
Ryan E. Emanuel, Ph.D.
-------------------------------------------
Ryan E. Emanuel, Ph.D.
Associate Professor and University Faculty Scholar
Department of Forestry and Environmental Resources
North Carolina State University
Campus Box 8008
Raleigh, NC 27695-8008 USA
tel: [phone]
email: [e-mail]
web: go.ncsu.edu/water
"All electronic mail messages in connection with State business which are sent to or
received by this account are subject to the NC Public Records Law and may be
disclosed to third parties." - NCSU Office of General Counsel
Page C.2-35
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Valerie Reynolds
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Monday, November 20, 2017 3:25:27 PM
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attachment to [e-mail].
Dear Mr. McEachern,
I am writing to voice my concern and opposition for the proposed natural gas
compressor station to be located in Northampton County, NC as part of the Atlantic
Coast Pipeline's required infrastructure. As consumption of natural gas has increased
across the country, the number of compressor stations needed to transport the
natural gas has also risen. However, what has not risen is the number of health
studies that examine the effects of living near a compressor station. Limited studies
suggest a negative correlation, citing higher concentrations of particulate matter and
volatile organic compounds, such as benzene, in nearby homes. Higher
concentrations of ozone and smog are also observed in these areas. As a result of
exposure to contaminants produced by compressor stations, local residents suffer
daily from dizziness, sore throat, and severe nosebleeds. Ozone alone is credited as
being the greatest contributor to asthma. The fact is that the activities associated with
fracking are taking place at a rate that far exceeds any studies on the health impacts
of such activities. Continuing this trend will put NC residents at greater risk, and
residents of Northampton County are already suffering. According to the 2017 County
Health Rankings for NC, Northampton County is one of the lowest performing
counties for health outcomes and health factors. To add a compressor station to this
population is unjust.
In addition to degrading air quality, compressor stations-and their pipeline
counterparts-are often routed through rural regions that disproportionately impact low
income and minority groups who often make a living off of their land and depend on
well water (ground water) as their primary drinking water and irrigation source. In NC,
this is no exception. All along the pipeline's route, household incomes are below the
state's median value. Furthermore, the pipeline would run through regions of the state
that contain some of the highest quality farmland. NC's agriculture industry faces
serious threats from development that is expected to accompany the proposed
pipeline, eliminating significant swaths of land that are currently being used for
agricultural purposes.
In closing, while I understand the necessity of a compressor station for the Atlantic
Coast Pipeline to be constructed in NC, I am not convinced that air quality will not be
compromised (nor that the pipeline is actually needed). The federal air quality
guidelines are not strict enough to ensure the safety of local residents. Without
ensuring the people of Northampton County (and other downwind counties) that their
air quality, and therefore their health, will not be compromised, I oppose the proposed
construction of the natural gas compressor station.
Page C.2-36
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Sincerely,
Dr. Valerie Reynolds
Geology Lecturer, UNC Charlotte
Page C.2-37
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Andrea Emanuel
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Monday, November 20, 2017 6:29:42 AM
Attachments:ACP_DEQ_compressor station.pdf
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Hi, Mr. McEachern-
Please see the attached document containing comments regarding the ACP.
Thank you.
Andrea Emanuel
Page C.2-38
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
November​ ​18,​ ​2017,

Mr.​ ​Charles​ ​McEachern
Engineer,​ ​Division​ ​of​ ​Air​ ​Quality
North​ ​Carolina​ ​Department​ ​of​ ​Environmental​ ​Quality

RE:​ ​Northampton​ ​Compressor​ ​Station
​ ​​ ​​ ​​ ​​ ​​ ​​ ​Draft​ ​Permit

Dear​ ​Mr.​ ​McEachern,

I​ ​am​ ​a​ ​North​ ​Carolina​ ​native,​ ​a​ ​healthcare​ ​planner​ ​for​ ​the​ ​State​ ​and​ ​a​ ​board​ ​member​ ​of​ ​Clean
Water​ ​for​ ​North​ ​Carolina.​ ​​ ​I​ ​write​ ​to​ ​you​ ​as​ ​a​ ​private​ ​citizen​ ​who​ ​is​ ​concerned​ ​about​ ​the
development​ ​of​ ​the​ ​Atlantic​ ​Coast​ ​Pipeline.​ ​​ ​I​ ​have​ ​been​ ​following​ ​the​ ​plans​ ​for​ ​the​ ​pipeline.​ ​The
amount​ ​of​ ​greenhouse​ ​gas​ ​pollution​ ​that​ ​would​ ​be​ ​created​ ​by​ ​this​ ​station​ ​renders​ ​it​ ​a​ ​facility​ ​that
should​ ​require​ ​major​ ​source​ ​permit​ ​requirements.​ ​I​ ​am​ ​convinced​ ​that,​ ​due​ ​to​ ​the​ ​ambiguity
surrounding​ ​the​ ​risks​ ​for​ ​the​ ​people​ ​of​ ​Northampton​ ​County​ ​that​ ​could​ ​be​ ​imposed​ ​by​ ​the
compressor​ ​station,​ ​the​ ​Division​ ​of​ ​Air​ ​Quality​ ​should​ ​​deny​ ​the​ ​draft​ ​permit​ ​for​ ​this
equipment.

The​ ​draft​ ​permit​ ​contains​ ​glaring​ ​weaknesses​ ​as​ ​it​ ​largely​ ​omits​ ​important​ ​information.​ ​​ ​Despite
the​ ​fact​ ​that​ ​toxic​ ​chemicals,​ ​including​ ​the​ ​carcinogenic​ ​formaldehyde​ ​and​ ​other​ ​VOCs,​ ​are
found​ ​in​ ​higher​ ​concentrations​ ​around​ ​compressor​ ​stations,​ ​the​ ​draft​ ​permit​ ​does​ ​not​ ​include
any​ ​requirements​ ​to​ ​monitor​ ​the​ ​level​ ​of​ ​pollutants​ ​that​ ​surrounding​ ​residents​ ​would​ ​be​ ​exposed
to.​ ​​ ​The​ ​census​ ​block​ ​group​ ​where​ ​the​ ​installation​ ​of​ ​the​ ​compressor​ ​station​ ​is​ ​planned​ ​is​ ​79%
African​ ​American,​ ​and​ ​as​ ​such,​ ​there​ ​is​ ​a​ ​potential​ ​for​ ​a​ ​disproportionate​ ​burden​ ​for​ ​a
community​ ​of​ ​color.​ ​Thus,​ ​lack​ ​of​ ​monitoring​ ​is​ ​especially​ ​problematic​ ​in​ ​Northampton​ ​County
where​ ​​other​ ​major​ ​polluting​ ​facilities​ ​are​ ​already​ ​burdening​ ​our​ ​fellow​ ​North​ ​Carolina​ ​residents
with​ ​toxic​ ​emissions​.

Finally,​ ​the​ ​language​ ​in​ ​the​ ​draft​ ​permit​ ​is​ ​vague​ ​-​ ​permissive​ ​at​ ​best​ ​-​ ​and​ ​invites​ ​conditions​ ​for
the​ ​surrounding​ ​community​ ​to​ ​be​ ​exposed​ ​to​ ​toxins​ ​without​ ​holding​ ​ACP​ ​owners​ ​and​ ​operators
accountable.​ ​​ ​As​ ​written,​ ​requirements​ ​are​ ​unclear​ ​as​ ​the​ ​authors​ ​of​ ​the​ ​permit​ ​have​ ​elected​ ​to
use​ ​phrases​ ​such​ ​as,​ ​‘to​ ​the​ ​extent​ ​practical’,​ ​‘within​ ​the​ ​limits​ ​of​ ​practicality’,​ ​and​ ​‘substantive
complaints’.​ ​‘Practical’,​ ​‘within​ ​the​ ​limits​ ​of​ ​practicality’​ ​and​ ​‘substantive’​ ​are​ ​not​ ​true​ ​parameters
and​ ​would​ ​easily​ ​leave​ ​communities​ ​without​ ​much​ ​recourse.

Therefore,​ ​I​ ​proffer​ ​three​ ​recommendations:​ ​DEQ​ ​should​ ​1)​ ​complete​ ​a​ ​rigorous​ ​environmental
justice​ ​review​ ​before​ ​granting​ ​the​ ​permit;​ ​2)​ ​fund​ ​a​ ​study​ ​that​ ​includes​ ​baseline​ ​data​ ​on​ ​relevant
physical​ ​and​ ​psychological​ ​indicators​ ​in​ ​the​ ​community​ ​surrounding​ ​the​ ​area​ ​of​ ​the​ ​planned
compressor​ ​station;​ ​and​ ​​ ​3)​ ​develop​ ​unequivocal​ ​language​ ​that​ ​is​ ​enforceable,​ ​rendering​ ​ACP’s
developers​ ​responsive​ ​to​ ​clear​ ​requirements​ ​such​ ​that​ ​they​ ​keep​ ​emissions​ ​below​ ​thresholds.

Page C.2-39
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
This​ ​draft​ ​permit​ ​is​ ​clearly​ ​out​ ​of​ ​alignment​ ​with​ ​the​ ​Governor’s​ ​commitment​ ​to​ ​combating
climate​ ​change,​ ​DEQ’s​ ​own​ ​Environmental​ ​Equity​ ​policy,​ ​its​ ​obligations​ ​under​ ​Title​ ​VI​ ​of​ ​the
Civil​ ​Rights​ ​Act​ ​of​ ​1964​ ​​ ​to​ ​consider​ ​environmental​ ​harms​ ​to​ ​minority​ ​and​ ​low-income
communities,​ ​and​ ​more​ ​generally,​ ​our​ ​State’s​ ​commitment​ ​to​ ​the​ ​safety​ ​and​ ​well-being​ ​of​ ​its
residents.

Again,​ ​I​ ​urge​ ​DEQ​ ​to​ ​deny​ ​the​ ​draft​ ​permit​ ​for​ ​the​ ​compressor​ ​station​ ​planned​ ​for​ ​Northampton
County.​ ​Thank​ ​you​ ​for​ ​your​ ​attention​ ​to​ ​this​ ​matter.

Best​ ​Regards,

Andrea​ ​Emanuel,​ ​PhD

Page C.2-40
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Cathy Scott
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Sunday, November 19, 2017 8:30:01 PM
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attachment to [e-mail].
Dear Charles McEachern,
There are many good reasons to turn down the Air Quality permit application, from the ACP,
for the compression station.
Some of those reasons involve long term thinking, and some short. They are all important for
those who will be around for the next generation or so, whether on not that is you and me!
Focusing on just two reasons:
The compressor station violates the mandate to protect the health and well being of the
inhabitants of the area. As you know from being in the area, it is an area of natural beauty,
especially in the eyes of someone like myself who was raised in a farming community. It is
also,historically, an area of low income residents and residents of color; some in both of these
groups have owned and worked land here for generations.
Here is what a report compiled by the NC NAACP says:
In Northampton County where the compressor station would be built, the population is
54.6 percent African American and the median household income is $31,453, nearly
$15,000 below the state average. Almost 32 percent of the county’s residents live in
poverty, the report notes, compared to 17.2 percent statewide.
The report says the overall cancer rate in the county is higher now than the state
average, with 517 cases per 100,000 people, compared to 489 cases per 100,000 people
across the state. Lung and bronchial cancers occur at a rate of 81 cases per 100,000
people in the county, while the state average is 70 cases.
Clean Water for North Carolina’s report from 2016 says compressors on gas pipelines emit
volatile organic compounds that are associated with higher risks of cancer, respiratory and
cardiovascular illness and birth defects, and complaints of headaches, sinus problems and skin
irritations. The closer people live to the compressors, the report said, the higher the risk of
problems.
It is known that the Northampton area already has other nearby pollution facilities, some of
which I saw when I walked the area in the spring of this year. There is another compressor
station in Pleasant Hill and a wood pellet plant. I hope and expect the DAQ must take into
consideration the cumulative amount of pollutants that the several facilities emit, when
considering adding on yet another pollution source, am I right?
There is also the possibility that additional compressor stations will need to be built, since the
number of stations mentioned in the application is lower than is typical for the distances
involved. That would mean that the permit has been issued for an incomplete application.
Page C.2-41
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Better to catch that earlier, rather than later!
I appreciate the scrutiny that North Carolina’s DEQ has brought to bear on several of the ACP
permit applications. Don’t think your rigor has gone unnoticed, nor unappreciated!
Many of us believe the ACP is an act of great folly as well as greed. We are protesting it for a
multitude of reasons having to do with an affection for the planet and the beings who live here.
As a permitting agency, you must stick to a consideration of the regulations that govern your
agency’s work, and I (and many of us) believe those regulations are sufficient to require you
to turn down this application, as lacking in detail, failing to meet standards of compliance in
monitoring, inappropriate for the communities affected, and failing to supply modeling of
pollution effects.
Thank you for reading through this; thank you for the work you do to protect the people and
the places we live.
Gratefully,
Cathy T. Scott
Asheville NC 28804
--
"Power at its best is love implementing the demands of justice, and justice at its best is
power correcting everything that stands against love.”
-Dr. Martin Luther King, Jr. (1967 Speech, “Where Do We Go From Here?”)

“Our ability to perceive quality in nature begins, as in art, with the pretty.
It expands through successive stages of the beautiful to values as yet uncaptured by language.”
― Aldo Leopold, A Sand County Almanac
Page C.2-42
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Scott Weir
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Sunday, November 19, 2017 8:02:54 PM
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attachment to [e-mail].
As an economist with a bachelor's degree in physics, I am strongly opposed to construction of
the proposed Atlantic Coast Pipeline in general, and in particular to the Horthampton
compressor station.
The science is unequivocal regarding the necessity of near-total abandonment of all fossil
fuels by the year 2050 in order to maintain a climate in which human beings may be able to
survive if our ingenuity and resilience can overcome the many severe difficulties in the
conversion. I have been following the science as it has developed--and the opposition to the
science, as if it were no more than opinion or value judgment--since 1972. The claim that
increased use of methane is necessary as a "bridge" until sufficient renewable energy capacity
is in place is simply false according to everything I read.
Not only is it now entirely feasible to ramp up renewable capacity about as rapidly as
additional fossil fuel capacity: The increased use of methane in the short run would increase
global temperature rise far beyond that caused by its carbon content alone, because of its
potency as a greenhouse gas in the short term, and because it is impossible to recover,
transport, and use methane fuel without significant leakage even in a best-case scenario, for
which fossil fuel extraction/conversion firms have a horrendous track record. That in turn
would make the transition to renewables slower and more difficult because it would divert
resources to dealing with the consequences of temperature rise that can easily be avoided by
eschewing the use of "natural gas."
If the pipeline and its support systems are to be built, it would be both immoral and
pragmatically foolish to do so without a great deal more attention to detail in all aspects of the
project, from general environmental pollution of air, water, and soil (much of it directly toxic),
to the manifold effects of such pollution on human health, to environmental justice (how about
building it primarily through subdivisions of homes whose owners can well afford the costs to
mitigate its pernicious effects?), to the inevitable diversion of resources from development of
clean and sustainable energy.
A Cuban refugee I knew some years ago who was building a sailboat to transport his family
from the West Coast to the archipelagos of the western Pacific said there are three ways to do
any project, but especially one on which people's lives depend: There is "it's right," there is
"it's good enough," and there is "oh, (bleep), it'll do." As best I can tell, the ACP in all its parts
is predicated on the latter. If it is worth doing, it is worth doing at least on the high side of well
enough--for those who will come after us, and who will curse us if we leave them with an
unworkable situation.
I urge DEQ and Governor Cooper to reject the draft permit for the Northampton compressor
station, and if it must eventually be built that the final permit hold it to the standard of "good
enough" as described above, that is to say, REALLY GOOD ENOUGH for the well-being of
ALL stakeholders present and future.
Page C.2-43
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Scott A. Weir, PhD (Economics), BA (Physics)
3509 Duke Homestead Rd
Durham, NC 27704
919-479-0294
Virus-free. www.avast.com
Page C.2-44
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Belinda Joyner
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Sunday, November 19, 2017 3:33:37 PM
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attachment to [e-mail].
Northampton County Compressor Station
My name is Belinda Joyner, I live and work in Northampton. We have enough pollution here to kill ten people a
day. Enviva who putting out two to three times the VOC its suppose to. then we have Kapstone , Georgia Pacific,
Piedmont Gas and the list could go on. We are human begins with the right to clean air and water.
DAQ as well as DEQ know that a natural gas pipeline isn't needed....... The only reason that Dominion, Duke
Engery and those that's associated with them want this pipeline is for self gain. The contractors, those who have
heavy equipment to help build this pipeline and anything else they want will profit.
They use jobs as a reason for the pipeline, they tell lies about industry needing natural gas what have they used all
these years. These people come into our communities and destroy them. People are living in BLAST Zones and
don't even know it. Our farm land being takes over for their gain. Wetland, forestry being destroyed animals have no
homes. River being polluted not to mention the fumes and noise coming from the Compressor station.
They wouldn't have any such thing like this in there community because it would bring there property value down.
WHAT ABOUT US????????????? We've worked hard for what we have and its not fair for them to profit off what
we worked for. They are killing us both ways.
I ask you to put yourself in our place would you want this in your community???
The pipeline comes with great danger. We know that one day we are all going to die, but we would like to die a
natural death and not be killed by explosions, methane gases and the likes that come from such things.
I ask you to deny any permits they request and do justice to those that feel like you all don't care. We are a
community of color whom they don't seem to think matter.
Page C.2-45
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Laura Manigrasso
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Sunday, November 19, 2017 11:30:16 AM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
Hello,
I am writing to ask the Division of Air Quality to deny the Air Quality permit for the proposed
Atlantic Coast Pipeline.
To even consider this permit, more information is needed, such as:
- accurate modeling of the expected air pollution from this compressor station
- monitoring of existing, nearby sources of air pollution.
To approve this permit, the DAQ must be able to guarantee no adverse health effects from the
compressor station - also including other nearby sources in their consideration of risk.
Other areas to consider:
- This proposed pipeline will damage farmland now and into the future. The area above the
pipeline will not be able to be used. Farmers with pipelines on their property note that the
yield has decreased.
- The siting of this compressor station will likely cause disproportionate environmental
burdens on low-income minorities and people of color. A comprehensive environmental
justice review seems necessary before consideration of a permit.
- The construction of this pipeline will have little economic advantage for the people of NC.
There will be few jobs generated and the price of electricity will go up to the benefit of Duke
Energy.
Please protect our health and air quality by denying this permit.
Thank you,
Laura Manigrasso
Page C.2-46
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Lars Nyland
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Sunday, November 19, 2017 10:39:29 AM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
I am writing to ask the Division of Air Quality to deny the Air Quality permit for the proposed Atlantic Coast Pipeline.
To even consider this permit, more information is needed, such as:
- accurate modeling of the expected air pollution from this compressor station
- monitoring of existing, nearby sources of air pollution.
I take the individual and compounded risk from the potential pollutants very seriously and ask you to do the same.
To approve this permit, the DAQ must be able to guarantee no adverse health effects from the compressor station - also
including other nearby sources in their consideration of risk.
Other areas to consider:
- This proposed pipeline will damage farmland now and into the future. The area above the pipeline will not be able to be
used. Farmers with pipelines on their property note that the yield has decreased.
- The siting of this compressor station will likely cause disproportionate environmental burdens on low-income minorities and
people of color. A comprehensive environmental justice review seems necessary before consideration of a permit.
- The construction of this pipeline will have little economic advantage for the people of NC. There will be few jobs generated
and the price of electricity will go up to the benefit of Duke Energy.
Please protect our health and air quality by denying this permit.
--
Lars Nyland
Page C.2-47
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Rebecca Ewing
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Sunday, November 19, 2017 8:46:22 AM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
Mr. McEachern,
The proposed Northampton Compressor Station, part of the Atlantic Coast Pipeline, would be
a detriment to the environment of our state. Please do not approve a permit for this pollution
emitter.
There are eight or more major pollutants emitted by compressor stations. Nitrogen oxide
emissions cause severe ozone alerts, which lead to increased illness in asthma and COPD
sufferers. Other pollutants contribute significantly to greenhouse effect and global warming.
The noise produced by the engines is non-stop and will reduce quality of life for the entire
surrounding community.
I also foresee this permit request as a “foot in the door” to ACP requesting additional
compressor stations along the route in North Carolina.
Please do not give this for-profit enterprise (not a utility request) a chance to pollute our
state! Health and safety should predominate in any permitting decision, not the intimidating
influence of mighty capital investors.
Sincerely,
Rebecca Ewing
Rebecca Ewing, M.A., J.D.
Lecturing Fellow
Duke University
Spanish Language Program
[e-mail]
[phone]
2122 Campus Drive
Durham, NC 27708
Page C.2-48
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Francine Stephenson
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Saturday, November 18, 2017 9:55:02 AM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
Mr. McEachern,
The proposed Northampton Compressor Station, part of the Atlantic Coast Pipeline, would be
a detriment to the environment of our state. Please do not approve a permit for this pollution
emitter.
There are eight or more major pollutants emitted by compressor stations. Nitrogen oxide
emissions cause severe ozone alerts, which lead to increased illness in asthma and COPD
sufferers. Other pollutants contribute significantly to greenhouse effect and global warming.
The noise produced by the engines is non-stop and will reduce quality of life for the entire
surrounding community.
I also foresee this permit request as a “foot in the door” to ACP requesting additional
compressor stations along the route in North Carolina. Just wait and see!
Please do not give this for-profit enterprise (not a utility request) a chance to pollute our state!
Health and safety should predominate in any permitting decision, not the intimidating
influence of mighty capital investors.
Francine Stephenson
2012 Raccoon Run
Clayton, NC
Page C.2-49
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Keely Wood
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Friday, November 17, 2017 12:04:53 PM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
The North Hampton Compressor station application is in an area of 79.2% of the population is
African American. This area is a low income community. The DEQ must consider the projects that
harm minority and low income residents. Title VI of the Civil Rights Act requires DEQ to review the
harmful action before approving a compressor station. DAQ should rescind the draft permit and
require the Company to obtain an air toxic permit that fully evaluates the risks to the public.

Keely Wood
919-708-5221

Page C.2-50
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Isabel Geffner
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Friday, November 17, 2017 8:19:52 AM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
To Whom It May Concern:
I urge you to reject the Atlantic Coast Pipeline compressor station in North Carolina.
Low-income African Americans who live along the pipeline route – in what the report
calls fence-line communities – already are at higher risk of illness than the general
population, and exposure to pollutants associated with the pipeline would make their
problems worse. The ACP crosses more than 1300 parcels of land, and is near
enough to thousands of homes that, in the event of a rupture or explosion, it will
endanger both homes and families in them, as well as farm animals and pets.
Please protect me, my family, my neighbors, and the future of our state by ensuring
that we do not have this compressor station in our state.
Thank you.
Isabel Geffner
Page C.2-51
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:Christine Ellis
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Thursday, November 16, 2017 11:03:04 PM
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
What are our concerns about Air Quality and the proposed Northampton Compressor
Station?
the permit application DOES NOT:
contain critical information needed to properly regulate the compressor station
take into account the impact of other nearby major polluters
the Air Quality permit DOES NOT:
include enforceable requirements, instead only requiring
the facility’s operators “to the extent practical, consistent with good air pollution control
practice for minimizing emissions”
a completely “complaint-driven” system for dust (particulates) control and odor control
rather than an enforceable dust control plan that includes monitoring
acknowledge the impact of total air pollution from major nearby polluting facilities (e.g., the
Pleasant Hill compressor station, Georgia Pacific mill, Enviva wood pellet plant)
include monitoring requirements for Volatile Organic Compounds or Hazardous Air
Pollutants
require regional modeling and monitoring to establish clear limits to releases from the
compressor station in order to protect local air quality and the nearby community
consider the project’s environmental harms to minority and low-income communities, as
required by DEQ’s Environmental Equity policy and its obligations under Title VI of the Civil
Rights Act of 1964
The facility will put more hazardous air pollutants, nitrogen oxides and volatile organic compounds
(precursors of ozone, also known as smog), particulate matter, greenhouse gases, and other
pollutants into the air that people breathe. All of these pollutants are harmful to people’s health.
Reference the October 2017 report from the Southwest Pennsylvania Environmental Health
Project reporting that every compressor station routinely studies released large volumes of
chemicals associated with respiratory, cardiovascular and neurological problems in nearby
residents. Reference FERC EIS referenced studies reporting that those who live near compressor
stations have reported a number of symptoms from skin rashes to gastrointestinal, respiratory and
neurological problems.
What do we ask DEQ/DAQ to do?
DAQ must ensure no adverse health effects from this facility, taking into account
emissions from other nearby sources.
DAQ has not performed the analysis to make this determination, required before issuing a permit.
The department should require modeling of the expected air pollution from this facility and
monitoring of existing, nearby major sources of air pollution.
DEQ must consider the project’s environmental harms to minority and low-income
communities.
The Northampton compressor station is within a census block group where 79.2 percent of the
population is African American. DEQ must complete a rigorous environmental justice review
Page C.2-52
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
before it can grant this permit.
DEQ should update its regulations and subject facilities like the Northampton compressor
station to major source permit requirements as the greenhouse gas major source
threshold is exceeded.
Given Governor Cooper’s commitment to combating climate change, the compressor station must
be considered a major new source of greenhouse gas pollution, with nearly 130,000 tons per year
of carbon dioxide equivalent emissions. Methane is an especially powerful greenhouse gas, at
least 86 times more potent than carbon dioxide over a 20 year time frame.
DAQ should rescind the draft permit and require the Company to obtain an air toxic permit
that fully evaluates the risks to the public.
More information is needed about the effects of air pollution from the proposed compressor station
before an air quality permit can be issued.
--
Support Fishable, Swimmable, Drinkable Water for Our Families and Our Future.
www.winyahrivers.org
Christine Ellis
Deputy Director / River Advocate
Winyah Rivers Foundation, Inc.
www.winyahrivers.org
[e-mail]
[phone]
A proud member of WATERKEEPER® ALLIANCE.
Page C.2-53
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
From:John Runkle
To:SVC_DENR.publiccomments
Subject:[External] ACP/DAQ
Date:Thursday, November 16, 2017 4:26:31 PM
Attachments:Summary Compressor-station-emissions-and-health-impacts-02.24.2015.pdf
Health_Effects_Associated_with_Stack_Chemical_Emissions_from_NYS_Natural_Gas_Compressor_Stations_2008_2014.pdf
Fumes-Across-the-Fence-Line_NAACP_CATF.pdf
Request for Rehearing ACP.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to [e-mail].
NC WARN is a member-based nonprofit tackling the climate crisis – and other hazards posed by
electricity generation – by watch-dogging Duke Energy practices and building people power for a
swift North Carolina transition to clean, renewable and affordable power generation and increased
energy efficiency. On its behalf, please find the following attached reports on air quality and health
for your review of the impacts of the proposed Northampton Compressor Station:

1. Institute for Health and the Environment, ”Health Effects Associated with Stack Chemical
Emissions from NYS Natural Gas Compressor Stations: 2008 – 2014,” A Technical Report
Prepared for the Southwest Pennsylvania Environmental Health Project. October 12, 2017.

2. Congressional Research Service, “An Overview of Air Quality Issues in Natural Gas Systems,”
February 4, 2016.

3. NAACP, “Fumes Across the Fence-line: The Health Impacts of Air Pollution from Oil & Gas
Facilities on African American Communities,” November 2017.

I am also including the Request for Rehearing submitted by NC WARN, Clean Water for NC, BREDL,
and 18 other public interest groups to the Federal Energy Regulatory Commission (FERC) earlier this
week. The sections on greenhouse gases, environmental justice, and the cumulative impacts of the
project, including the proposed Northampton Compressor Station, are directly relevant to your
consideration.

Please notify me of any action you make on this permit.

FOR NC WARN

John D. Runkle
Attorney at Law
2121 Damascus Church Rd.
Chapel Hill, NC 27516
919-942-0600
[e-mail]

Page C.2-54
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
UNITED STATES OF AMERICA
BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

________________________________
In the matter of: )
)
Atlantic Coast Pipeline, LLC )
Docket Nos. CP15-554-000 )
PF15-6-000 )
) November 13, 2017
Dominion Transmission, Inc. )
Docket Nos. CP15-555-000 )
PF15-5-000 )
)
Atlantic Coast Pipeline, LLC and )
Piedmont Natural Gas Company )
Docket No. CP15-556-000 )
________________________________ )

REQUEST FOR REHEARING, RESCISSION OF CERTIFICATE,
AND STAY OF PROJECT BY THE PUBLIC INTEREST GROUPS

PURSUANT TO Rule 713 of the Rules of Practice and Procedure of the Federal Energy
Regulatory Commission (“Commission”), 18 C.F.R. § 385.713, now come the Public
Interest Groups, by and through the undersigned counsel, with a request for a rehearing
and rescission of the Commission’s Order Issuing Certificates (“Order”), October 13,
2017, granting a conditional certificate to Dominion Resources and the other members
of the joint venture (collectively, “Dominion.”), under authorization under sections 7(b)
and 7(c) of the NGA and Part 157 of the Commission’s regulations to construct and
operate the Atlantic Coast Pipeline (“ACP”).1 As part of this request, the Public Interest
Groups seek a stay of the project.
1 The ACP includes three compressor stations and at least 564 miles of pipeline across West Virginia,
Virginia, and North Carolina. The ACP is owned by a joint venture of Dominion Resources, Inc., Duke
Page C.2-55
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
The Public Interest Groups seek rehearing, rescission, and stay of the
Commission’s Order because the environmental review underlying the conclusions in
the Order fail to meet the requirements of the National Environmental Policy Act
(“NEPA”), 42 U.S.C. 4321 ff., its implementing regulations, 40 C.F.R. Parts 1500 –
1508, NEPA guidance documents, and related Commission guidance documents,
PURSUANT TO Commission Rule 212 at 18 C.F.R. § 385.212, NEPA at 42
U.S.C. § 4332, and the NEPA regulations at 40 C.F.R. § 1502.9, the Public Interest
Groups further renew their motions to the Draft Environmental Impact Statement
(“DEIS”) on the ACP issued on December 30, 2016 in the above captioned dockets.

STANDING
The Public Interest Groups are not-for-profit corporations under the laws of North
Carolina and Virginia law acting in the public interest, and community groups organized
to protect the family and property of their members. The Public Interest Groups are
North Carolina Waste Awareness and Reduction Network (“NC WARN”); Clean Water
for North Carolina; the Blue Ridge Environmental Defense League (“BREDL”), and its
chapters, Protect Our Water! (Faber, VA), Concern for the New Generation
(Buckingham, VA), Halifax & Northampton Concerned Stewards (Halifax and
Northampton, NC), No Pipeline Johnston County (Johnston, NC), Nash Stop the
Pipeline (Spring Hope, NC), Wilson County No Pipeline (Kenly, NC), Sampson County
Citizens for a Safe Environment (Faison, NC), No Fracking In Stokes (Walnut Cove,
NC), and Cumberland County Caring Voices (Eastover, NC); Concerned Citizens of
Energy Corporation, Piedmont Natural Gas Company, Inc. (now a wholly owned subsidiary of Duke
Energy), and AGL Resources, Inc.
Page C.2-56
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Tillery; the NC Alliance to Protect the People and the Places We Live; Beyond Extreme
Energy; Triangle Women's International League for Peace and Freedom; Haw River
Assembly; Winyah Rivers Foundation, Inc.; River Guardian Foundation; 350.org
Triangle; and the Chatham Research Group.
The Public Interest Groups and their members will be significantly affected and
aggrieved by the proposed ACP. Many of the economic concerns and environmental
impacts affecting the Public Interest Groups and their members have not been taken
into consideration by the Commission in its issuance of the Certificate.
Several of the Public Interest Groups, including but not limited to NC WARN and
BREDL, are intervenors in this proceeding pursuant to Commission Notice Granting
Late Interventions, November 8, 2016. As intervenors they have the ability to make
motions to the Commission pursuant to Commission Rule 212, 18 C.F.R. § 385.212,
and the present request for rehearing.
Although the interests of the intervenors are more clearly stated in their
respective motions to intervene, those same interests are held by each of the Public
Interest Groups.2 On April 5, 2017, the Public Interest Groups filed Joint Comments by
Public Interest Groups on Draft Environmental Impact Statement detailing flaws in the
DEIS.3 Those comments and the comments from many other parties demonstrate the
fundamental flaws in the Dominion application, the environmental documents, and the
resulting Order.
2 FERC Accession Nos. 20160411-5055 and 20151109-5041.

3 Adopted herein by reference, FERC Accession No. 20170405-5307.

Page C.2-57
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Fundamental due process demands an open and transparent comment process,
one which is based on all the facts. The Public Interest Groups have further made
several motions to supplement the DEIS based on new filings and new information.4
These motions are adopted herein by reference.

STATEMENT OF RELEVANT FACTS
On September 18, 2015, the ACP LLC filed an application under section 7(c) of
the Natural Gas Act, requesting authorization to construct, own, and operate the ACP,
including three compressor stations and at least 564 miles of pipeline across West
Virginia, Virginia, and North Carolina. The ACP is owned by a joint venture of Dominion
Resources, Inc., Duke Energy Corporation, Piedmont Natural Gas Company, Inc. (now
a wholly owned subsidiary of Duke Energy), and AGL Resources, Inc.
On October 2, 2015, the Commission filed its Notice of Application, providin g
additional details about the application and outlining the review process, and
opportunities for public comment.
The Commission has authority under NGA Section 7 (Interstate Natural Gas
Pipelines and Storage Facilities) to issue a Certificate of Public Convenience and
Necessity to construct a natural gas pipeline. As described in the Commission guidance
manuals, environmental documents are required to describe the purpose and
commercial need for the project, the transportation rate to be charged to customers,
4 Joint Motion to Rescind or Supplement DEIS, January 23, 2017, FERC Accession No. 20170124-5017;
Supplement to Joint Motion To Rescind Or Supplement DEIS Based on New Filings, February 15, 2017,
FERC Accession No. 20170215-0507; Joint Public Interest Groups 2nd Supplement to Motion to Rescind
or Supplement DEIS Based on New Filings, July 17, 2017, FERC Accession No. 20170717-5145; Public
Interest Groups’ New Motion to Supplement DEIS Based on New Filings, October 9, 2017, FERC
Accession No. 20171010-5108.
Page C.2-58
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
proposed project facilities, and how the company will comply with all applicable
regulatory requirements.5 The applicants must evaluate project alternatives, identify a
preferred route, and complete a thorough environmental analysis – including
consultation with appropriate regulatory agencies, data reviews, and field surveys. The
Commission is required to analyze the information provided by Dominion to determine if
the project is one of public convenience and necessity. The purpose of the
Commission’s review is to reduce overbuilding of pipeline capacity in order to protect
consumers and property owners.
As part of its review process, the Commission prepares environmental
documents, and in this case, a DEIS was prepared and released on December 30,
2016. As part of the release, the Commission provided a public comment period until
April 6, 2017. Subsequently, the Commission scheduled “public comment sessions” in
ten locations along the ACP route to allow for public comments.
The public comment sessions and comment period were not on the completed
application. The application was supplemented some eighteen times after the comment
period on the DEIS was ended, another five times after the Final Environmental Impact
Statement (“FEIS”) was issued, and at least three times after Commission issued the
Certificate.6 Many of these supplemental filings are not simply de minimus changes but
are significant modifications to routes and impact analysis, including but not limited to:
5 Both the FERC Guidance Manual for Environmental Report Preparation (August 2002) and the Draft
Guidance Manual for Environmental Report Preparation (December 2015) provide the minimum analysis
required by the agency in preparing environmental documents. Neither guidance manual discusses the
requirement to supplement environmental documents so the Commission must rely on NEPA guidance.

6 See Appendix A to Public Interest Groups’ Second Supplement to Joint Motion to Rescind or
Supplement DEIS Based on New Filings, July 17, 2017, FERC Accession No. 20170717-5145, for the 18
filings subsequent to the issuance of the DEIS. The additional
Page C.2-59
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
a. route changes;
b. archaeologic and cultural sites;
c. historic properties in West Virginia, Virginia, and North Carolina;
d. supplemental updates on compressor stations, metering and regulation station;
e. steep slopes in West Virginia and Virginia;
f. impacts of forest fragmentation on bird species;
g. aquatic species removal;
h. maps and analysis of non-jurisdictional facilities;
i. engineering updates on horizontal directional drilling;
j. river crossings;
k. hydrofracture risks;
l. cultural resources in West Virginia, including cemeteries;
m. restoration plans for wetlands;
n. considerations of soil, erosion, steep slopes;
o. direct impacts on forested sites in West Virginia, Virginia, and North Carolina;
p. impacts on streams and biotic resources;
q. removal and relocation of aquatic species; and
r. correspondence with state agencies and between state and federal agencies on
water quality, air quality, wildlife resources, threatened and endangered species,
and mitigation.
This new information in multiple filings clearly supplements the information in the
original application, the information supplied to FERC staff for their review, and any
information available to intervenors and the public.
Page C.2-60
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
The FEIS was issued on July 21, 2017.7
The conditional Order sub judice was issued on October 13, 2017.8 Appendix A
to the Order contains 73 conditions, ranging from ministerial to substantive
requirements.

CONCISE STATEMENT OF ALLEGED ERRORS
I. The Commission failed to supplement its environmental documents as
required by Federal statutes, implementing regulations, and guidance documents.
II. The Commission in its Order fails to adequately justify the need for the project
contrary to its own Certificate Policy Statement.
III. The Commission in its Order utilizes an invalid standard for consideration of
necessary state-issued permits and permissions.
IV. The Commission in its Order and supporting environmental documents fails to
adequately assess reasonably foreseeable greenhouse gas emissions and climate
change impacts from the Project.
V. The Commission in its Order fails to find that low-income, African-American,
and Native American families in North Carolina will bear a disproportionate impact from
the proposed pipeline.
VI. The Commission in its Order and supporting environmental documents fails
to adequately consider all reasonable direct and indirect impacts and cumulative
7 FERC Accession No. 20170721-3017.

8 161 FERC ¶ 61,042; FERC Accession No. 20171013-4003.
Page C.2-61
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
impacts, including the upstream and downstream impacts associated with gas
development and compressor stations.
VII. The Commission in its Order ignores planned and reasonably foreseeable
major expansions of the pipeline route and capacity, including the Piedmont Pipeline,
expansion into South Carolina, and other route and capacity expansions.

STATEMENT OF ISSUES
The Public Interest Groups maintain that the Project is not in the public interest
and that the Commission failed to meet its obligations under NEPA by authorizing the
Project without properly preparing and evaluating environmental documents that
appropriately assessed the Project’s potentially significant impacts on the economy,
human health, quality of life, and the environment. The Commission continues to err in
concluding that the Project will not have a significant impact on the quality of the human
environment; discounting the economic consequences; continuing to reject alternatives,
including the no action alternative; and in failing to ensure the implementation of
necessary measures to avoid significant adverse impacts from the Project.
The Commission has not accurately assessed many factors that would affect this
Project, including but not limited to the fundamental need for the pipeline, environmental
justice considerations, impacts on climate, the impacts of expanding fracking, the
cumulative impacts, and eminent domain. It is also evident that the approval of
potentially devastating impacts does not take into account the significant damage that
would be done over the long term even with the attempt to mitigate individual,
immediate environmental concerns. Specifically, this is contrary the purpose of the
Page C.2-62
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
NEPA review, i.e., “to ensure that the agency has adequately considered and disclosed
the environmental impact of its actions and that its decision is not arbitrary or
capricious.” Baltimore Gas & Electric Co. v. NRDC, 462 U.S. 87, 97-98, 103 S.Ct. 2246,
76 L.Ed.2d 437 (1983).
The Commission’s decision to grant a certificate to construct the ACP is a “major
Federal action” within the meaning of the National Environmental Policy Act (“NEPA”),
and any consideration of the certificate must be preceded by the preparation of an
Environmental Impact Statement (“EIS”). Pursuant to 42 U.S.C. § 4332, environmental
documents, including the DEIS under consideration, must address:
“(i) the environmental impact of the proposed action, (ii) any adverse
environmental effects which cannot be avoided should the proposal be
implemented, (iii) alternatives to the proposed action, (iv) the relationship
between the local short-term uses of the project as compared to the long term
use of the land, and (v) any irreversible and irretrievable commitments of
resources which would be involved in the proposed action should it be
implemented.”

The principal case on the adequacy of environmental documents, Marsh v. Oregon
Natural Resources Council, provides that under NEPA, “agencies [must] take a ‘hard
look’ at the environmental effects of their planned action.”9 As discussed throughout
these comments, the Commission’s analysis in the DEIS for the proposed ACP fails to
meet NEPA’s standards in numerous ways: it fails to address all of the environmental
impacts of the Project, effects that cannot be avoided, the alternatives to the proposed
action, short-term versus long term impacts, and commitments of resources.
The Public Interest Groups and other members of the public, and state and
Federal agencies have raised substantial questions as to whether the Project will have
9 490 U.S. 360, 374, 109 S.Ct. 1851, 104 L.Ed.2d 377 (1989).

Page C.2-63
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
significant impacts on the human environment. The Order’s lack of critical consideration
of the deficient analysis in the DEIS and FEIS demonstrates that the Commission failed
to take the requisite “hard look” at the Project’s impacts, as required by NEPA.
Each issue in support of the request for rehearing is provided below:

I. The Commission failed to supplement its environmental documents as
required by Federal statutes, implementing regulations, and guidance
documents.

In the Order, ¶¶ 200-202, the Commission denied the motions of several
commenters and intervenors, including those of the Public Interest Groups, claiming the
massive, substantive new filings by Dominion significantly supplementing required the
DEIS to be supplemented and reissued. The purposed two-prong test used by the
Commission is summarized in ¶ 202:
202. As shown in the final EIS, the additional information submitted by the
applicants between the issuance of the draft EIS and final EIS did not
cause the Commission to make “substantial changes in the proposed
action,” nor did it present “significant new circumstances or information
relevant to environmental concerns.” The final EIS analyzed the relevant
environmental information and recommended environmental conditions,
which we are imposing in this order, that must be satisfied before the
applicants may proceed with their projects.

As noted above, the application was supplemented some eighteen times after the
comment period on the DEIS was ended, another five times after the Final
Environmental Impact Statement (“FEIS”) was issued, and at least three times after
Commission issued the Certificate. As shown below, the Commission’s unsupported
assertion that the additional information was not significant and did not cause the
Commission to make changes to the project does not respond to the legal standard
Page C.2-64
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
whether the additional information required the Commission to supplement the
environmental documents under NEPA.
Pursuant to NEPA at 42 U.S.C. § 4332, and the rules promulgated under it
implementing its procedural provisions, and specifically 40 C.F.R. § 1502.9(c)(1)(ii), the
test is whether “[t]here are significant new circumstances or information relevant to
environmental concerns and bearing on the proposed action or its impacts.” As such,
the Commission is required to supplement the DEIS after receiving the new filings.
Rules promulgated by the Council on Environmental Quality pursuant to NEPA provide
mandatory guidance to all Federal agencies on the preparation of environmental
statements. 40 CFR 1502.9(c)(1)(ii) specifically addresses the obligation of the
agencies to supplement to the environmental statements, stating:
(c) Agencies:

(1) Shall prepare supplements to either draft or final environmental impact
statements if:

(i) The agency makes substantial changes in the proposed action that are
relevant to environmental concerns; or

(ii) There are significant new circumstances or information relevant
to environmental concerns and bearing on the proposed action or its
impacts.

(emphasis added). Granted there may no doubt be filings with only de minimus
changes, but this has not been the case herein. As shown above, the new filings by
Dominion throughout the application review process are squarely within the mandates
of this rule. The information is significant and directly relevant to environmental
concerns and impacts addressed in the DEIS, and after review by the agency staff, and
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public and state and Federal agency review, the information in the new filings are likely
to have a bearing on the Commission’s action.
The information in new filings is both substantive and relevant, fitting clearly
under the provisions of 40 CFR 1502.9(c)(1)(ii). Therefore, agency staff and the
Commission are required to review the new information and supplement the DEIS, with
a new public comment process, including new public comment sessions. Case law on
the agency’s requirement to supplement an environmental document is clear. New
information causes environmental documents to be supplemented, even after the
environmental document has been completed and the agency action taken. In its review
of one action, the Court found there "are significant new circumstances or information
relevant to environmental concerns and bearing on the proposed action or its impacts."
Norton v. Southern Utah Wilderness Alliance, 542 U.S. 55 (2004) (new study of use of
park lands). Of course, not all new information is significant or relevant; but the
Commission is required to take a “hard look” at the new information and after review,
incorporate the new information into the relevant environmental documents. As
discussed in Marsh v. Oregon Natural Resources Council, 490 U.S. 360, 109 S.Ct.
1851, 104 L.Ed.2d 377 (1989),
The parties are in essential agreement concerning the standard that
governs an agency's decision whether to prepare a supplemental EIS.
They agree that an agency should apply a "rule of reason," and the cases
they cite in support of this standard explicate this rule in the same basic
terms. These cases make clear that an agency need not supplement an
EIS every time new information comes to light after the EIS is finalized. To
require otherwise would render agency decisionmaking intractable, always
awaiting updated information only to find the new information outdated by
the time a decision is made. On the other hand, and as the petitioners
concede, NEPA does require that agencies take a "hard look" at the
environmental effects of their planned action, even after a proposal has
received initial approval.
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The Court endorsed the “hard look” at new information even after a proposal had
received its initial approval, and permit, from the agency. “When new information is
presented, the agency is obligated to consider and evaluate it and to make a reasoned
decision as to whether it shows that any proposed action will affect the environment in a
significant manner not already considered.”10
The Public Interest Groups believe the mandate for a full analysis of the “public
convenience and necessity” for pipelines involves public and state and Federal agency
comments on a complete application. The new, late-filed information from Dominion is
relevant and significant, directly concerning many of the environmental issues the
Commission is required to review and fully analyze. The burden is on the Commission
to allow the full investigation of the environmental risks and costs associated with the
ACP, including all new and supplemental information. This goes far beyond the “we
didn’t change our mind” rationale provided in the Order. It is apparent Dominion’s
practice is to frequently supplement its application without regard for an orderly process
and by flaunting Commission and NEPA rules. This has been condoned by the
Commission in its failure to supplement its environmental documents, and allow public
review and comment.

II. The Commission in its Order fails to adequately justify the need for the project
contrary to its own Certificate Policy Statement.

In its needs determination, the Commission relies almost completely on
precedent agreements as generally the best evidence for determining market need. The
10 Ibid., 490 U.S. at 374; also endorsed by the Court in Arkansas Wildlife v. U.S. Army Corps, 431 F.3d
1096 (Fed. 8th Cir., 2005).
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Commission’s rationale for the need for the Project is almost entirely based on affiliate
transaction, one of the owners of the Project selling to itself. This is contrary to the
Commission’s own policy statement regarding new natural gas pipelines, which
established a policy determining economic need that allowed the applicant to
demonstrate need relying on a variety of factors, including “environmental advantages
of gas over other fuels, lower fuel costs, access to new supply sources or the
connection of new supply to the interstate grid, the elimination of pipeline facility
constraints, better service from access to competitive transportation options, and the
need for an adequate pipeline infrastructure.”11 As Commissioner LaFleur notes in her
dissent, “the Commission’s implementation of the Certificate Policy Statement has
focused more narrowly on the existence of precedent agreements.”12
The end use of the natural gas is a crucial measure of need. In the present
matter, Dominion “estimates that 79.2 percent of the gas will be transported to supply
natural gas electric generation facilities, 9.1 percent will serve residential purposes, 8.9
percent will serve industrial purposes, and 2.8 percent will serve other purposes such as
vehicle fuel.”13 Dominion and Duke Energy, and its affiliate Piedmont, are the major
owners and investors in the Project, yet will at the same time be the major beneficiaries
of it.
11 Statement of Policy, PL99-3-000 88 FERC ¶ 61,227, www.ferc.gov/legal/maj-ord-reg/PL99-3-000.pdf,
as clarified in PL99-3-001,www.ferc.gov/legal/maj-ord-reg/PL99-3-001.pdf, and PL99-3-002
www.ferc.gov/legal/maj-ord-reg/PL99-3-002.pdf

12 Certificate, Dissent, page 4.

13 ACP FEIS at 1-3.
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In their Joint Comments, pages 17 – 53, the Public Interest Groups present
arguments the Commission’s approval of the need for the project.14 In summary, the
Commission failed because:
a. it did not compare the expressed needed for the project to the “no action”
alternative;
b. it did not rigorously explore or objectively evaluate reasonable alternatives;
c. it failed to provide a higher level of scrutiny for the affiliate transactions; and
d. it condoned the shifting of all economic risk from shareholders to ratepayers.
In addition the Commission failed to include in its analysis that:
e. natural gas companies have a history of overearning on pipelines;
f. natural gas companies have a history of overbuilding pipelines; and
g. existing pipelines are underutilized.
One of the crucial alternatives to the gas transmission pipeline, renewable energy, was
summarily dismissed by the Commission in its Order, ¶ 57:
With respect to the use of existing infrastructure or new renewable
generation to meet the project's need, our environmental review
considered the potential for energy conservation and renewable energy
sources, and the availability of capacity on other pipelines, to serve as
alternatives to the ACP Project and concluded that they do not presently
serve as practical alternatives to the project. Thus, contrary to commenters'
assertions, we are not persuaded that authorization of the ACP Project
would lead to the overbuilding of pipeline infrastructure.
.
As shown below, all upstream and downstream impacts, such as impacts on the
climate, families living along the line, and the environment were demonstrably flawed in
the Commission’s environmental documents it relied on to issue the Certificate. In
14 It is the understanding of the Public Interest Groups at least one of the other intervenors are presenting
more complete arguments on the Order’s failure to adequately address the need for the project. The
Public Interest Groups join in those arguments by reference.
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assessing the need for the project, the Commission selectively chose beneficial data
points supporting its conclusion, with analysis or due consideration.

III. The Commission in its Order utilizes an invalid standard for consideration of
necessary state-issued permits and permissions.

The Order sub judice is conditional on future actions by North Carolina and the
other states on various state-issued permits and permissions. The Commission’s
erroneous standard for necessary state-issued permits and permissions is both
problematic and overreaching. The Order, ¶324, attempts to assert an extremely broad
range of Federal preemption over matters that clearly are within the various state’s
jurisdictions:
324. Any state or local permits issued with respect to the jurisdictional
facilities authorized herein must be consistent with the conditions of this
order. The Commission encourages cooperation between interstate
pipelines and local authorities. However, this does not mean that state and
local agencies, through application of state or local laws, may prohibit or
unreasonably delay the construction or operation of facilities approved by
this Commission.

The authorities cited by the Commission in footnote 464 in support of this assertion are
not germane to the decisions North Carolina and the states are required to make
regarding the 401 water quality certification, erosion and sedimentation permits, and air
quality permits.
The relevant case giving North Carolina and the other states the ability to make
permit decisions which may have the effect of stopping a pipeline is Constitution
Pipeline Co. v. New York State Department of Environmental Conservation , No. 16-
1568 (2d Cir. 2017) in which the court makes it clear a state can deny a 401 water
quality certification of a pipeline if the project does not meet state standards. The
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Commission ignores this case and maintains its decision is the only decision that
matters. To the contrary, the Commission can only issue a permit for a pipeline project
until after the state makes its decisions on water quality, erosion control, and crucial to
this project, the air quality permit for the proposed compressor station in North Carolina.

IV. The Commission in its Order and supporting environmental documents fails to
adequately assess reasonably foreseeable greenhouse gas emissions and
climate change impacts from the Project.

As demonstrated in April 5, 2017 Joint Comments by Public Interest Groups on
Draft Environmental Impact Statement, pages 87 – 101, and through comments from
many other parties, the application, the environmental documents, and the Order were
flawed as each discounted the greenhouse gas emissions and impact on the climate
crisis from the proposed pipeline.15 In its Order, ¶ 296, the Commission acknowledges
this:
296. Interveners and commenters also assert that the Commission must
consider the impacts on climate change as a result of the end-use
consumption of the natural gas transported by the pipeline.

The Commission then proceeds to outline its inadequate analysis of the impacts of the
proposed pipeline on the climate and addresses Sierra Club’s motion regarding the
inadequacies in the analysis.16
However, in light of the recent decision by the D.C. Circuit Court of Appeals in
Sierra Club v. FERC, (D.C. Cir. 2017), the Commission must revisit its superficial
15 FERC Accession No. 20170405-5307.

16 The Public Interest Groups support the Sierra Club’s motion on September 18, 2017, Notice of New
Authority and Request for Supplemental Environmental Impact Statement for the Atlantic Coast Pipeline
and Supply Header Project. FERC Accession No. 20170918-5043. Discussed in the Order, ¶¶ 299-304,
307.

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impacts analysis to fully address the greenhouse gas emissions and climate impacts. In
that case, the Court concluded
We conclude that the EIS for the Southeast Market Pipelines Project
should have either given a quantitative estimate of the downstream
greenhouse emissions that will result from burning the natural gas that the
pipelines will transport or explained more specifically why it could not have
done so. As we have noted, greenhouse-gas emissions are an indirect
effect of authorizing this project, which FERC could reasonably foresee,
and which the agency has legal authority to mitigate. See 15 U.S.C. §
717f(e). The EIS accordingly needed to include a discussion of the
“significance” of this indirect effect, see 40 C.F.R. § 1502.16(b), as well as
“the incremental impact of the action when added to other past, present,
and reasonably foreseeable future actions,” see WildEarth Guardians, 738
F.3d at 309 (quoting 40 C.F.R. § 1508.7).

Quantification would permit the agency to compare the emissions from
this project to emissions from other projects, to total emissions from the
state or the region, or to regional or national emissions-control goals.
Without such comparisons, it is difficult to see how FERC could engage in
“informed decision making” with respect to the greenhouse-gas effects of
this project, or how “informed public comment” could be possible.

The Commission’s analysis does not provide the quantified comparisons to provide it
with enough information for “informed decision making.”
The environmental documents the Commission relies on are inadequate and do
not provide the climate impacts from methane leaking and venting throughout the
natural gas infrastructure, from well head to burn point, including the pipeline and the
compressor stations. In its Order, the Commission does not adequately evaluate the
potential impacts of, alternatives to, and mitigation measures for the proposed project
on greenhouse gas (“GHG”) emissions, public health, and the impacts of climate
change. In its environmental documents, the Commission utilizes an outdated global
warming potential (“GWP”) value for methane. Due to its short lifetime in the
atmosphere - 12.4 years - the GWP of methane should be calculated using the 20-year
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timeframe, which makes it 86 times as potent as carbon dioxide. Thus, relative to
carbon dioxide, methane has much greater climate impacts in the near term than in the
long term, and yet the Commission does not address it in any way in its Order.
The Commission has promulgated its own in-house guidance on the preparation
of environmental documents. The most recent is the 2017 guidance document and it
begins to add issues relating to climate change into the environmental analysis of a
project.17 In preparing environmental documents, FERC staff are required to assess
GHG emissions and:
GHG emissions should include the emission categories and/or
methodologies described in the most current version of the CEQ’s
guidance on GHG emissions and climate change, as applicable.

Guidance Document, p. 4-123. It is clear from the Order and the supporting application
and environmental documents, the Commission did not demand this analysis from
Dominion or its own staff, and did not follow the tenets of the 2017 guidance document.
As acknowledged by the Commission in its DEIS (and surprisingly dropped in the
Order), the White House Council on Environmental Quality (“CEQ”) issued its "Final
Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas
Emissions and the Effects of Climate Change in National Environmental Policy Act
Reviews," ("CEQ final guidance") on August 1, 2016, which outlines the analyses and
documentation of GHG emissions and climate change impacts that agencies should
include to facilitate compliance with existing NEPA requirements. In the DEIS, the
Commission states that "[a]s recommended in this new guidance, to the extent
17 February 2017 Draft Guidelines: https://www.ferc.gov/industries/gas/enviro/guidelines/guidance-
manual-volume-1.pdf ; August 2002 Guidelines:
https://www.ferc.gov/industries/gas/enviro/guidelines/guidance-manual-volume-1.pdf

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practicable, the FERC staff has presented the direct and indirect GHG emissions
associated with construction and operation of the projects and the potential impacts of
GHG emissions in relation to climate change." In the Order, the Commission abandons
this position and provides only a thin rationale for its conclusion.
The CEQ final guidance, which addresses compliance with existing NEPA
obligation, explicitly states that this purported reasoning - that a particular project has a
small contribution to emissions relative to global emissions - is not an appropriate
excuse to avoid fully assessing the GHG impacts of a project, as follows:
Climate change results from the incremental addition of GHG emissions from
millions of individual sources, which collectively have a large impact on a global
scale. CEQ recognizes that the totality of climate change impacts is not
attributable to any single action, but are exacerbated by a series of actions
including actions taken pursuant to decisions of the Federal Government.
Therefore, a statement that emissions from a proposed Federal action represent
only a small fraction of global emissions is essentially a statement about the
nature of the climate change challenge, and is not an appropriate basis for
deciding whether or to what extent to consider climate change impacts under
NEPA. Moreover, these comparisons are also not an appropriate method for
characterizing the potential impacts associated with a proposed action and its
alternatives and mitigations because this approach does not reveal anything
beyond the nature of the climate change challenge itself: the fact that diverse
individual sources of emissions each make a relatively small addition to global
atmospheric GHG concentrations that collectively have a large impact.18

The CEQ final guidance also lists various appropriate methodologies for
analyzing the greenhouse gas emissions of a project, stating that "[q]uantification tools
are widely available, and are already in broad use in the Federal and private sectors, by
state and local governments, and globally." In fact, CEQ provides a compilation of GHG
accounting tools, methodologies, and reports, none of which were apparently utilized by
the Commission in preparing its Order.
18 CEQ final guidance at 10-12.

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Additionally, even if "no standard methodology" is available, as the Commission
claims, the CEQ final guidance states that this is not a valid excuse for failing to assess
impacts and that, at a minimum, a qualitative analysis must be performed. It states as
follows:
“When an agency determines that quantifying GHG emissions would not be
warranted because tools, methodologies, or data inputs are not reasonably
available, the agency should provide a qualitative analysis and its rationale for
determining that the quantitative analysis is not warranted.”19
The CEQ final guidance also states that agencies should quantify a proposed agency
action's projected direct and indirect GHG emissions. The final guidance explains how
the scope of the proposed action should be considered:
“In order to assess effects, agencies should take account of the proposed action
– including “connected” actions – subject to reasonable limits based on feasibility
and practicality. (Actions are connected if they: (i) Automatically trigger other
actions which may require environmental impact statements; (ii) Cannot or will
not proceed unless other actions are taken previously or simultaneously, or; (iii)
Are interdependent parts of a larger action and depend on the larger action for
their justification). Activities that have a reasonably close causal relationship to
the Federal action, such as those that may occur as a predicate for a proposed
agency action or as a consequence of a proposed agency action, should be
accounted for in the NEPA analysis.”

In the Order, the Commission fails to follow the requirements of NEPA as
explained in the directives of the CEQ final guidance and its own 2017 guidance
document. The Commission states that "induced or additional natural gas production is
not a 'reasonably foreseeable' indirect effect resulting from the proposed ACP and the
EEP, and this topic need not be addressed in this EIS," and that "the environmental
effects resulting from natural gas production are not linked to or caused by a proposed
19 CEQ final guidance at 13.

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pipeline project.” In fact, the CEQ final guidance provides an example of the types of
impacts that should be considered specifically for resource extraction projects:
For example, NEPA reviews for proposed resource extraction and development
projects typically include the reasonably foreseeable effects of various phases in
the process, such as clearing land for the project, building access roads,
extraction, transport, refining, processing, using the resource, disassembly,
disposal, and reclamation.20

More broadly, the Commission must analyze the possibility that additional natural
gas infrastructure will lock-in fossil fuel use for decades to come and discourage or
prevent the construction of carbon-free energy sources, which has significant
implications for the climate. Because the construction and operation of new interstate
natural gas infrastructure approved by Commission ultimately contributes to, or
facilitates, increased GHG emissions into the atmosphere, the Commission must fully
evaluate these impacts, compare alternatives, and develop mitigation measures to
address such emissions. The Commission's duty to analyze the lifecycle GHG
emissions and the climate change implications of such emissions is required by NEPA,
and is supported by recent case law interpreting NEPA in the context of climate change,
CEQ's recently issued final guidance, and the Commission's own 2017 guidance
document.
The Order fails by not adopting a full suite of mitigation measures analyzed to
determine the ultimate impact of the project. The Commission must therefore revise its
Order and require Dominion to include specific actions that will be taken to reduce or
prevent GHG emissions, with the detailed plans for carrying out those actions, including
proposed timelines, and the ultimate impacts. As stated above, the new environmental
20 CEQ final guidance at 14.
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document is required to take a much broader range of direct, indirect, and cumulative
impacts resulting from the ACP project to fully comply with NEPA, and it must use this
information to develop alternatives and implement mitigation strategies for those
impacts.

V. The Commission in its Order fails to find that low-income, African-American,
and Native American families in North Carolina will bear a disproportionate
impact from the proposed pipeline. .

The Commission in its Order does not adequately address sociological and
demographic issues related to environmental justice.21 The Commission even begins its
discussion in ¶¶ 253 – 257 with an unsupported statement that it does not to comply
with the Executive Order 1289822 requiring it to do so.
253. Executive Order 12898 requires that specified federal agencies make
achieving environmental justice part of their missions by identifying and
addressing, as appropriate, disproportionately high and adverse human or
environmental health effects of their programs, policies, and activities on
minorities and low income populations. The Commission is not one of the
specified agencies and the provisions of Executive Order 12898 are not
binding on this Commission. Nonetheless, in accordance with our usual
practice, the final EIS addresses this issue.

The Order purports to include an environmental justice analysis supported
by the FEIS, pages 4-511 – 4-515, but offers no factual basis for its conclusion.
Most of its summary analysis centers on the impacts of air emissions and dust
near the compressor station. More important, the Commission fails to provide
21 The U.S. Environmental Protection Agency (“EPA”) defines “environmental justice” as “the fair
treatment and meaningful involvement of all people regardless of race, color, national origin, or income,
with respect to the development, implementation, and enforcement of environmental laws, regulations,
and policies.” www.epa.gov/environmentaljustice/learn-about-environmental-justice

22 Executive Order 12898, “Environmental Justice for Low Income & Minority Populations,” 1994.
www.archives.gov/files/federal-register/executive-orders/pdf/12898.pdf

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any factual support for its conclusion in ¶ 257, that the minority communities will
not be significantly impacted by the project:
257. In response to comments regarding specific environmental health
concerns of minority communities, including African-American populations,
the final EIS considered in greater detail the potential risks of impacts
falling on these communities, and what those effects would be. Due to
construction dust and compressor station emissions, African-American
populations near ACP and Supply Header projects could experience
disproportionate health impacts due to higher rates of asthma within the
overall African-American community. However, health impacts from
construction dust would be temporary, localized, and minor. Health
impacts from compressor station emissions would be moderate because,
while they would be permanent facilities, air emissions would not exceed
regulatory permittable levels. While the final EIS discusses the potential
for the risk of impacts to fall disproportionately on minority communities, it
further notes that, in relation to comments received regarding Compressor
Station 2's effects on African-Americans, the census tracts around the
station are not designated as minority environmental justice populations .
Therefore, by following the methodology outlined above, the final EIS
concludes, and we agree, that the projects will not result in
disproportionately high and adverse impacts on environmental justice
populations as a result of air quality impacts, including impacts associated
with the proposed Compressor Station 2. Further, no disproportionately
high and adverse impacts on environmental justice populations as a result
of other resources impacts will be expected as a result of the projects.

Contrarily, the Public Interest Groups in their Joint Comments, pages 65 – 71,
produced quantified, fact-based analysis showing the proposed pipeline would have a
disproportionate impact on low-income, African-American, and Native American families
in North Carolina. This is supported by the determination in the FEIS that acknowledges
that more than half of North Carolina counties are below the median income for the
state, and notes that “[t]wenty-seven of the 42 census tracts in North Carolina within a
1-mile radius of ACP facilities have a higher percentage of persons living below poverty-
level when compared to the state.” This fact, by itself, indicates that the route chosen
creates disproportionate impact of the pipeline on low income residents, and therefore
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contradicts the DEIS conclusion that “no environmental justice populations are
impacted.”
Similarly in its mention of environmental justice impacts at the compressor station
in Buckingham County, Virginia, the Commission failed to analyze the impacts on the
African-American population in close proximity to the station. Order¶ 255 concludes that
since the adverse impacts affect everyone along the route, it does not matter that some
of the affected communities around the compressor station are predominately African-
American:
255. The construction and operation of the proposed facilities would affect
a mix of racial/ethnic and socioeconomic areas in the ACP and Supply
Header project area. However, not all impacts identified in the final EIS
would affect minority or low-income populations. The primary adverse
impacts on the environmental justice communities associated with the
construction of projects would be the temporary increases in dust, noise,
and traffic from project construction. These impacts would occur along the
entire pipeline route and in areas with a variety of socioeconomic
background. We also received numerous comments expressing concern
about minority and low income communities near the proposed
Compressor Station 2 in Buckingham County, Virginia. Based on the
methodology used in the final EIS, of the three census tracts within one
mile of Compressor Station 2, one is a designated low-income community,
and none of the tracts were designated as minority environmental justice
populations.

The Commission, relying on the FEIS, page 4-513, just scanned the three census
blocks around the compressor station site, ignoring the immediate community of Union
Hill. Data shows 85 per cent of adjoining landowners are African-American but the use
of census blocks dilutes the impact on these families. On the other end, reliance on
adjacent census blocks does not adequately address the health and safety impacts on
all the families within the several-mile radius affected by the compressor station.
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The FEIS analysis of minority populations is remarkable in its contorted logic
used minimize the relative impact on people of color. It notes that “[i]n North Carolina,
minorities comprise 30.5 percent of the total population. The percentage of minorities in
the North Carolina census tracts within one mile of ACP ranges from 12.5 to 95.5
percent. In 13 of the 42 census tracts, the minority population is meaningfully greater
than that of the county in which it is located.” The Commission uses this result to
reinforce its conclusion that there are no disproportionate impacts on environmental
justice populations.
Remarkably, unlike using poverty data in census tracts within one mile of the
pipeline corridor to compare to the state as a whole, the Commission’s study only
compares minority population percentages in census tract near pipeline with the
percentage of minorities in the county in which this occurs. As most of the North
Carolina counties along the proposed ACP corridor have minority populations
significantly above the state average this greatly minimizes the apparent
disproportionality in minorities impacted. As noted in the Joint Comments of the Public
Interest Groups, Northampton County, for instance, is 58 percent African-American,
compared to a state average of 22 percent. A comparable analysis to disproportionate
impacts on low income residents would use a comparison to state minority populations,
and would result in a dramatically different conclusion.
Environmental justice analyses are mandatory in Federal environmental
documents, but there is no standard method for computing disproportionate impacts. As
such, the research community has long raised concerns about potential misapplication
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of methods or tailoring of methods to support a predetermined outcome.23 The
environmental justice section of the FEIS that the Commission uses as its rationale for
its conclusions is an example of such misapplication.
The Commission fails to conduct any serious credible analysis of environmental
justice without any basis or even minimal quantification. In its lack of understanding of
the simple term “disproportionate,” the Commission asserts that because impacts may
be happening in low population areas, fewer people would be hurt and therefore they
cannot see evidence of disproportionate impact. As noted above, the Commission in
Order ¶ 255 concludes “[t]hese impacts would occur along the entire pipeline route and
in areas with a variety of socioeconomic background.” Just because there is a low
population concentration does not mean that people of low income or people of color
would not be disproportionately impacted. In fact, in comparing the current ACP corridor
to earlier proposed ACP routes, it is clear that the pipeline has been moved to areas of
greater poverty and more people of color.
In addition to the fundamental flaws in the methodology used by the Commission,
the analysis fails to identify the major impacts on Native American populations living
along the preferred pipeline route. As noted in the Joint Comments, data shows that in
North Carolina alone, approximately 30,000 Native Americans live in census tracts
along the route. This number represents one quarter of the state’s Native American
23 Rose, L., et al., Environmental Justice Analysis: How Has It Been Implemented in Draft Environmental
Impact Statements?, Environmental Practice 7, 235-245 (2005); Hartell, A. Methodological challenges of
environmental justice assessments for transportation projects , Transportation Research Record: Journal
of the Transportation Research Board, 21-29 (2007); Holifield, R. Environmental Reviews and Case
Studies: Accounting for Diversity in Environmental Justice Screening Tools: Toward Multiple Indices of
Disproportionate Impact, Environmental Practice 16, 77-86 (2014); Liang, J. Defining Environmental
Justice Communities for Regulatory Enforcement: Implications from a Block‐Group‐Level Analysis of
New York State, Review of Policy Research 33, 666-685 (2016).

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population and one percent of the entire Native American population of the U.S. The
Commission’s environmental justice analysis is silent on this issue, but instead
concludes that the preferred route has no disproportionate impacts on minority
communities. It draws this conclusion by counting up the number of census tracts with
“meaningfully greater” minority populations than the county in which it they are located.
Failure of the environmental justice analysis to detect these impacts is based on at least
two flaws in the method.
The Commission apparently recognized the inadequacies in the environmental
documents by including a condition on the Certificate requiring consultation between
Dominion and four of the Indian tribes with significant populations along the route.
Condition 56. Atlantic and DETI shall not begin construction of the ACP
and Supply Header projects facilities or use of contractor yards, ATWS, or
new or to-be-improved access roads until:
a. Atlantic files with the Secretary documentation of communications with
the Lumbee Indian Nation, Coharie Tribal Council, Haliwa-Saponi Tribe,
and the Meherrin Tribe regarding traditional tribal sites, including natural
resources gathering locations in the project area;
b. Atlantic and DETI file with the Secretary:
i. all survey reports, evaluation reports, reports assessing project effects,
and site treatment plans, and cemetery avoidance treatment plans;
ii. comments on all reports and plans from the Pennsylvania, West
Virginia, Virginia, and North Carolina SHPOs, the MNF, GWNF, and NPS,
as well as any comments from federally recognized Indian tribes, and
other consulting parties, as applicable; and
iii. revised Unanticipated Discovery Plans that include tribal contact
information for those tribes that request notification following postreview
discovery of archaeological sites, including human remains, during
project activities;
c. the ACHP is afforded an opportunity to comment if historic properties
will be adversely affected; and
d. the FERC staff reviews and the Director of OEP approves the cultural
resources reports and plans, and notifies Atlantic and DETI in writing that
treatment plans/mitigation measures (including archaeological data
recovery) may be implemented and/or construction may proceed. All
material filed with the Commission that contains location, character, and
ownership information about cultural resources must have the cover and
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any relevant pages therein clearly labeled in bold lettering “CUI//PRIV –
DO NOT RELEASE.” (Section 4.10.7)

This consultation on tribal sites, and cultural and environmental resources known both
profoundly and intimately by the members of the Indian tribes should have occurred as
part of the review process, not as an afterthought. 18 C.F.R. § 2.1c(e) states
(e) The Commission, in keeping with its trust responsibility, will assure that
tribal concerns and interests are considered whenever the Commission's
actions or decisions have the potential to adversely affect Indian tribes or
Indian trust resources.

The consultation should have taken place between the tribal councils and the
Commission, or at least with FERC staff, rather than with the developers of the project.
As noted above, the insights by the tribal councils as well as comprehensive
“unanticipated discovery” plans should have been included in the application, and
become a consideration in the preparation of the DEIS.
The summary analysis in the environmental documents takes a single, interstate
project and breaks it down into a series of county-level projects for evaluating impacts
on minorities. In doing so, the analysis masks large disproportionate impacts on minority
populations, particularly Native American and African-Americans populations along the
route. Regardless if the Commission maintains the public benefits of the Project are
realized at the regional scale and not necessarily in the counties or census tracts
adjoining the pipeline route, the impacts are localized. For these reasons, the
Commission should demand a new environmental justice analysis based on
demographic data that considers the nature of this pipeline as a single, interstate project
and considers reference populations more carefully. This analysis should become part
of the supplement DEIS, and open for public review and comment.
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VI. The Commission in its Order and supporting environmental documents fails
to adequately consider all reasonable direct and indirect impacts and cumulative
impacts, including the upstream and downstream impacts associated with gas
development and compressor stations.

In addition to the environmental justice and climate impacts described above the
Order fails to adequately consider all reasonable direct and indirect impacts and
cumulative impacts, including those impacts associated with fracking gas development
and compressor stations. In analyzing the potential impacts of its approval of the ACP,
the Commission must consider the indirect effects of shale gas development. Indirect
effects are “caused by the action and are later in time or farther removed in distance,
but are still reasonably foreseeable. … Indirect effects are defined broadly, to ‘include
growth inducing effects and other effects related to induced changes in the pattern of
land use, population density or growth rate, and related effects on air and water and
other natural systems, including ecosystems.’”24
For several years, however, the Commission has categorically refused to
consider induced gas development as an indirect effect of pipeline projects such as the
ACP. The Commission first claims that gas drilling and pipeline projects are not
“sufficiently causally related” to warrant a detailed analysis.25 Then the Commission
claims that even if gas drilling and pipeline projects are sufficiently causally related, the
potential environmental impacts of the gas development are not “reasonably
24 Natural Res. Def. Council v. U.S. Army Corps of Eng’rs , 339 F. Supp. 2d 386, 404 (S.D.N.Y. 2005)
(quoting 40 C.F.R. § 1508.8(b)).

25 Nat’l Fuel Gas Supply Corp., 150 FERC ¶ 61,162, at P 44 (2015).

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foreseeable” as contemplated by CEQ’s NEPA regulations. The Commission’s
erroneous position is reiterated in the Order, ¶ 289:
289. With respect to the argument that the Commission must analyze the
environmental impacts associated with the upstream production of natural
gas that may be induced by the approval of ACP and Supply Header
projects, as we have previously concluded, the environmental effects
resulting from natural gas production are generally neither caused by a
proposed pipeline (or other natural gas infrastructure) project nor are they
reasonably foreseeable consequences of our approval of an infrastructure
project, as contemplated by CEQ regulations. A causal relationship
sufficient to warrant Commission analysis of the non-pipeline activity as an
indirect impact would only exist if the proposed pipeline would transport
new production from a specified production area and that production
would not occur in the absence of the proposed pipeline (i.e., there will be
no other way to move the gas). To date, the Commission has not been
presented with a proposed pipeline project that the record shows will
cause the predictable development of gas reserves. In fact, the opposite
causal relationship is more likely, i.e., once production begins in an area,
shippers or end users will support the development of a pipeline to move
the produced gas.

Given the comments in this docket, this position is irrational, arbitrary, and capricious. In
their Joint Comments, pages 108 - 114, the Joint Intervenors cite government and
industry sources showing how the development of a new pipeline leads to additional
fracking.
It is clear the activities permitted under the Certificate plausibly induce new natural
gas production since new pipelines will be made available to transport fracked gas, an
indirect impact related to the issuance of the Certificate. Therefore, it seems reasonable
for the Commission to conduct NEPA analyses of the upstream development that would
likely occur due to its certificate approvals. Courts have said that an agency must consider
something as an indirect effect if the agency action and the effect are “two links of a single
chain.”26 It cannot be disputed that gas development and infrastructure that transports
26 Sylvester v. U.S. Army Corps of Eng’rs, 884 F.2d 394, 400 (9th Cir. 1989).
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that gas are “two links of a single chain.” If new infrastructure is not built, prices drop, new
production slows, well shut-ins occur, and the attendant environmental and social impacts
of drilling are reduced or eliminated.
Shale gas development is not only causally related to construction of the ACP,
but is also reasonably foreseeable. An indirect effect is “reasonably foreseeable” if it is
“sufficiently likely to occur that a person of ordinary prudence would take it into account
in reaching a decision.”27 “[W]hen the nature of the effect is reasonably foreseeable but
its extent is not, [an] agency may not simply ignore the effect.”28 “Agencies need not
have perfect foresight when considering indirect effects, effects which by definition are
later in time or farther removed in distance than direct ones.”29 Here, additional shale
gas drilling is sufficiently likely to occur that a person of ordinary prudence would take it
into account when assessing the impact of the project on the environment. Moreover,
the Commission is well aware of the nature of the effects of shale gas development
and, therefore, may not ignore those effects.
In addition to considering the direct and indirect effects of the project, the
Commission must also consider cumulative impacts, especially in the Marcellus play in
Pennsylvania and West Virginia.30 A cumulative impact is:
“The impact on the environment which results from the incremental impact of the
action when added to other past, present, and reasonably foreseeable future
actions regardless of what agency (Federal or non-Federal) or person undertakes

27 Sierra Club v. Marsh, 976 F.2d 763, 767 (1st Cir. 1992).

28 Mid States Coal. for Progress v. Surface Transp. Bd., 345 F.3d 520, 549 (8th Cir. 2003) (emphasis in
original); see also Habitat Educ. Ctr. v. U.S. Forest Serv., 609 F.3d 897, 902 (7th Cir. 2010).

29 WildEarth Guardians v. U.S. Office of Surface Mining, 104 F. Supp. 3d 1208, 1230 (D. Colo. 2015).

30 40 C.F.R. § 1508.7.

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such other actions. Cumulative impacts can result from individually minor but
collectively significant actions taking place over a period of time.”

Cumulative impact analyses that contain “cursory statements” and “conclusory terms”
are insufficient.31 The Commission’s cumulative impact analysis for the ACP is
insufficient because it is needlessly and impermissibly restrictive both in terms of time
and geography and relies on cursory statements and conclusory terms that seek to
minimize impacts to an array of environmental resources. Conclusory statements are
not analysis of the impacts.
The Commission’s cumulative impacts analysis is fatally flawed because it
substantially limited the analysis area to the vicinity of the ACP pipeline and associated
facilities. The Commission should have broadened the scope to consider cumulative
impacts on water resources and wetlands. The Commission also should have selected
analysis areas for vegetation, land use, and wildlife that were rationally connected to
those particular resource areas. Demographic data of the ACP route and alternative
routes would have provided the necessary information to make conclusions on the
cumulative and disproportionate impacts on sensitive populations.
The cumulative impacts of the pipeline include impacts in the blast zone32, the
evacuation zone, and any local government zoning on public and private property. The
blast zone is also referred to as the “incineration zone” or “potential impact radius.”
Surprisingly the 660-foot blast zones used by Dominion in its application, and adopted
31 Delaware Riverkeeper Network v. F.E.R.C., 753 F.3d 1304, 1319-20 (D.C. Cir. 2014); see also Natural
Resources Defense Council v. Hodel, 865 F.2d 288, 298 (D.C. Cir. 1988) (although “FEIS contains
sections headed ‘Cumulative Impacts,’ in truth, nothing in the FEIS provides the requisite analysis,”
which, at best, contained only “conclusory remarks”).

32 See Stephens, M. J., A Model for Sizing High Consequence Areas Associated with Natural Gas
Pipelines, C-FER Technologies, (2000).
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by the Commission in the Order are significantly narrower than the 943 foot radius as
determined by established modelling procedures. This draws into serious question the
accuracy of the high consequence areas (“HCAs”) designations, and their scope and
impact.
Compressor stations are of particular concern because of their impacts. The
Order fails to address the cumulative impacts of compressor stations and related control
stations and further fails to acknowledge the presence of an existing compressor station
at Pleasant Hill in close proximity to the proposed Compressor Station 3 in Northampton
County. In addition, there are two major Title V facilities close by releasing significant
particulate and formaldehyde emissions, the Georgia-Pacific paper plant, less than two
miles west of the proposed Compressor Station 3, and the Enviva Wood Pellet Plant
approximately four miles to the southwest of the proposed compressor station.
One of the major sources of GHG emissions is from the compressor stations,
along with metering and regulating stations and valve control stations. Compressor
stations generally run 24 hours per day, 365 days a year, and are not very efficient, with
the majority of fuel burned producing only pollution and heat. Problems include:
 High amounts of pollution are emitted, including sulfur dioxide, carbon monoxide,
hazardous air pollutants, greenhouse gases, and particulates, including high
amounts of formaldehyde and other toxic air pollutants
 In cold weather, compressor stations can emit up to 13 times more pollution
 Excessive noise and stress for persons living nearby
 Lack of pollution control devices
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
 Serious environmental justice issues, since they are often located in lower
income areas and communities of color.
The toxic emissions from the compressor stations, and other points in the
infrastructure where natural gas is vented or leaking, directly cause health impacts on
the surrounding population. People who live near compressor stations experience skin
rashes, gastrointestinal, respiratory, neurological, and psychological problems. Air
samples show elevated levels of many toxics, including volatile organic compounds,
particulates and gaseous radon. Areas surrounding compressor stations are known in
the gas industry as "sacrifice zones" - for good reason.
CEQ’s guidance on cumulative impacts recommends significantly expanding the
cumulative impacts analysis area beyond the “immediate area of the proposed action”
that is often used for the “project-specific analysis” related to direct and indirect effects:
For a project-specific analysis, it is often sufficient to analyze effects within the
immediate area of the proposed action. When analyzing the contribution of this
proposed action to cumulative effects, however, the geographic boundaries of
the analysis almost always should be expanded. These expanded boundaries
can be thought of as differences in hierarchy or scale. Project-specific analyses
are usually conducted on the scale of counties, forest management units, or
installation boundaries, whereas cumulative effects analysis should be conducted
on the scale of human communities, landscapes, watersheds, or airsheds.33

(emphasis added). CEQ further says that it may be necessary to look at cumulative
effects at the “ecosystem” level for vegetative resources and resident wildlife, the “total
range of affected population units” for migratory wildlife, and an entire “state” or “region”
for land use.
33 CEQ, Considering Cumulative Effects under the National Environmental Policy Act, 1997, p. 12.
(emphasis added)

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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
EPA guidance on cumulative impacts states that “[s]patial and temporal
boundaries should not be overly restrictive in cumulative impact analysis.”34 EPA
specifically cautions agencies to not “limit the scope of their analyses to those areas
over which they have direct authority or to the boundary of the relevant management
area or project area.” Rather, agencies “should delineate appropriate geographic areas
including natural ecological boundaries” such as ecoregions or watersheds.
Because the Commission unreasonably restricted the extent of its cumulative
impacts analysis, failed to quantify many of the effects that it does acknowledge, an d
repeatedly relied on conclusory statements to dismiss significant impacts, the resulting
Order, depending on flawed environmental documents, does not meet the requirements
of NEPA. The Commission must remedy those defects in a revised DEIS and provide
that analysis for public comment.

VII. The Commission in its Order ignores planned and reasonably foreseeable
major expansions of the pipeline route and capacity, including the Piedmont
Pipeline, expansion into South Carolina, and other route and capacity
expansions.

A major deficiency in the DEIS is the failure to include environmental and
socioeconomic impacts from the approximately 26-mile spur line from Junction A in
Robeson County to the Smith Energy Complex near Hamlet in Rockingham County (the
“Piedmont Pipeline”).35 The Order, ¶ 8, mischaracterizes this pipeline as an existing
pipeline even though that pipeline has yet to be constructed. The pipeline extension
goes directly to two natural gas combined-cycle units, with a capacity of 1,084 MW, and
34 EPA, Consideration of Cumulative Impacts in EPA Review of NEPA Documents, 1999, p. 8.

35 Dominion Resource Report 1 (General Project Description), pp. 1-69 – 1-72.
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
five natural gas combustion turbine units. The burning of the natural gas by these plants
has been used by Dominion to justify the need for the ACP; it is one of the long-term
contracts discussed above. The Piedmont Pipeline is part and parcel to the Project. The
sole purpose of the Piedmont Pipeline is to carry the natural gas flowing on the ACP to
one of its major end users. The ACP does not end at Junction A but continues on to the
Smith Energy Complex, making it a link in the ACP corridor. The ACP terminates at the
Smith Energy Complex rather than the Junction A interconnect. The Commission has
failed to claim its authority over the Piedmont Pipeline as part of the Project.
In their October 9, 2017 motion36, the Public Interest Groups brought to the
attention of the Commission Dominion’s plans to expand the Project into South
Carolina.37 This new information, i.e., Dominion’s plans to extend the ACP into South
Carolina, demonstrates the application for the ACP was intentionally misleading in
terms of the scope of the project and the overall need for the project.
Order, ¶¶ 124, 125, and 127, in the Commission’s discussion of the need for the
Project acknowledges future expansion of the Project, and seemingly without any
further review. ¶127 summarizes contract rights given certain Project sponsors will lead
to future expansion capacity:
127. The Commission has found that giving project sponsors certain
priority rights to future expansion capacity is a permissible material
deviation from the pro forma service agreement because such provision
reflects the unique circumstances of the initial project. As the Commission
discussed in Transcontinental Gas Pipeline Co., LLC, "where a
subsequent expansion is envisioned that will be less costly due to the
anchor shipper's subscription, such capacity priority is reasonable when
an anchor shipper is committing to both projects and the provision was
36 FERC Accession No. 20171010-5108.

37 Rankin, S., “Disputed East Coast Pipeline Likely to Expand,” September 29, 2017, (widely report in
other news outlets). www.apnews.com/d9e1216747d642abb025dedb0043462f
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
offered to all potential shippers in the open season.” We find Atlantic's
provision to offer optional capacity to Foundation and Anchor Shippers, via
an expansion, to be a contractual incentive for obtaining each shipper's
binding commitments to the project. We find these rights are permissible
because Atlantic offered all Anchor and Foundation shippers the
expansion rights in its open season, and the expansion rights do not
present a risk of undue discrimination, do not affect the operational
conditions of providing service, and do not result in any customer
receiving a different quality of service.

The Order allows for “material deviations” of the Project, including route changes and
volume expansions.
The environmental documents should be supplemented to include the financial
costs, environmental and socioeconomic costs, and environmental justice impacts from
the Piedmont Pipeline, the South Carolina extension, and all other reasonably
foreseeable expansions of pipeline routes or capacity. Additional shipment of natural
gas in the pipeline will increase pressure within the pipeline, putting more pressure on
compressor stations (including a new station required for North or South Carolina), and
expanding the blast zones38 and evacuation zones. New corridors will have many of the
same environmental impacts as does the rest of the ACP, such as impacts on stream
crossings, water quality, wildlife habitat, and farms and families. The Piedmont Pipeline
will have a disproportionate impact on the Lumbees, Native American tribe primarily in
Robeson County.
The piecemealing of projects – eliminating a major component of a project -- is
discouraged by NEPA. “From a procedural standpoint, NEPA “provides the vehicle for
agency [and public] consideration of overall project-related impacts prior to the permit
decision. Ideally, EISs present comprehensive, rather than piecemeal, environmental
38 The inadequacies of the HCA designations are discussed above. See also footnote 32 above.

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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
impact and regulatory analysis.”39 All of these impacts should be analyzed and
presented for review and comment in supplement environmental documents.

REQUEST FOR STAY
The Public Interest Groups have raised substantial questions in this Request for
Rehearing related to whether the issuance of the Certificate was in the public interest.
As demonstrated in their Joint Comments and above, the Public Interest Groups an d
their members, and the public at large, will suffer irreparable harm if the Project is
allowed to go forward. Families and communities along the route will face immediate
harm through the destruction of the environment and forcible taking of their property
through eminent domain from a Project that may not be allowed to go forward once the
issues raised by this Request are properly and fully resolved.
The Permit on its face is conditional; many of the 73 conditions are requirements
to be fulfilled before the Project can go forward. As noted above, the Permit is further
conditional on the granting of state-issued permits and permissions. Dominion has not
completed, or in many instances even begun, its condemnation of property along the
route. Therefore, any delay in the proceeding with the construction of the Project should
be only minimal. In weighing the minimal delay caused to Dominion against the
irreparable harm that will occur to the Public Interest Groups and other members of the
public, the balance tips decisively in favor of issuing a stay until the Commission finally
decides the issues raised in the Request.
39 40 CFR 1502.9(c)(1)(ii); see also www.yalelawjournal.org/note/nepa-eiss-and-substantive-regulatory-
regimes

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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Therefore, the Commission should issue a stay prohibiting Dominion from
pursuing any action that might be authorized by the Certificate in this matter, including,
without limitation, any construction activity or activities related thereto and any
condemnation proceedings, until the Commission issues a final decision.

RELIEF REQUESTED
For the above reasons, the Public Interest Group respectfully request the
following relief:
a. Grant the Request for Rehearing;

b. Stay Dominion from taking any action authorized by the Certificate, including all
construction activities and condemnation proceedings pending the Commission’s
final action on this Request;

c. Within 30 days of the filing of this Request, rescind the Certificate;

d. Conduct a proper assessment of all environmental impacts pursuant to NEPA,
and supplement the environmental documents as put forth in this request; and

e. Grant any other relive to which the Public Interest Groups may be entitled.

This is the 13th day of November 2017.

FOR THE PUBLIC INTEREST GROUPS
/s/ John D. Runkle
______________________________
John D. Runkle
Attorney at Law
2121 Damascus Church Road
Chapel Hill, North Carolina 27516
919-942-0600
[e-mail]
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
NOVEMBER 2017
Fumes Across the Fence-Line
The Health Impacts of Air Pollution from Oil & Gas Facilities
on African American Communities
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
Fumes Across the Fence-Line:
The Health Impacts of Air Pollution
from Oil & Gas Facilities on African
American Commmunities
November 2017
© 2017 NAACP & CATF
All Rights Reserved.
www.catf.us
www.naacp.org
This report is available online at:
www.naacp.org/climate-justice-resources/
fumes-across-the-fence-line
http://catf.us/resources/publications/
files/FumesAcrossTheFenceLine.pdf
DESIGN
David Gerratt/NonProfitDesign.com
COVER PHOTO
© Creative Commons/The City Project
Acknowledgements
The authors would like to thank the following individuals
for their invaluable contributions and counsel: Jacqueline
Patterson (NAACP), Katerhine Egland (NAACP, Board of
Directors), Matt Kelso (FracTracker Alliance), Molly Dunton,
Alan Septoff (Earthworks), Doris Browne MD, Mark
Mitchell MD MPH (National Medical Association)
Conrad Schneider, Sarah Uhl, Stuart Ross, Jonathan
Banks, David McCabe, and John Graham (CATF).
Authors
Lesley Fleischman (CATF)
Marcus Franklin (NAACP)
D ISCLAIMER
Permission: This document may be quoted, copied and
distributed freely. We request that any quotes that are taken
from this work be properly credited and appropriately honored.
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
F UMES A CROSS THE F ENCE-L INE 1
Contents
3 Executive Summary
6 Environmental Pollution and the Health Impact in African American Communities
14 Health Impacts from Natural Gas Facilities
21 Health Impacts from Oil Refineries
28 Call to Action
31 Endnotes
Figures
8 Figure 1: Poverty Status
9 Figure 2: African American Percent of Population in 200 Counties with Highest
Oil and Gas Production (2015)
10 Figure 3: Threat Radius—The Area within a Half Mile of Active Oil and Gas Wells, Compressors,
and Processing Plants
15 Figure 4: Number of Asthma Attacks Experienced by African American Children Caused
by Ozone Attributable to Oil and Gas by Metropolitan Area
17 Figure 5: African American Percent of Population in Counties above EPA’s Level of Concern
for Cancer Risk from Oil and Gas Emissions
22 Figure 6: African American Percent of Population in Counties with Oil Refineries
Tables
11 Table 1: Top 10 States by African American Population Living within a Half-Mile Radius (2010 Census)
15 Table 2: Top 10 Metropolitan Areas by African American Health Impacts Attributable to Ozone caused
by Oil and Gas Pollution
18 Table 3: Top 10 States by African American Population Living in Counties Above EPA’s Level of Concern
for Cancer Risk (2015 Population Data)
22 Table 4: Top 10 States by African American Population Living Counties with Oil Refineries
Boxes
12 Air Pollutants & Associated Health Concerns from Oil and Gas
13 Air Pollution Sources in the Oil and Gas Industry
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
2 FUMES A CROSS THE F ENCE-L INE
Case Studies
7 Siting of natural gas infrastructure in environmental justice communities:
The Atlantic Coast Pipeline (ACP), North Carolina, Virginia, and West Virginia
16 Downwind air pollution in the Mid-Atlantic: Baltimore, MD
19 A history of urban drilling: Inglewood Oilfield, Inglewood, CA
20 Uneven responses to community oil and gas air pollution: Los Angeles, CA
23 East Bay Refinery Corridor: East Bay, CA
23 Burdens of a fence-line community: Valero Oil and Gas Refinery, West Port Arthur, TX
25 Toxic Emission in South Philadelphia: Pennsylvania, PA
26 Accidents at oil and gas facilities: ExxonMobil Refinery, Baton Rouge, LA
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
F UMES A CROSS THE F ENCE-L INE 3
Executive Summary
The oil and gas industry dumps 9 million
tons of methane and toxic pollutants like
benzene into our air each year. Methane
is a greenhouse gas 87 times more
potent than carbon dioxide at driving climate
change and the oil and gas industry is now the
largest source of methane pollution in the U.S.
But methane is just one harmful air pollutant from
the oil and gas industry. This paper sheds light on
the health impacts of air pollutants from oil and
gas facilities that specifically threaten the health
of African American communities living near oil
and gas facilities and in areas far from oil and
gas production.
The life-threatening burdens placed on com-
munities of color near oil and gas facilities are
the result of systemic oppression perpetuated
by the traditional energy industry, which exposes
communities to health, economic, and social
hazards. Communities impacted by oil and gas
facility operations remain affected due to energy
companies’ heavy polluting, low wages for danger-
ous work, and government lobbying against local
interests. The nature of the vulnerability of African
American and other person of color fence-line
communities is intersectional--subject to con-
nected systems of discrimination based on social
categorizations such as race, gender, class, etc.
Health impacts from the natural gas supply
chain (natural gas facilities as well as oil produc-
tion facilities with associated gas) were quantified
in two reports published by Clean Air Task Force
(CATF). As demonstrated in the CATF’s Fossil
Fumes report, many of these toxic pollutants are
linked to increased risk of cancer and respiratory
disorders in dozens of counties that exceed U.S.
EPA’s level of concern. These pollutants from the
natural gas supply chain also contribute to the
ozone smog pollution that blankets the U.S. in
the warmer months. The 2016 Gasping for Breath
report, published by CATF, found that ozone smog
from natural gas industry pollution is associated
with 750,000 summertime asthma attacks in
children and 500,000 missed school days. Among
adults, this pollution results in 2,000 asthma
related emergency room visits and 600 hospital
admissions and 1.5 million reduced activity
days. (Chapter 2)
  This paper also shows the health impacts
from petroleum refinery pollution. While we do
The life-threatening burdens placed
on communities of color near oil
and gas facilities are the result of
systemic oppression perpetuated by
the traditional energy industry, which
exposes communities to health,
economic, and social hazards.
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
4 FUMES A CROSS THE F ENCE-L INE
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within a half mile of existing natural gas facilities
and the number is growing every year.
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nities face an elevated risk of cancer due to
air toxics emissions from natural gas develop-
ment: Over 1 million African Americans live
in counties that face a cancer risk above EPA’s
level of concern from toxics emitted by natural
gas facilities.
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violates air quality standards for ozone smog.
Rates of asthma are relatively high in African
American communities. And, as a result of
ozone increases due to natural gas emissions
during the summer ozone season, African
American children are burdened by 138,000
asthma attacks and 101,000 lost school
days each year.
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in the 91 counties with oil refineries.

The impacts described in this paper are just one
layer of the many public health issues that these
communities face. For example, this analysis
only accounts for the risks associated with air
pollution from oil and gas facilities—water and
soil contamination may also harm communities
living near oil and gas facilities. We also only
included health impacts directly linked to oil
and gas facilities—oil and gas development may
also bring increased truck traffic, oil trains, and
changes in land use, which can have significant
public health impacts. In addition, many African
American communities are located near other
major sources of pollution, like power plants,
chemical plants, hazardous waste facilities, and
others. These communities already face high
levels of pollution from various sources, and
the added health threats from oil and gas
development exacerbate their problems.
Air pollution is emitted from dozens of types
of equipment and processes throughout the oil
and gas sector, such as wells, completion equip-
ment, storage tanks, compressors, and valves.
Many proven, low-cost technologies and practices
are available to reduce these emissions, while
also reducing emissions of methane, the main
constituent of natural gas. Thus, policies that
Air pollution is emitted from dozens
of types of equipment and processes
throughout the oil and gas sector.
Many proven, low-cost technologies
and practices are available to reduce
these emissions, while also reducing
emissions of methane, the main
constituent of natural gas.
not quantify health impacts from oil refineries, as
we did for impacts from natural gas facilities, we
include case studies and stories from community
members that have been impacted by pollution
from these facilities. In this chapter, we focus
solely on petroleum refineries, not the entire
petroleum supply chain. (Chapter 3)  
Many African American communities face
serious health risks caused by air pollution.
Higher poverty levels increase these health
threats from air pollution translating into a bigger
health burden on African American communities.
And, companies often site high polluting facilities
in or near communities of color, furthering the
unequal distribution of health impacts. This paper
for the first time quantifies the elevated health
risk that millions of African Americans face due
to pollution from oil and gas facilities. Specifically,
the paper finds that:
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F UMES A CROSS THE F ENCE-L INE 5
reduce pollution from the oil and gas industry
can help protect the health of local communities
while addressing global climate change. In the
Waste Not report, Clean Air Task Force (CATF), the
Natural Resources Defense Council (NRDC), and
the Sierra Club called for EPA regulations to cut
methane emissions from the oil and gas industry
by half. These methane standards would also
significantly cut toxic and ozone-causing air pollu-
tion, which could have important benefits for air
quality and public health in and downwind of oil
and gas producing areas. In addition, stringent
standards specifically for toxic and ozone causing
pollutants emitted throughout the oil and gas
supply chain are needed to ensure compliance
with the Clean Air Act and protect public health.
  Defending the safeguards finalized during the
Obama administration and pushing for additional
protections against pollution from the oil and
gas industry will help improve the health of many
African American communities while addressing
global climate change. In June 2016, the EPA
finalized strong methane standards covering
new and modified oil and gas facilities. Although
cutting methane from new oil and gas facilities
is a step in the right direction, more important
is cutting pollution from the nearly 1.3 million
existing oil and gas facilities. These standards
will reduce the risk from the air toxics and ozone
smog-forming pollutants from this industry, but
without a comprehensive standard, the vast major-
ity, at least 75 percent, of all of the wells and oil
and gas infrastructure in use today, will remain
virtually unregulated and can continue to pollute
without limit. Existing facilities spewed over 8 mil-
lion metric tons of methane in 2015—equivalent
in near-term warming potential to the greenhouse
gas emissions from 200+ coal-fired power plants.
To reduce the risk from air toxics and smog-
forming pollution from this industry, EPA must
require pollution reductions from all oil and gas
facilities, and not roll back the protections that
are already in place.
  Environmental and energy justice issues are
multilayered. Thus, the approach to tackling these
issues must also be multilayered. People of color
and low-income communities are disproportion-
ately affected by exposure to air pollution, and
standards that protect communities from this
pollution are critical. In addition, these communi-
ties have a lot to gain from the transition from
the current fossil fuel energy economy to one
based on equitable, affordable, and clean energy
sources. African American and other fence-line
communities, such as people who are low-income,
can organize to fight the intentional polluting of
their neighborhoods. The first step is to address
the many ways fossil fuels taint our communities,
including the air pollution from oil and gas
development.
Equipment at a gas well.© CATFDefending the safeguards finalized
during the Obama administration
and pushing for additional
protections against pollution from
the oil and gas industry will help
improve the health of many African
American communities while
addressing global climate change.
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6 FUMES A CROSS THE F ENCE-L INE
CHAPTER 1
Environmental Pollution and
the Health Impact in African
American Communities
It is not a coincidence
that so many African
Americans live near
oil gas development.
Historically, polluting
facilities have often
been sited in or near
African American
communities.
T he racial disparities among communities
impacted by environmental pollution in the
United States are stark. African Americans
are exposed to 38 percent more polluted
air than Caucasian Americans, and they are 75
percent more likely to live in fence-line communi-
ties than the average American.1 Fence-line com-
munities are communities
that are next to a company,
industrial, or service facility
and are directly affected in
some way by the facility’s
operation (e.g. noise, odor,
traffic, and chemical emis-
sions). Most fence-line
communities in the United
States are low-income indi-
viduals and communities
of color who experience
systemic oppression such
as environmental racism.
Many African Americans are exposed
to high levels of pollution.
The air in many African American communities
violates air quality standards intended to protect
human health.
  Over 1 million, or two percent of African Ameri-
cans, live in areas where toxic air pollution from
natural gas facilities is so high that the cancer
risk due to this industry alone exceeds EPA’s level
of concern.2 And, over 1 million African American
individuals live within a half mile of an oil and gas
facility—those within this half mile radius have
cause for concern about potential health impacts
from oil and gas toxic air pollution.3 These figures
only account for air pollution from wells and
natural gas compressors and processors—the
numbers would be much higher if pollution from
oil refineries was factored.
It is not a coincidence that so many African
Americans live near oil gas development. Histori-
cally, polluting facilities have often been sited in
or near African American communities. Companies
take advantage of communities that have low
levels of political power.4 In these communities,
companies may face lower transaction costs
associated with getting needed permits, and they
have more of an ability to influence local govern-
ment in their favor.5
African Americans and other environmental
justice communities face heavy burdens because
of the millions of pounds of hazardous emissions
released by the oil and gas industry each year.
Many African American communities face serious
health risks as a result of toxic pollution from in-
dustrial facilities that are often located blocks
from their homes. These life-threatening burdens
are the result of systemic oppression perpetuated
by the traditional energy industry, which exposes
communities to health, economic, and social
hazards. Communities impacted by oil and gas
facility operations remain affected due to energy
companies’ heavy polluting, low wages for danger-
ous work, and government lobbying against local
interests.6 African American and other person of
color living in fence-line communities experience
connected systems of discrimination based on
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F UMES A CROSS THE F ENCE-L INE 7
CA SE STUDY
Siting of natural gas infrastructure in environmental
justice communities
The Atlantic Coast Pipeline (ACP), North Carolina,
Virginia, and West Virginia
Set for completion in 2019, Duke Energy and Dominion Resources have begun steps to build
a 600-mile transmission pipeline from West Virginia through eastern North Carolina. The
Atlantic Coast Pipeline (ACP), being built to bring natural gas from hydraulic fracturing sites in
West Virginia and Pennsylvania to power plants in North Carolina.10 This expansion of coastal
infrastructure along the densely populated East Coast, will increase the likelihood of facilities
being sited in heavily populated areas. Typically, areas with a high concentration of low-income
and people of color, as well as other fence-line communities.
The North Carolinian coastline from the Outer Banks north to the Virginia line, is heavily
populated by low-income, African American residents. The proposed route of the ACP directly
impacts a number of African-American, and other vulnerable communities, in the state. In seven
of the eight counties along the proposed route the African American population ranges from
24.3 to 58.4 percent, compared to the 21.3 percent at the state level. These counties also
reflect income vulnerability, as seven of the eight counties have median household incomes
below the statewide median of $46,693. Seven of the eight counties along the proposed route
have poverty levels higher than the state average (17.2 percent), ranging from 17.6 to 33.1
percent.11 The expansion of the ACP and other natural gas infrastructure along the North
Carolinian coast would have unavoidable adverse impacts on already vulnerable communities.
The pipeline is not the only piece of infrastructure to be established as a part of the project.
As part of the plan for the Atlantic Coast Pipeline, Dominion intends to build a compressor
station in Northampton County, North Carolina, a county that share’s a border with Virginia.
Northampton’s African American population is 54.6 percent, and the median household income
in $31,453, nearly $15,000 below the state average. Almost 32 percent of Northampton
residents live in poverty, compared to 17.2 percent statewide.12
The overall cancer rate in Northampton County exceeds that for the state of North Carolina
at 516.6 per 100,000 (the state average is 488.9 per 100,000 people). Lung and bronchial
cancers, two forms of cancer caused by common air pollutant, are specifically elevated: 80.5 per
100,000 people compared to 70.1 per 100,000.13 Given the current state of vulnerable popu-
lations in the area of impact of the proposed pipeline, particularly in in North Hampton, a
compressor station, pipeline, and other natural gas infrastructure, could exacerbate health
problems from increased air pollution.
For more on the communities affected by the ACP project visit the Southern Environmental
Law Center, Path of the Pipeline.14
social categorizations such as race, gender, class,
disability, etc. These communities are impacted by
the negative health impacts of oil and gas facility
operations because of discrimination.
The impacts described in this paper are just
one layer of the many public health issues that
African American and other communities of color
face as a result of oil and gas operations. For ex-
ample, this analysis only accounts for the risks
associated with air pollution from oil and gas facil-
ities—the exposure risks from water and soil con-
tamination may also harm communities living near
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8 FUMES A CROSS THE F ENCE-L INE
oil and gas facilities.7 We also only included
health impacts directly associated with oil and
gas facilities—oil and gas development may
also entail increased truck traffic, oil trains, and
changes in land use, which can have significant
public health impacts.8 In addition, many African
American communities are located near other
major sources of pollution, like power plants,
chemical plants, hazardous waste facilities, and
others.9 These communities already face high
levels of pollution from various sources, and the
added health threats from oil and gas develop-
ment exacerbate their problems.
This paper sheds light on the health impacts
many African American communities face from oil
and natural gas production, processing, and trans-
mission facilities. It also underscores both the
need to implement commonsense standards that
reduce pollution from these facilities, and the
need to transform the current energy economy
“Common sense would suggest that a pipeline carrying a highly
flammable substance and a massive polluting industrial facility
should not be placed in any residential community, much less
an environmental justice community.”
– Congressman Sanford D. Bishop, Jr. John Lewis, Hank Johnson Jr., and David Scott in a 2015 response to the Saber Trail
Pipeline Project in Alabama, Southern Georgia, and Central Florida.19
into one that is based on clean energy sources
and the principles of energy democracy (local
energy choice) and energy sovereignty (local con-
trol of energy systems). This new energy economy
will need to address the overlapping systems
of oppression that allow whole communities
to be poisoned.

Asthma threatens the health of children
in African American communities.
Approximately 13.4 percent of African American
children have asthma (over 1.3 million children),
compared to 7.3 percent for white children.15 The
death rate for African American children with asth-
ma is one per 1 million, while for white children it
is one per 10 million.16
Many African Americans are particularly burdened
with the health impacts from air pollution, due
to high levels of poverty and relatively lower
rates of health insurance.
Individuals living below the poverty level are
particularly burdened by the effects of air pollu-
tion. In 2015, 24 percent of the African American
population (including 32 percent of African Ameri-
can children) were living in poverty, compared
to 14 percent for the overall US population (and
20 percent of US children).17 High poverty rates
restrict housing options for African American
families. African Americans are also somewhat
less likely to have health insurance than the popu-
lation as a whole. In 2015, 11.5 percent was the
uninsured rate for African Americans under the
age of 65, versus 10.8 percent for the population
as a whole and 7.5 percent for the white popula-
tion.18 The combination of higher poverty rates
and lower prevalence of health insurance exacer-
bates the impact air pollution has on low-income
African American families.
F IGURE 1
Poverty Rate
Source: U.S. Census Bureau, National Center for Health Statistics
25%
20%
15%
10%
5%
0%Poverty RateAfrican
American
Population
Total
Population
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F UMES A CROSS THE F ENCE-L INE 9
A large number of African Americans live in
states with large numbers of polluting oil and
gas facilities.
Many of the states with the highest amount of
oil and gas development also have large African
American populations. In three of the top ten oil
and gas production states of 2015—Louisiana,
F IGURE 2
African American Percent of Population in 200 Counties with
Highest Oil and Gas Production (2015)
Source: U.S. Census Bureau, DI Desktop
African American Percent
of Population
n <1%
n 2%–5%
n 6%–10%
n 11%–15%
n 16%–25%
n > 25%
C OMMUNITY S TORY
“My parents grew up on the Permian Basin where we have some of the largest frack fields
and very old oil wells, as well. Thinking about the impacts of these chemicals and toxins
that persist in the area, I realized that I never been out of this stuff. Even in the womb of
my mother and her own sort of chemistry and biology that she grew up with having spent
her whole life there…. The city of Houston did a study and identified 12 carcinogens and
that research is available and some of the highest concentrations are in areas that I grew
up in and spent majority of my childhood in. Some of the things that I experienced were
frequent headaches, irritability, and nose bleeds, gastrointestinal problems, a lot of things
that I said I can show and we have seen are the same symptoms are as a result from
being exposed to some of these carcinogens.”
— Bryan Parras, Houston, TX
Texas, and Pennsylvania—African Americans made
up more than 10 percent of the population. And,
in two of the other top oil and gas states--North
Dakota and Wyoming--the African American popu-
lation has grown significantly since 2000, a time
when oil and gas production in these states has
also grown.20

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10 FUMES A CROSS THE F ENCE-L INE
C OMMUNITY S TORY
“Fortunately, no one was seriously injured as a result of the explosion, but nearby residents
were concerned about what they might be exposed to as a result of the explosion [BP Amoco
and Enterprise Products, LLC gas processing plant in Jackson County, MS]…Unlike oil and
chemical plants, gas processing plants are not required to report the list and quantity of
hazard pollutants they release to the Environmental Protection Agency’s Toxic Release
Inventory (TRI) Program.”
— Steps Coalition, Biloxi, MS
Earthworks released the “Oil and Gas Threat
Map,” an interactive map of the nearly 1.3 million
active oil and gas wells, compressors and proces-
sors in the U.S.21 The map shows how many African
Americans live within a half mile of oil and gas
facilities, and it indicates that those within this
radius have cause for concern about potential
health impacts from oil and gas pollution. It is
not a declaration that those near oil and gas
facilities will definitely have negative health
impacts, and it also does not mean that people
living further than a half mile are safe from health
impacts. As we document later in this paper, there
is ample evidence that the pollution from oil and
gas operations impacts individuals and commu-
nities both close to and far from these facilities.
F IGURE 3
Threat Radius—The Area within a Half Mile of Active Oil and Gas Wells, Compressors,
and Processing Plants
The oil and gas well data was downloaded directly from state government agencies, and it includes all active conven-
tional and unconventional wells in 2016 and 2017. Gas compressor and processing plant data were primarily taken from
a variety of state and federal databases. State and federal agencies do not monitor compressors and processing plants
as closely as they do wells, so this data is not comprehensive in all states.
Source: http://oilandgasthreatmap.com/threat-map
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F UMES A CROSS THE F ENCE-L INE 11
More than 1 million African Americans nationally
(2.4 percent of the total African American popu-
lation) live within a a half mile radius of oil and
gas facilities (see Table 1).
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approximately one in five African Americans
in the states live within the half mile radius
of oil and gas facilities.

State
African American
Population within a
Half Mile Radius
Percent of African American
Population in State within
a Half Mile Radius
Texas 337,011 10%
Ohio 291,733 19%
California 103,713 4%
Louisiana 79,810 5%
Pennsylvania 79,352 5%
Oklahoma 73,303 22%
West Virginia 13,453 17%
Arkansas 10,477 2%
Mississippi 10,448 1%
Illinois 10,227 1%
TOTAL 1,052,680 2%
TABL E 1
Top 10 States by African American Population Living within
a Half Mile Radius of Oil and Gas Facilities (2010 Census)
Source: http://oilandgasthreatmap.com
Equipment at a gas well.© CATF
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12 FUMES A CROSS THE F ENCE-L INE
BOX 1
Air Pollutants & Associated Health Concerns
from Oil and Gas
Methane, the primary component of natural gas, is over 80 times more potent than carbon
pollution’s projected disruption to our climate over the coming decades. Methane also
contributes to ozone smog formation.

Toxic and Hazardous Air Pollutants include a wide range of chemicals that are known or
probable carcinogens and/or cause other serious health impacts. Among other chemicals of con-
cern, oil and natural gas facilities are responsible for the following air pollutants, either emitted
as a component of raw natural gas or a by-product of natural gas combustion that occurs at
these sites. Exposure studies based on air measurements have identified levels of benzene,
hydrogen sulfide, and formaldehyde near oil and gas sites that exceed health-based thresholds.
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has been linked to cancer, anemia, brain damage, and birth defects, and it is
asso-ciated with respiratory tract irritation.22 Over time, benzene exposure can also lead to
reproductive, developmental, blood, and neurological disorders. A 2012 study estimated a
10 in a million cancer risk--well over EPA’s level of concern--for residents near a well pad,
attributable primarily to benzene levels measured in the air near the well site.23 The EPA’s
National Emissions Inventory (NEI) estimates that over 20,000 tons of benzene was emitted
by oil and gas sources in 2011.24 Benzene is a constituent of raw natural gas, so leaks
and vents are the primary source of benzene pollution from the oil and gas industry.
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has been associated with respiratory and eye irritation, as well as blood and
neurological disorders.25 The NEI estimates that over 2,000 tons of ethylbenzene was emitted
by oil and gas sources in 2011.26 Like benzene, ethylbenzene is a constituent of raw natural
gas and leaks and vents of gas are the primary sources of ethylbenzene.
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gas is primarily found near wells producing “sour gas.” At high concentra-
tions, it can cause severe respiratory irritation and death. At lower levels, it can lead to eye,
nose, and throat irritation; asthma attacks; headaches, dizziness, nausea, and difficulty
breathing.27
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has been linked to certain types of cancer, and chronic exposure is known to
cause respiratory symptoms.28 The NEI estimates that nearly 22,000 tons of formaldehyde
was emitted by oil and gas sources in 2011.29 Formaldehyde is primarily emitted from
combustion sources such as flares and compressor engines.
Volatile Organic Compounds (VOCs) are precursors to ground level ozone smog. Ozone
smog can impair lung function, trigger asthma attacks, and aggravate conditions of people
with bronchitis and emphysema.30 Children, the elderly, and people with existing respiratory
conditions are the most at risk from ozone pollution.
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F UMES A CROSS THE F ENCE-L INE 13
BOX 2
Air Pollution Sources in the Oil and Gas Industry
The oil and gas industry includes a large number of industrial sites across the country. These
include hundreds of thousands of wellpads where oil and gas are produced, thousands of
compressor stations which move natural gas from wells to markets, and hundreds of processing
plants which prepare gas for high-pressure pipelines that take it to markets.
Raw natural gas (i.e., gas as it is produced from underground formations, before significant
processing is done) usually contains significant amounts of ozone-forming volatile organic com-
pounds (VOCs) and often contains significant amounts of toxic hazardous air pollutants (HAPs),
though gas varies in composition from source to source. The HAPs in raw gas include hexane,
benzene, and other aromatic chemicals; poisonous gases like hydrogen sulfide can also be
present. As such, natural gas wellpads and the natural gas gathering pipeline and compression
systems that move gas from wells emit substantial amounts of VOCs and HAPs, as do the
processing plants that separate natural gas liquids (VOC species that are valuable components
of raw natural gas) from the natural gas that is sent through pipelines to customers. Some
of those pollutants remain in the gas even after processing. Emissions from facilities further
downstream in the natural gas supply chain, like transmission compressor stations and local
distribution equipment, still include some of these pollutants.
Crude oil production operations also emit substantial amounts of VOCs and HAPs. Methane,
as the main constituent of natural gas, is emitted from all types of oil and natural gas facilities,
from wellpads to the natural gas distribution systems in urban areas.
r
Oil and Gas Production: The oil and gas production segment includes many diverse activities,
such as production of hydrocarbons from underground geologic formations; separation of
natural gas, oil, and, water; and collection of gas from multiple wells through natural gas
gathering pipeline and compressor systems. These activities in turn involve processes such
as well drilling, hydraulic fracturing or other well stimulation, and well workovers; and they
require equipment such as tanks, piping, valves, meters, separators, dehydrators, pipelines,
and gathering compressors.
 r
Natural Gas Processing: Gas processing plants separate raw natural gas into natural gas
liquids and processed natural gas that meets specifications for transport in high-pressure
pipelines and consumption in furnaces and power plants. Natural gas liquids are hydrocarbons
such as propane, butane, etc., which are valuable products of gas processing. The processing
removes most of the toxic components from the gas, but some toxins remain.
r
Natural Gas Transmission and Storage: Natural gas transmission pipelines carry gas from
production regions to markets. This segment also includes facilities where gas is stored,
either underground or in tanks. Compressor stations along pipelines maintain pressure
and provide the energy to move the gas.
 r
Natural Gas Distribution: Finally, natural gas is delivered to customers (residential,
commercial, and light industrial) via low-pressure underground distribution pipelines.
r
Oil Refineries: Refineries are large industrial plants that process crude oil into various
petroleum products, such as gasoline, diesel fuel, jet fuel, and others. Emissions of toxic
and hazardous pollution from these facilities are very high, while methane emissions
are relatively small.
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14 FUMES A CROSS THE F ENCE-L INE
CHAPTER 2
Health Impacts
from Natural Gas Facilities
“Just because the oil
company brings jobs
and other benefits,
doesn’t mean it can
do it at the expense
of my health and
well-being.”
— Charles Zacharie, Baldwin Village
resident, Los Angeles, CA32
Natural gas facilities emit toxic air
pollution and pollution that forms ozone
smog. In two previous reports, “Fossil
Fumes” and “Gasping for Breath,” CATF
presented the public health impact of toxic air
pollution and ozone smog,
respectively, from the natu-
ral gas industry. Here, we
break out and discuss the
public health impacts of
these pollutants specifically
for African American com-
munities.
The health impacts
described in this chapter
are the result of air pollu-
tion that is directly due to
natural gas facilities and
equipment (for impacts of
petroleum refineries, see Chapter 3).31 As noted
above, we are not fully accounting for the public
health impact of natural gas development: water
pollution and soil con-tamination can also have a
significant public health impact, as can ancillary
activities such as increased truck traffic. As
such, the impacts presented in this chapter
should be understood as minimum amount of im-
pact; the true public health impact of natural gas
development is certainly much higher.
In this chapter, we discuss the following public
health impacts of natural gas facilities:
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emissions.
The air in many African American communities
violates air quality standards for ozone.
High ozone levels are caused by emissions from a
variety of industries, but it is possible to separate
out the increase in ozone that can be directly
attributed to emissions from natural gas facilities
and its associated health impact.33 CATF’s
“Gasping for Breath” describes an ozone model-
ing analysis that compares ozone levels in a 2025
“Baseline” case and a 2025 “Zero Natural Gas
Emissions” case. The difference in ozone levels
between these two cases is the ozone that can
be directly attributable to natural gas.34
  The increased level of ozone can be associated
with an increase in a variety of health impacts.
The EPA uses peer-reviewed literature to estimate
how these changes in ozone will affect public
health.35 Using the same studies and methodology
as the EPA used in its recent Ozone National
Ambient Air Quality Standards (NAAQS) rulemaking
process, CATF’s ozone modeling estimates the
impact on public health that can be directly attrib-
utable to ozone caused by emissions from the
natural gas sector. Nationally, CATF estimates that
over 750,000 asthma attacks for children and
over 500,000 lost school days during the summer
ozone season are due to ozone increases resulting
from natural gas emissions.36 After adjusting
these total incidence rates based on the county
level African American population, the African
American population is burdened by approximately
138,000 asthma attacks and 101,000 lost
school days attributable to natural gas air pollu-
tion each year. The burden of these health impacts
falls more heavily on populations that already
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F UMES A CROSS THE F ENCE-L INE 15
F IGURE 4
Number of Asthma Attacks Experienced by African American Children Caused by Ozone
Attributable to Oil and Gas by Metropolitan Area
Source: “Gasping for Breath,” US Census Bureau
Number of Asthma
Attacks per Ozone Season
25–250
251–500
501–1,000
1,001–2,000
2,001–3,000
> 3,000
Metropolitan Area
Asthma Attacks
(per year)
Lost School Days
(per year)
Dallas-Fort Worth (TX, OK) 8,059 5,896
Atlanta (GA) 7,499 5,469
Washington-Baltimore (DC, MD, VA, WV, PA) 7,216 5,269
New York-Newark (NY, NJ, CT, PA) 5,235 3,821
Houston (TX) 4,256 3,111
Chicago (IL, IN, WI) 3,777 2,760
Memphis (TN, MS, AR) 3,674 2,692
Philadelphia (PA, NJ, DE, MD) 2,887 2,104
Shreveport-Bossier City (LA) 2,536 1,871
Detroit (MI) 2,402 1,751
National African American Total 137,688 100,564
TABL E 2
Top 10 Metropolitan Areas by African American Health Impacts Attributable to Ozone
caused by Natural Gas Pollution
Source: “Gasping for Breath,” US Census Bureau
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16 FUMES A CROSS THE F ENCE-L INE
have high levels of asthma or who are already
systemically oppressed. Figure 4 on page 15 shows
the number of asthma attacks due to natural gas
air pollution among African American children in
metropolitan areas across the county each year.37
Two of the ten metropolitan areas with the
most asthma attacks attributable to natural gas
ozone pollution are located in Texas: the areas in
and around Dallas and Houston. The Shreveport,
Louisiana metropolitan area is located near
natural gas production. In addition, the air pollu-
tion from natural gas facilities has a large impact
on some metropolitan areas that are located far
from natural gas producing regions, like in Atlanta,
Washington DC, New York, Chicago, Memphis,
Philadelphia, and Detroit.
CA SE STUDY
Downwind Air Pollution in the Mid-Atlantic
Baltimore, MD
While health risks are greatest near the original sources of pollution, airborne pollution
from oil and gas facilities can have health impacts far downwind. The air pollution from
natural gas facilities in Pennsylvania and West Virginia has had significant impacts on air quality
in M aryland, particularly in the Baltimore—District of Columbia (D.C.) corridor where there is
a high concentration of African Americans and other people of color.
A 2015 study from the University of Maryland evaluated the longer-term and long-range effects
of hydraulic fracturing on regional air pollution. The study analyzed hourly measurements of air
pollutants, including ethane — gases found in natural gas mixtures — in Baltimore and Washington,
D.C. between 2010 and 2013. It found that ethane measurements increased by 25 percent be-
tween 2010 and 2013 in the region. Ethane is the second-most abundant compound in natural
gas, which when inhaled can cause nausea, headaches, and dizziness. While there has been an
overall decline in non-methane organic carbons and improvement in air quality since 1996, the
atmospheric concentration of ethane in the region managed to rise between 2010 and 2013.38
Maryland officially banned the practice of hydraulic fracturing in 2017, although even before
the ban, hydraulic fracturing was a rare practice. After comparing the rise in ethane to natural
gas extraction in neighboring states, the researchers found a correlation. After tracking the wind
direction, distribution, and speed in the Marcellus shale play region, researchers determined that
Baltimore and other areas in Maryland and Washington DC were on the tail end of natural gas
emissions originating from sites in Pennsylvania, West Virginia, and Ohio.
In 2015, people in Baltimore experienced 89 days of elevated smog, and on 20 days it was
at unhealthy levels, increasing the risk of premature death, asthma attacks, and other adverse
health impacts.39 Baltimore is a predominately African American city, with African Americans
accounting for 63 percent of the city’s population. The city’s fence-line neighborhoods have a
history steeped in toxic fumes, industry dumping, and hazardous air pollutants. The impacts
of methane and other gases from out of state have further worsened of air quality in these
communities and the entire region. With poor air quality already, residents of Baltimore should
not also be exposed to pollution from oil and gas development in other states.
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F UMES A CROSS THE F ENCE-L INE 17
C OMMUNITY S TORY
“Over 200 cities in Texas have local ordinances regulating oil and gas activity where people
are living with these consequences. Cities all over Texas have ordinances regulating things
like reasonable distances for drilling away from neighborhoods. They have rules to protect
fresh water to decide where pipelines can be constructed. They even regulate where trucks
can drive and the hours in which facilities can operate and these are all locally regulated…
Ordinances like Dallas’s and any of the other ordinances across Texas could be overturned
as soon as the company sues the city and future ordinances have to move industry stan-
dards…. This is a human rights violation because people pass these laws to protect their
health and safety from explosions and to prevent water and air pollution and the state
agencies and the federal government will not. It was a power grab and it weakens our
most democratic institution.”
— Melanie Scruggs, TX
F IGURE 5
African American Percent of Population in Counties above EPA’s Level of Concern
for Cancer Risk from Oil and Gas Emissions
Source: “Fossil Fumes,” U.S. Census Bureau
African American Percent
of Population
n <1%
n 2%–5%
n 6%–10%
n 11%–15%
n 16%–25%
n > 25%
Many African American communities face
an elevated risk of cancer due to toxic air
emissions from natural gas development.
In the EPA’s National Air Toxics Assessment
(NATA), the EPA identifies and prioritizes air toxics,
emission source types, and locations that are of
greatest potential concern when looking at health
risk from air emissions in populations. NATA
estimates cancer risk that can result from toxic
air emissions. The metric for cancer risk is the
number of cancer cases per million people exposed;
areas with cancer risk above one-in-a-million are
considered to be above EPA’s level of concern.
In CATF’s Fossil Fumes report, 238 counties in
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18 FUMES A CROSS THE F ENCE-L INE
21 states faced a cancer risk above EPA’s one-in-
a-million level of concern due to toxic emissions
from natural gas operations.40 In 2015, over
9 million people lived in these counties, of whom
1.1 million were African American.
Of the African Americans living in counties
above EPA’s level of concern for cancer risk,
most live in Texas, Louisiana, and Oklahoma.
The inventory that our analysis relied on, the
National Emissions Inventory, may underestimate
the total emissions of toxics from natural gas.41
Many peer-reviewed studies based on indepen-
dent measurements conducted in both natural
gas producing basins and urban areas consuming
natural gas have concluded that official emissions
TABL E 3
Top 10 States with African American Population Living in Counties Above EPA’s Level
of Concern for Cancer Risk (2015 Population Data)
Source: “Fossil Fumes,” US Census Bureau
State
Number of Counties
Above EPA’s Level
of Concern for
Cancer Risk
Total Population in
High Risk Counties
Total African
American
Population in High
Risk Counties
Percent of
Population in High
Risk Counties that
is African American
Texas 82 4,189,179 528,357 13%
Louisiana 19 1,027,556 354,952 35%
Oklahoma 40 796,695 37,130 5%
West Virginia 28 804,850 30,589 4%
Pennsylvania 8 624,764 25,071 4%
North Carolina 1 169,866 22,682 13%
Mississippi 2 37,135 17,039 46%
Colorado 6 419,023 7,458 2%
Illinois 13 205,829 7,417 4%
New Mexico 3 247,495 7,093 3%
Total 238 9,086,228 1,050,372 12%
inventories such as the National Emissions
Inventory (NEI)underestimate actual emissions
from natural gas.
While the cancer risk estimates are based on
the EPA’s most recent NEI projections, there is still
a degree of uncertainty regarding emissions levels
reported to the NEI. For example, in 2015, an
expert review analysis in California identified the
need to update emissions estimates, particularly
in relation to understanding health threats for
communities in the Los Angeles Basin. Thus,
while no counties in California are above EPA’s
level of concern in the current analysis, this may
be a result of underestimated emissions reported
to EPA, not an actual indication of low risk levels.
C OMMUNITY S TORY
“Oil and gas development poses more elevated health risks when conducted
in areas of high population density, such as the Los Angeles Basin, because
it results in larger population exposures to toxic air contaminants.”
— The California Council on Science & Technology
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F UMES A CROSS THE F ENCE-L INE 19
CA SE STUDY
A History of Urban Drilling
Inglewood Oilfield, Inglewood, CA
Los Angeles has a long history of urban oil drilling.
Across Los Angeles, drilling pumps can be found
in and near public parks, as well as throughout commer-
cial and residential areas. The 1000-acre Inglewood Oil
Field, operated by Freeport-McMoRan Oil and Gas, is
one of the largest urban oil fields in the United States.
The field contains 959 wells that extract over three
million barrels of oil a year. The environmental hazards
of this urban drilling have caused countless environmen-
tal and public health issues, lawsuits, and community
actions.
Inglewood oil field, located in the north-western area
of the Los Angeles Basin, has more than one million
residents within five miles of the oil field. 50,000 house-
holds sit immediately next to the field.42 Many of these
fence-line communities are predominately communities
of color. The neighborhoods surrounding the oilfield in-
clude Baldwin Hills, Inglewood, and Culver City neighbor-
hoods, which together are 50 percent African American.
Residents and local organizations surrounding the
Inglewood Oil Fields have expressed concerns about
the environmental, health, and seismic effects of drilling
in their community. Given the proximity of the oil field
to residential areas, emissions from the site result in
continuous human exposure.
People have detailed smelling diesel or industrial
smells, as well as soapy smelling odor suppressants.
A number of advocacy groups in Los Angeles, including
the coalition Stand Together Against Neighborhood
Drilling (STAND L.A.), have called for a 2,500 foot set-
back requirement for oil facilities to protect the health
and safety of nearby residents. This distance is on the
lower end of the range researchers have recommended
as necessary to protect human health and quality of life
from the impacts of toxic emissions and exposures.43
Although community groups and members have come
forward about the toxic nature of the fumes and other
air pollutants coming from the Inglewood oilfield, local
decision makers have not addressed these concerns,
claiming that the public health impacts of this air
pollution are still unknown.44
Oil wells in a residential neighborhood in Los Angeles.© CATFOil wells in a residential neighborhood in Los Angeles.© CATFPage C.2-115
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20 FUMES A CROSS THE F ENCE-L INE
CA SE STUDY
Uneven Responses to Community Oil and Gas
Air Pollution
Los Angeles, CA
Not only are the rates of health impacts from oil and gas facilities drastically different between
communities, so is local and state responses to air pollution from these facilities. Low-income
and communities of color seldom receive the same amount of attention as higher income, white
communities when faced with major pollution related events. From October 2015 to February
2016, the affluent, suburban Los Angeles neighborhood of Porter Ranch experienced the worst
reported methane leak in the United States. The $400,000 plus homes inside gated commu-
nities are located a mile away from the Aliso Canyon natural gas storage facility, which leaked
a total of 96,000 metric tons of methane as well as other air pollutants over the course of five
months.45 This pollution caused many to experience symptoms including vomiting, rashes,
headaches, dizziness, and bloody noses.46
With the declaration of a state of emergency from Governor Jerry Brown, came an overwhelm-
ing response. Over 4,000 households in Porter Ranch were evacuated. Alongside community
and state insistence for the shut-down of the facility, the city ordered the gas company to provide
temporary housing for residents. As the largest methane leak in U.S. history, the Porter Ranch
disaster, unique in its size and suddenness, deserved a substantial response. However, Los
Angeles residents who live right next to some of the 5,000 active drilling sites in the city--
disproportionately low-income communities of color--have dealt with similar issues for years
and deserve a similar response to their plight.47
Oil operations look a lot different in low-income communities of color, where drilling sites
are often adjacent to residential areas. Jefferson Park, a South L.A. neighborhood impacted by
drilling, is 90 percent African American or Latinx This is in stark contrast to Porter Ranch, where
the majority of the population is white and median household income is more than triple that
of Jefferson Park and other neighborhoods.48
The AllenCo drilling site in Jefferson Park—now closed but pending reopening—was 30
feet away from the nearest home. Residents filed hundreds of complaints about odors, nausea,
body spasms, and respiratory illnesses, before the site was finally closed in 2013.49 Despite
the efforts of community members, the site was only closed after EPA officials became sick
while investigating the site. Communities across Los Angeles have faced the same burdens
from urban oil and gas drilling faced by the residents of Porter Ranch. The major difference
is the amount of time and the nature of the response. Other communities have faced these
health impacts for decades, with no evacuations or government response.
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F UMES A CROSS THE F ENCE-L INE 21
CHAPTER 3
Health Impacts
from Oil Refineries
In this chapter, we include case studies and
stories of community members that have
been impacted by pollution from oil refineries.
We do not quantify health impacts from oil
refineries, as we did for impacts from natural gas
facilities, but the case studies demonstrate the
range of impacts that are felt by fence-line com-
munities around the country. In addition, in this
chapter, we focus solely on petroleum refineries,
not the entire petroleum supply chain.
Refineries release toxic air pollution in commu-
nities in 32 states. This toxic mix of carcinogens,
neurotoxins, and hazardous metals—such as
benzene, hydrogen cyanide, and lead—can cause
cancer, birth defects, and chronic conditions like
asthma. While about 90 million Americans live
within 30 miles of at least one refinery, 6.1 million
Americans live within three miles of one refinery
or more.50 There are even cases, similar to natural
gas and other oil facilities, where houses are a
mere few feet away from refinery property lines.
There are 142 large refineries in the United
States, the majority of which are sited in low-income
areas and communities of color. In 2010, oil
refineries reported approximately 22,000 tons of
hazardous air pollution to the U.S. Environmental
Protection Agency (EPA).51 However, this number
fails to take into account unreported emissions
from refinery sources, like flares, tanks, and
cooling towers, as well as accidents, which can
release 10 or even 100 times more pollution than
what is reported.52 Proximity to oil refineries and
other oil and gas facilities also poses serious risk
during natural disasters. Air pollution from refineries
during and after extreme weather events severely
impacts fence-line communities. As during Hurricane
Harvey in August 2017, refineries in the
Houston, TX metro area released thousands of
pounds of toxic air pollutants, resulting in further
evacuations and curfews for local residents. The
full impact of these chemical released during
natural disasters and other events are often
immeasurable.
While about 90 million Americans
live within 30 miles of at least one
refinery, 6.1 million Americans live
within three miles of one refinery
or more.
Oil refineries are one of numerous plights for
African American and other fence-line communities,
who are subject to the environmental burdens of
the fossil fuel industry. People of color, including
African Americans and Hispanic Americans, have
a higher cancer risk from toxic air emissions from
refineries than the average person. Risk factors
are increased when also looking at adults living
in poverty.
r
Most counties with oil refineries and higher
percentages of African American residents are
concentrated in the Gulf Coast Basin (Texas,
Louisiana, Alabama, and Mississippi).
r
Texas, California, and Pennsylvania have the
most African American residents living in
counties with oil refineries.
r
Michigan, Louisiana, and Tennessee have the
highest percent of African American residents
living in oil refinery counties.
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22 FUMES A CROSS THE F ENCE-L INE
F IGURE 6
African American Percent of Population in Counties with Oil Refineries
Source: U.S. Census, Energy Information Administration Form 820
African American Percent
of Population
n <1%
n 2%–5%
n 6%–10%
n 11%–15%
n 16%–25%
n > 25%
TABL E 4
Top 10 States by African American Population Living Counties with Oil Refineries
Source: U.S. Census, Energy Information Administration Form 820
State
Total Population in
Refinery Counties
African American Population
in Refinery Counties
Percent African American
in Refinery Counties
Texas 8,973,679 1,397,018 16%
California 13,060,074 1,302,860 10%
Pennsylvania 2,214,144 848,064 38%
Michigan 1,759,335 712,290 40%
Louisiana 1,358,443 540,435 40%
Tennessee 938,069 509,942 54%
Alabama 657,160 228,846 35%
New Jersey 847,265 173,852 21%
Delaware 556,779 148,994 27%
Ohio 913,279 146,192 16%
Total 39,793,311 6,709,206 17%
Figure 6 (p. 22) shows the percent of African
Americans in U.S. counties with oil refineries.
  This chapter highlights the health impacts of
oil refinery air pollution on predominately African
American fence-line communities—communities
that sit adjacent to polluting facilities and sources.
We do not quantify health impacts using atmo-
spheric models, as we did for air pollution from
natural gas facilities, as we did in Chapter 2.
However, through case studies in Port Arthur,
Texas; Baton Rouge, Louisiana; East Bay,
California; and South Philadelphia, Pennsylvania
we explore the various impacts oil refinery opera-
tion and related events impact African American
and fence-line communities.
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F UMES A CROSS THE F ENCE-L INE 23
CA SE STUDY
East Bay Refinery Corridor
East Bay, CA
The burden placed on communities of color in the north coast of the East Bay region, which
is home to a variety of petrochemical industry sites, cannot be ignored. The five petroleum
refineries in this region emit a unique cocktail of toxic and carcinogenic compounds that impact
cardiovascular health of surrounding communities. This region, nicknamed the “refinery corridor,”
has a petroleum refining capacity of roughly 800,000 barrels per day of crude oil.53 While there
have been many strides to clean up these major sources of air pollution, health impacts in the
region, including cancer rates, are still disproportionately high. The City of Richmond’s residents
of color disproportionately live near the refineries and chemical plants.
CA SE STUDY
Burdens of a Fence-
Line Community:
Valero Oil and Gas
Refinery
West Port Arthur, TX
On the border of Texas and
Louisiana lies the city of Port
Arthur, Texas, which houses two no-
torious oil refineries: a 3,600-acre
Motiva Enterprises plant, to the
northeast, and a 4,000-acre plant
owned by Texas-based Valero to the
west. The two facilities refine more than 900,000 barrels of crude per day. Like many Gulf Coast
cities and towns, Port Arthur is not only exposed to the hazards of neighboring oil and gas infra-
structure, it is also downwind of nearly every coastal refinery in Texas, as well as other industrial
facilities.54
The western Valero refinery—one of the largest in the world—borders West Port Arthur, a
predominately African American community (95 percent African American in 2013) with several
complexes of low-income public housing that exist directly on the refineries’ fence. For decades,
West Port Arthur’s enormous refineries have released and leaked benzene, carbon monoxide,
sulfur dioxide, and other pollutants. The U.S. Environmental Protection Agency’s Toxics Release
Inventory ranks Jefferson County, Texas among the worst nationally for chemical emissions
known to cause cancer, birth defects, and reproductive disorders. Port Arthur is near the top of
the list of offending cities.55 According to the Texas Cancer Registry, cancer rates among African
Americans in Jefferson County are 15 percent higher than for the average Texan. The mortality
— C ONTIN U E D —
The Carver
Terrace housing
project sits next
to an oil refinery
in West Port
Arthur, Texas.© AP Photo/LM OteroPage C.2-119
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24 FUMES A CROSS THE F ENCE-L INE
rate from cancer is more than 40 percent higher. 56 In addition to higher cancer rates, residents
of Port Arthur were found to be four times more likely than people approximately 100 miles
upwind to report suffering from heart and respiratory conditions; nervous system and skin
disorders; headaches and muscle aches; and ear, nose, and throat ailments.57
Community activists in Port Arthur have been fighting against the refineries polluting their
communities’ air for more than a decade. Organizations, such as the Community in-Power Devel-
opment Association (CIDA, Inc.), work with community members in Port Arthur to collect and
analyze air, water, and soil samples, conduct direct action events, lobby local and state legisla-
tures, and hold large industries accountable for the pollution they create. CIDA has won many
victories alongside other local groups in Port Arthur. In 2007, CIDA Inc. was able to negotiate
an agreement for the Valero oil refinery to assist with health care cost for residents West Port
Arthur residents and for the construction of a health clinic in the community.58
The organization, with other major environmental groups, helped establish the national
Start-up Shut-down and Malfunction (SSM) Law for refineries. SSM removes exemptions for large
industrial pollution sources from meeting protective standards during facility start up, shutdown,
or malfunction and bars the use of the “affirmative defense” by industrial facilities—the defense
allowed facilities to avoid paying penalties if violations occurred because of malfunctions.59
C OMMUNITY S TORY
“Our communities have had to work hard to force the EPA to do
something about the hazardous pollution from these refineries that
we live with every day and we will keep fighting to protect our families’
and our children’s health. We refuse to just stand by while the petro-
leum industry tries to undo important progress to finally reduce the
toxic air coming from oil refineries.” 
— Hilton Kelley, executive director of Community In-Power & Development Association,
Port Arthur, TX
Valero Refinery
in West Port Arthur,
Texas
© Eugene Richards, OnEarth— C ONTIN U E D —
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F UMES A CROSS THE F ENCE-L INE 25
CASE S TUDY
Toxic Emission in
South Philadelphia
Pennsylvania, PA
Impacts are also severely felt by commu-
nities in South Philadelphia that share a
neighborhood with the Philadelphia Energy
Solutions (PES), the largest fossil fuel refinery
on the East Coast and one of the oldest in the
world. The refinery is responsible for 72 per-
cent of the toxic air emissions in Philadelphia,
which contributes largely to a citywide child-
hood asthma rate that is more than two times
the national average.62 Toxics released from the
refinery include ammonia, hydrogen cyanide,
benzene, and sulfuric acid, which cause
effects ranging from headaches to cancer.63
Philadelphia Energy Solutions (PES) fossil fuel refinery
in South Philadelphia.© Grid MagazineChallenges to SSM were denied by the Supreme Court in the summer of 2017.60 The role of com-
munity organizations, like CIDA Inc., as well as community members themselves was
critical and preserving this law.
In addition to air pollution from refinery operations, those from accidents and natural disas-
ters must also be acknowledged. Air pollution from refineries during and after extreme weather
events severely impacts fence-line communities. During Hurricane Harvey, in September 2017,
many oil refineries along the Gulf Coast of Texas and Louisiana shutdown due to severe flooding.
Refinery shutdowns, even under normal circumstances, are a major cause of abnormal emission
events. Sudden shutdown events can release large plumes of sulfur dioxide or toxic chemicals
in a matter of hours, worsening already life-threatening situations, exposing downwind commu-
nities to peak levels of pollution that increase the prevalence of negative health conditions.61
The Port Arthur community was not spared these extra pollutants in the wake of this storm.
The ills brought onto the West Port Arthur community violate basic human rights to a clean
and livable environment. Air pollution from oil and gas facilities, permitted or otherwise, is a
continued violation of this basic right.
A video by Hilton Kelley, a local Port Arthur environmental and community activist, and Executive
Director of CIDA Inc., shows Valero refinery towers spewing huge flags of orange fire and thick,
black smoke into over West Port Arthur.
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26 FUMES A CROSS THE F ENCE-L INE
A mostly abandoned
square of the
Standard Heights
neighborhood tucks
into a corner of the
Exxon Mobile plant
in North Baton
Rouge.© Bitter SouthernerCASE S TUDY
Accidents at Oil and Gas Facilities:
ExxonMobil Refinery
Baton Rouge, LA
In 2010, there was significant increase in air pollution released due to accidents at oil and gas
refineries in Louisiana. That year, facilities released 950,750 pounds of toxic pollution to the
air. Between 2005 and 2014, Louisiana’s refineries experienced 3,339 accidents that released
24 million pounds of air pollution. According to the Louisiana Bucket Brigade, from January to
April 2017 there have been 647 petrochemical accidents. 117 of these accidents were reported
from oil and gas facilities in April 2017 alone.64 These accidents are common for the majority of
oil and gas facilities nationwide. Leaks, holes, ruptures in pipelines and other infrastructure are
common and often unreported. Over 200,000 people live within two miles of most of Louisiana’s
refineries. The potential public health impacts of oil and gas accidents is considerable.
In an effort to document the impact of petrochemical accidents on local communities, a
number of community and labor groups in Louisiana—including the Louisiana Bucket Brigade,
United Steelworkers, Standard Heights Community Association, and Residents for Air Neutrali-
zation—have produced a series of reports entitled, Common Ground, since 2009. The fourth
publication, released in 2012, found that Louisiana’s 17 oil and gas refineries reported 301
accidents that leaked over a million pounds of toxic chemicals into the air. Among these air
pollutants were large quantities of benzene, a chemical known to cause cancer, and sulfur
dioxide, which triggers asthma attacks. These types of accidents are an ongoing burden
for Louisiana’s vulnerable populations.
ExxonMobil, one of the many petrochemical companies present in Louisiana, reported
the most accidents of any refiner in the state, in 2011. The company reported 138 accidents
between two of its facilities in Chalmette and Baton Rouge. The 1,800-acre ExxonMobil Standard
Heights plant in Baton Rouge, like many refineries, sits adjacent to a number of low-income and
communities of color. The city of Baton Rouge is 50 percent African American and the child
— C ONTIN U E D —
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F UMES A CROSS THE F ENCE-L INE 27
poverty rate in the Standard Heights neighborhood next to Exxon Mobil refinery is 45 percent.
The Baton Rouge refinery is the second largest in the country and is part of a 67 million square
foot (6.25 million m2) industrial complex. Tens of thousands of people live within two miles of
the complex, which produces gasoline for much of the East Coast.65
The state permits Exxon to release millions of pounds of air pollution each year from its
Baton Rouge complex. However, air pollution exceeds allowed levels due to accidents and leaks.
From 2008 to 2011 the Exxon Mobil Baton Rouge complex released four million pounds of
unpermitted volatile organic compounds (VOCs).66 VOCs contribute to increases in ozone
concentration and smog. East Baton Rouge and adjacent parishes have teetered between
normal and hazardous levels of ozone.
In 2016, the EPA finally indicated that the air quality in Baton Rouge was compliant with
EPA standards. Despite this declaration, concerned community members still report accidents or
otherwise unhealthy conditions. One citizen complaint received by the Louisiana Bucket Brigade
in April 2017, detailed air contaminants from Exxon’s Baton Rouge Refinery. One individual who
lives close to the Exxon Refinery in north Baton Rouge, made 11 calls reporting: 67
r
“foul gassy odor”
r
“a strong odor of sulfur”
r
“a smell that makes me sick of the stomach nauseous”
r
“a flame that is burning real high and there’s a foul odor in the air”
r
“a really strong odor that is like burning your nose.”
The constant release of air pollutants from oil and gas facilities, whether legal or illegal, inten-
tional or accidental, contributes to the health problems plaguing African American and vulnerable
communities. The efforts of local organizations in Louisiana to document accidents and make
that information transparent to citizens has greatly benefited community action. Information
gathered by community groups has been critical in the many actions against the construction
of the Bayou Bridge Pipeline that will cut through more low income and communities of color
in 11 South Louisianan parishes. To learn more about this pipeline and the impacts potential
accidents may have visit the Louisiana Bucket Brigade website here.
C OMMUNITY S TORY
“It’s often not worth risking a dangerous encounter in a small
southern town to stop and record pollution. What we’re recording
is another form of violence—this kind the long, steady attack of
carcinogens and neurotoxins that ruin the health and the lives of
those in Louisiana, usually African Americans, who are unfortunate
enough to live cheek to cheek with Big Oil’s refineries.”
— Anna Rolfes, Founding Director, Louisiana Bucket Brigade
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28 FUMES A CROSS THE F ENCE-L INE
CHAPTER 4
Call to Action
A ir pollution that affects many African
American communities is emitted
throughout the oil and gas sector. In
the current regulatory environment,
the disproportionate burden of pollution will only
increase for low-income communities and com-
munities of color. That means more “code red”
air quality days, more trips to the emergency
r
Many African American communities face
an elevated risk of cancer due to air toxics
emissions from natural gas development. Over
one million Americans live in counties that face
a cancer risk above EPA’s level of concern from
toxics emitted by oil and gas facilities.
r
6.7 million African Americans live in counties
with petroleum refineries.
Oil and gas infrastructure including drilling sites,
pipelines, and refineries are typically located in
low-income communities and communities of
color. These are also the areas where drilling is
likely to expand and new pipelines will likely be
built. The energy industry has and continues to
commit the same oppressive behaviors that have
ravaged communities of color for centuries. In
order to create an energy economy that upholds
communities’ rights to a healthy environment,
communities must demand changes in the oil
and gas industry, and regulators and companies
must be held accountable for the continued
suffering of fence-line communities.
We must reform the energy and industrial
sectors into cleaner, sustainable, and vibrant
economies, that work for the communities
they serve.
This means more than shifting to clean energy
sources; it requires also giving local communities
control over their energy sources and promoting
local economic growth through stable employment
opportunities. Intersectional issues demand inter-
sectional solutions that uphold social, economic,
and ecological justice. The just energy future will
serve to reduce both the poverty and the pollution
plaguing communities throughout the United
States.
Oil and gas infrastructure including
drilling sites, pipelines, and refineries
are typically located in low-income
communities and communities of
color. These are also the areas where
drilling is likely to expand and new
pipelines will likely be built.
room for asthma sufferers, and more instances
of cancer and respiratory disease. It is critical to
remember that:
r
More than 1 million African Americans live
within ½ mile of existing oil and gas facilities
and the number is growing every year.
r
Many African Americans are particularly
burdened with health impacts from this air
pollution due to high levels of poverty.
r
The air in many African Americans communities
violates air quality standards for ozone smog.
Rates of asthma are relatively high in African
American communities. And, due to ozone in-
creases resulting from natural gas emissions,
African American children are burdened by
138,000 asthma attacks and 101,000 lost
school days each year.
Page C.2-124
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
F UMES A CROSS THE F ENCE-L INE 29
In order to combat the often overlooked, life-
threatening actions of oil and gas operations, we
must both implement commonsense standards
that reduce pollution from these facilities, and
transform the current energy economy.
It will take the combined effort of community
members, decision-makers, industry, and others
to create meaningful change, which is grounded
in principles of energy democracy (local energy
choice), energy sovereignty (local control over
energy systems), and the right to live free from
pollution. Before the transition to a clean energy
economy can be achieved, it is first necessary to
eliminate the injustices that are taking human life
now. In the short term, more needs to be done
to address the air pollution resulting from the
oil and gas sector that harms the health of our
families and our communities:
1. We must all learn about the oil and gas
facilities that are located in our communities,
and advocate for their decommissioning or
removal.
Companies disproportionately build polluting
facilities in or near communities of color, leading
to unequal health impacts. In order to change
this, we need to make more communities aware
that their safety, health, and longevity are at
stake. Go to www.oilandgasthreatmap.com to
learn more about the oil and gas facilities that
are located in your community. Be sure to learn
about the impacts these facilities have in your
community. The NAACP’s Environmental and
Climate Justice Program’s publication, Just Energy
Policies and Practices Action Toolkit, can be used
to help guide community groups through energy
justice campaigns. The toolkit provides resources
and guidance for communities to organize around
energy justice issues and execute community
projects that move power back to communities
and improve local quality of life. It is crucial to
remember that any community can change, that
every community can be healthy, and that every
community has power.
It is now more important than ever for commu-
nities to become informed about and remove near-
by polluting facilities. If the current administration
has its way, the EPA’s Office of Environmental
Justice will be dismantled. The purpose of this
office has been to ensure that all communities,
regardless of race, national origin, or income, have
the same degree of protection from environmental
and health hazards. The loss of this office means
one fewer safeguard from the unequal impacts
of all types of air pollution.
2. We must support technology that cuts air
pollution.
Many proven, low-cost technologies and practices
are available to reduce methane pollution and toxic
chemicals released along with it. In fact, dozens
of companies in the methane mitigation industry
are providing technologies and services to the
oil and gas industry to help reduce methane and
other air polluting emissions. These companies
employ people at 531 locations in 46 states and
are often offering well-paying and secure manu-
facturing jobs.68 The companies that do this work
can create jobs that should be targeted to local
communities.
Completion equipment at a gas well.© CATFPage C.2-125
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
30 FUMES A CROSS THE F ENCE-L INE
3. We must urge national leaders to address
the pollution from the oil and gas sector.
Defending the methane pollution safeguards
finalized during the Obama administration and
pushing for additional protections against pollu-
tion from the oil and gas industry will help improve
the health of many African American communities
while also addressing global climate change.
In June 2016, the EPA finalized strong methane
standards covering new and modified oil and
gas facilities. The rule will cut 510,000 tons of
methane pollution from new and modified oil
and gas facilities—the equivalent of 11 coal-fired
power plants, or taking 8.5 million cars off the
road every year. In addition, the rule is also ex-
pected to reduce 210,000 tons of volatile organic
compounds and 3,900 tons of air toxics annually
by 2025. These EPA standards must be enforced,
and more also needs to be done to address the
nearly 1.3 million existing oil and gas facilities
across the country. Without government interven-
tion, the vast majority, at least 75 percent, of all
of the wells and oil and gas infrastructure in use
today, will remain virtually unregulated and can
continue to pollute methane without limit.69
Existing facilities spewed over 8 million metric
tons of methane in 2014—equivalent to 200+
coal-fired power plants.70 Common sense, low-
cost standards can both cut methane pollution
by at least half and also significantly cut toxic
and ozone smog-forming air pollution, which
would have important benefits for air quality
and public health in and downwind of oil and
gas producing areas.
4. We must urge our states to reduce oil and
gas air pollution.
Several states have stepped up to work on clean-
ing up the existing infrastructure within their borders,
including California, Colorado, and Wyoming, and
we call on additional states to follow their lead
and protect the health of communities.
Please visit www.methanefacts.org to learn
more and connect with organizations involved
in the campaign.
. . . . . . . . . . . . . . . . . . .
Environmental and energy justice issues are
multilayered. Thus, the approach to tackling these
issues must also be multilayered. People of color
and low-income communities are disproportion-
ately affected by exposure to air pollution, and
standards that protect communities from this pol-
lution are critical. In addition, these communities
have a lot to gain from the transition from the
current fossil fuel energy economy to one based
on equitable, affordable, and clean energy sources.
The first step is to address the many ways fossil
fuels taint our communities, including the air
pollution from oil and gas development.
The fight against the oil and gas air pollution
is not about making things better for fence-line
communities; it is about eliminating poverty,
racism, and other social and structural inequities
that render communities vulnerable. The air pollu-
tion that plagues communities across the country
does not have to and should not exist. It is time
to ask ourselves, what are we willing to do to
ensure a clean and healthy future?
Page C.2-126
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
F UMES A CROSS THE F ENCE-L INE 31
ENDNOTES
1 Clark LP, Millet DB, Marshall JD (2014) “National
Patterns in Environmental Injustice and Inequality:
Outdoor NO2 Air Pollution in the United States.”
PLoS ONE 9(4): e94431. Available at: https://doi.
org/10.1371/journal.pone.0094431.
2 Fleischman, Lesley et al. (June 2016), “Fossil Fumes:
A public health analysis of toxic air pollution from the
oil and gas industry.” Clean Air Task Force. Available at:
http://www.catf.us/resources/publications/view/221.
Note: This paper only accounts for pollution from
natural gas facilities and oil production facilities with
associated natural gas. It does not include pollution
from petroleum refineries. If these were included, the
health impacts would be much greater.
3 http://oilandgasthreatmap.com
4 Badger, Emily. (2016) “The nation’s housing recovery
is leaving blacks behind.” The Washington Post. https://
www.washingtonpost.com/graphics/business/wonk/
housing/atlanta.
5 Horowitz, D. A., & Benander, L. (2017). Energy
Democracy: Advancing Equity in Clean Energy Solutions.
Island Press.
6 Patterson, Jacqui, et al. (2014) “Just Energy Policies
and Practices Compendium A State by State Guide
to Energy Efficiency and Renewable Energy Policies.”
NAACP. Available at http://www.naacp.org/wp-content/
uploads/2016/04/JustEnergyPolicies%20
Compendium%20FINAL%20DECEMBER%202013%20
UPDATED%20%28Corrected%20ToC%29.pdf
7 Hildenbrand, Zacariah, et al. (2015) “A Comprehensive
Analysis of Groundwater Quality in The Barnett Shale
Region.” Environ. Sci. Technol., 2015, 49 (13), pp
8254–8262. Available at: http://pubs.acs.org/doi/
abs/10.1021/acs.est.5b01526.
Colborn, Theo, et al. (2011). “Natural gas operations
from a public health perspective.” Human and
Ecological Risk Assessment: An International Journal.
17(5):1039–1056. Available at: http://www2.cce.
cornell.edu/naturalgasdev/documents/pdfs/
fracking%20chemicals%20from%20a%20public%20
health%20perspective.pdf.
Harrison, S.S. (1983). “Evaluating system for ground-
water contamination hazards due to gas-well drilling on
the glaciated Appalachian Plateau.” Groundwater
21(6):689–700. Available at: http://onlinelibrary.wiley.
com/doi/10.1111/j.1745-6584.1983.tb01940.x/
abstract.
8 Goodman, Samuel S. (2016). “Investigating the traffic-
related environmental impacts of hydraulic-fracturing
(fracking) operations.” Environment International. 89-
90: 248-260. Available at: http://www.sciencedirect.
com/science/article/pii/S0160412016300277.
Fractracker Alliance. (2015) “Pipelines vs Oil Trains.”
Available at: https://www.fractracker.org/2015/05/
pipelines-vs-oil-trains.
9 “Toxic Wastes and Race at Twenty: 1987-2007.”
(2007). Available at: https://www.nrdc.org/sites/
default/files/toxic-wastes-and-race-at-twenty-1987-2007.
pdf.
“Coal Blooded: Putting Profits Before People.” (2016).
Available at: http://www.naacp.org/wp-content/
uploads/2016/04/CoalBlooded.pdf.
“Air of Injustice” (2002). Available at: http://www.
energyjustice.net/files/coal/Air_of_Injustice.pdf.
10 Clean Water for North Carolina. “Dangerous Neighbors:
Pipelines, Compressor Stations, and Environmental
Injustice.” Available at: http://www.cwfnc.org/
documents/Dangerous-Neighbors-Final-6-8-2016.pdf
11 https://www.census.gov
12 Id.
13 http://www.schs.state.nc.us/data/databook
14 Id.
15 https://www.minorityhealth.hhs.gov/omh/browse.
aspx?lvl=4&lvlid=15.
16 Source: CDC 2017. CDC Wonder. http://wonder.cdc.
gov.
17 Table 3 and Table B-2. https://www.census.gov/
content/dam/Census/library/publications/2016/demo/
p60-256.pdf.
18 ftp://ftp.cdc.gov/pub/Health_Statistics/NCHS/NHIS/
SHS/2015_SHS_Table_P-11.pdf.
19 http://bishop.house.gov/sites/bishop.house.gov/files/
SabalTrailEnvironmentalJusticeLetter102315.pdf
20 DI Desktop for 2015 production by county, US Census
for 2015 population estimate by county.
21 http://oilandgasthreatmap.com
22 U.S. Environmental Protection Agency (EPA). Benzene
Hazard Summary. Available at: http://www3.epa.gov/
ttn/atw/hlthef/benzene.html.
23 McKenzie LM, Witter RZ, Newman LS, et al. (2012)
“Human health risk assessment of air emissions from
development of unconventional natural gas resources.”
Sci Total Environ 424: 79-87. Available: http://www.
ncbi.nlm.nih.gov/pubmed/22444058.
24 U.S. EPA. 2011 National Emissions Inventory (NEI)
Data. Available at: https://www.epa.gov/air-
emissionsinventories/2011-national-emissions-inventory-
nei-data.   
Page C.2-127
Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
32 FUMES A CROSS THE F ENCE-L INE
Note: Many peer-reviewed studies based on indepen-
dent measurements conducted in both oil and gas
producing basins and urban areas consuming natural
gas have concluded that official emissions inventories
such as NEI underestimate actual emissions from oil
and gas. E.g. Petron et al. “Estimation of Emissions
from Oil and Natural Gas Operations in Northeastern
Colorado.” Available at: https://www3.epa.gov/ttnchie1/
conference/ei20/session6/gpetron.pdf.
25 U.S. EPA. Ethylbenzene Hazard Summary. Available at:
https://www3.epa.gov/airtoxics/hlthef/ethylben.html.
26 2011 NEI.  
27 Simonton, Scott (Oct 2007), “Human Health Effects
from Exposure to Low-Level Concentrations of Hydrogen
Sulfide.” Occupational Health & Safety. Available at:
http://ohsonline.com/articles/2007/10/human-health-
effects-from-exposure-to-lowlevel-concentrations-of-
hydrogen-sulfide.aspx.
28 U.S. EPA. Formaldehyde Hazard Summary. Available at:
http://www3.epa.gov/ttn/atw/hlthef/formalde.html.
29 2011 NEI.
30 U.S. EPA. Ozone Basics. Available at: https://www.epa.
gov/ozone-pollution/ozone-basics.
31 This chapter does not account for pollution from
petroleum refineries. See Chapter 4 for information
about those facilities.
32 Stand L.A. “The Inglewood Oil Field.” Available at:
http://www.stand.la/inglewood.html.
33 Note: This only accounts for pollution from natural gas
facilities and oil production facilities with associated
natural gas. It does not include pollution from petroleum
refineries. If these were included, the health impacts
would be much greater.
34 Baseline is EPA’s 2025 NEI projection, with additional
reductions from CO and WY oil and gas regulations that
EPA did not account for in its model. See Fleischman et
al. (August 2016), “Gasping for Breath: An analysis of
the health effects from ozone pollution from the oil and
gas industry.” CATF. Available at: http://www.catf.us/
resources/publications/view/221.
35 U.S. EPA (Sept 2015), “Regulatory Impact Analysis of
the Final Revisions to the National Ambient Air Quality
Standards for Ground-Level Ozone.” Available at:
https://www3.epa.gov/ttn/naaqs/standards/ozone/
data/20151001ria.pdf.
Studies cited include:
• Asthma exacerbations:
– Mortimer, KM; Neas, LM; Dockery, DW; Redline, S;
Tager, IB. 2002. “The effect of air pollution on
innercity children with asthma.” Eur Respir J 19:
699-705. Available at: http://www.ncbi.nlm.nih.gov/
pubmed/11999000.  
– Schildcrout, J. S., Sheppard, L., Lumley, T.,
Slaughter, J. C., Koenig, J. Q., & Shapiro, G. G.
(2006). “Ambient air pollution and asthma
exacerbations in children: an eight-city analysis.”
Am J Epidemiol, 164(6), 505-517. Available at:
http://www.ncbi.nlm.nih.gov/pubmed/16798793.
• School Loss Days:
– Chen L, Jennison BL, Yang W, and Omaye ST. 2000.
“Elementary school absenteeism and air pollution.”
Inhalation Toxicolology 12(11):997-1016. Available
at: http://www.ncbi.nlm.nih.gov/
pubmed/11015140.
– Gilliland FD, Berhane K, Rappaport EB, Thomas DC,
Avol E, Gauderman WJ, et al. 2001. “The effects of
ambient air pollution on school absenteeism due
to respiratory illnesses.” Epidemiology 12(1):43-
54. Available at: http://www.ncbi.nlm.nih.gov/
pubmed/11138819.
36 Fleischman et al. (August 2016), “Gasping for Breath:
An analysis of the health effects from ozone pollution
from the oil and gas industry.” CATF. Available at:
http://www.catf.us/resources/publications/view/221.
37 Metropolitan areas defined by US Census Bureau. See:
U.S. Census Bureau. “Metropolitan and Micropolitan
Delineation Files,” Core based statistical areas
(CBSAs), metropolitan divisions, and combined
statistical areas (CSAs). Available at: http://www.
census.gov/population/metro/data/def.html
38 Vinciguerra, Timothy, Simon Yao, Joseph Dadzie, Alexa
Chittams, Thomas Deskins, Sheryl Ehrman, and Russell
R. Dickerson. “Regional air quality impacts of hydraulic
fracturing and shale natural gas activity: Evidence from
ambient VOC observations.” Atmospheric
Environment 110 (2015): 144-150.
39 American Lung Association. “State of the Air 2017.”
Maryland: Baltimore. Available at: http://www.lung.org/
our-initiatives/healthy-air/sota/city-rankings/states/
maryland/baltimore.html.
Environment Maryland. (2017) “Our Health At Risk Why
Are Millions of Americans Still Breathing Unhealthy
Air?” Available at: http://environmentmaryland.org/
sites/environment/files/reports/Our%20Health%20
at%20Risk%20vMD%20web.pdf.
40 Fleischman, Lesley et al. (June 2016), “Fossil Fumes: A
public health analysis of toxic air pollution from the oil
and gas industry.” Clean Air Task Force. Available at:
http://www.catf.us/resources/publications/view/221.
Note: This only accounts for pollution from natural gas
facilities and oil production facilities with associated
natural gas. It does not include pollution from
petroleum refineries. If these were included, the health
impacts would be much greater.
41 See Waste Not, pp. 9–11. More recent work, including
work carried out in cooperation with the industry, has
come to similar conclusions. See Harriss, R., et al.,
(2015) “Using Multi-Scale Measurements to Improve
Methane Emission Estimates from Oil and Gas Oper-
ations in the Barnett Shale Region, Texas,” Environ.
Sci. Technol. 49, 7524−7526, and references therein.
Recent work to update and improve emissions inven-
tories, particularly for methane, is improving this situ-
ation. EPA Office of Inspector General (2013), “Report:
EPA Needs to Improve Air Emissions Data for the Oil
and Natural Gas Production Sector.” Available at:
https://www.epa.gov/office-inspector-general/report-epa-
needsimprove-air-emissions-data-oil-and-natural-gas-
production. Although the methane inventory and the
NEI, which NATA and our analysis are based on, are
developed separately, it is likely that the NEI underesti-
mates HAP from oil and gas just as the GHG inventory
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Attachment C.2: Unique Comments Received via Email Opposing the Northampton Compressor Station
F UMES A CROSS THE F ENCE-L INE 33
underestimates methane from oil and gas, for similar
reasons (underestimated emissions factors and
undercounts of equipment).
42 Stand L.A. “The Inglewood Oil Field.” Available at:
http://www.stand.la/inglewood.html.
43 Stand L.A. “Existing scientific literature on setback
distances from oil and gas development sites”
(June 2017). Available at: http://www.stand.la/
uploads/5/3/9/0/53904099/2500_literature_review_
report-final_jul13.pdf.
44 Stand L.A. “The Inglewood Oil Field.” Available at:
http://www.stand.la/inglewood.html.
45 Rode, Erin. (March 2016) “After Porter Ranch, Los
Angeles’ Low-Income Communities Want Environmental
Justice Too.” Generation Progress. Available at: http://
genprogress.org/voices/2016/03/23/42591/after-
porter-ranch-los-angeles-low-income-communities-want-
environmental-justice-too.
Environmental Defense Fund. “Aliso Canyon leak sheds
light on national problem.” Available at: https://www.
edf.org/climate/aliso-canyon-leak-sheds-light-national-
problem?utm_source=methane-counter&utm_
campaign=edf_meth_upd_dmt&utm_
medium=referral&utm_id=1450381973.
46 Bliss, Lara. “L.A.’s Slow-Moving Oil and Gas Disaster.”
Citylab (February 2016) Available at: https://www.
citylab.com/equity/2016/02/california-porter-ranch-gas-
leak-oil-environmental-justice/425052.
47 Rode, Erin (March 2016).
48 Bliss, Lara (February 2016).
49 Sahagun, Louis. (November 2013) “EPA officers
sickened by fumes at South L.A. oil field.” L.A. Times.
Available at: http://www.latimes.com/local/la-me-1109-
fumes-20131109-story.html.
50 Earthjustice. “Fact Sheet: Oil Refineries And Toxic Air
Pollution.” Available at: http://earthjustice.org/sites/
default/files/files/Refineries-Fact-Sheet_04-08.pdf.
51 Earthjustice. (February 2016) “Community Groups
Intervene To Defend Air Pollution Controls On Oil
Refineries.” Available at: https://earthjustice.org/news/
press/2016/community-groups-intervene-to-defend-air-
pollution-controls-on-oil-refineries.
52 Earthjustice. “Fact Sheet: Oil Refineries And Toxic Air
Pollution.”
53 Fractracker. (May 2017) “Tracking Refinery Emissions in
California’s Bay Area Refinery Corridor.” Available at:
https://www.fractracker.org/2017/05/tracking-refinery-
emissions-in-californias-bay-area-refinery-corridor.
54 http://archive.onearth.org/articles/2013/08/if-built-the-
keystone-xl-pipeline-will-end-in-one-toxic-town
55 Genoways, Ted. (August 2013) “Port Arthur, Texas:
American Sacrifice Zone.” Onearth. Available at:
https://iaspub.epa.gov/triexplorer/tri_factsheet.factshee
t?&pstate=TX&pcounty=jefferson&pyear=2015&pParent
=TRI&pDataSet=TRIQ1.
56 Age-Adjusted Invasive Cancer Incidence Rates by County
in Texas, 2010 - 2014. Cancer Incidence File, March
2017. Cancer-Rates.info. Texas Cancer Registry.
Available at: http://cancer-rates.info/tx.
57 Morris, D. L., Barker, P. J., & Legato, M. S. (2004).
Symptoms of adverse health effects among residents
from communities surrounding chemical-industrial
complexes in southeast Texas. Archives of Environ-
mental Health: An International Journal, 59(3),
160-165.
58 Community In-Powr and Development Association.
http://www.cidainc.org.
59 Earthjustice. (May 2015) “EPA Releases Rule To
Close Clean Air Act Loopholes For Industrial Polluters.”
Available at: https://earthjustice.org/news/press/2015/
epa-releases-rule-to-close-clean-air-act-loopholes-for-
industrial-polluters.
60 Earthjustice. (June 2017) “Supreme Court Won’t Hear
Case That Could Have Opened Dangerous Clean Air Act
Loophole.” Available at: https://earthjustice.org/news/
press/2017/supreme-court-won-t-hear-case-that-could-
have-opened-dangerous-clean-air-act-loophole.
61 Democracy Now. (August 31, 2017) “Surrounded by Oil
Refineries, Port Arthur, TX Faces New Environmental
Crisis Following Harvey Floods. Available at: https://
www.democracynow.org/2017/8/31/surrounded_by_
oil_refineries_port_arthur.
62 Pennsylvania Department of Health. “2015 Asthma
Prevalence Report.” Available at: http://www.health.pa.
gov/My%20Health/Diseases%20and%20Conditions/A-D/
Asthma/Documents/2015%20PENNSYLVANIA%20
ASTHMA%20PREVALENCE%20REPORT%20
UPDATED%20FEB%2023%202016.pdf.
Centers for Disease Control and Prevention. “Most
Recent Asthma Data.” Accessed 9/19/2017. Available
at: https://www.cdc.gov/asthma/most_recent_data.htm.
63 Philly Thrive. “A City Divided: Philadelphia’s Energy
Hub.” Available at: http://www.phillythrive.org/issue.
64 LA Bucket Brigade. Petrochemical Industry Accidents.
Available at: http://labucketbrigade.org/sites/default/
files/PetrochemicalAccidentsReport_April2017.pdf.
65 Sturgis, Sue. (December 2012) “Pollution from oil
refinery accidents on the rise in Louisiana.” Facing
South. Available at: https://www.facingsouth.
org/2012/12/pollution-from-oil-refinery-accidents-on-the-
rise-in-louisiana.html.
66 NPR. (May 2013) “Baton Rouge’s Corroded,
Overpolluting Neighbor: Exxon Mobil.” Available at:
http://www.npr.org/2013/05/30/187044721/baton-
rouge-s-corroded-overpolluting-neighbor-exxon.
67 LA Bucket Brigade. Petrochemical Industry Accidents.
68 Stokes et al. (Oct 2014) “The emerging U.S. Methane
Mitigation Industry.” Datu Research, prepared on behalf
of Environmental Defense Fund (EDF). Available at:
https://www.edf.org/sites/default/files/us_methane_
mitigation_industry_report.pdf.
69 The only existing facilities that may be regulated are
those covered by the BLM rules (finalized in November
2016) and the Control Technique Guideline Standards.
70 U.S. EPA. (2017), “U.S. Greenhouse Gas Inventory
Report: 1990-2015.” Available at: https://www3.epa.
gov/climatechange/ghgemissions/usinventoryreport.
html.
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