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Oct 04

Please submit a comment by Oct. 19 to stop Dominion from polluting more!

LATEST UPDATE: All comments must be received by the PSC no later than October 19 — either by 5 p.m. at its Baltimore address (6 St. Paul St., Baltimore) or by 10 p.m. at the hearing in Lusby (12200 Southern Connector Blvd., Lusby). If you used our online comment tool before midnight on October 17, we printed your comment and mailed it to the PSC in time. After October 17, it’s too late to use our online tool.

The Maryland Public Service Commission announced a continuation of the October 2 hearing to allow the people who were signed up to speak but weren’t able before the meeting was closed a chance to speak. Anybody who didn’t come or sign up to speak at the October 2 hearing is also welcome to come and give testimony. People who were called to speak at the October 2 hearing and didn’t, or people who already spoke at the October 2 hearing will not be able to speak at this new hearing.

The hearing will be on October 19, from 6-10 p.m. at Mill Creek Middle School, 12200 Southern Connector Blvd., Lusby, MD. Please come if you can! The deadline for submitting written comments has also been extended to October 19.

How do I submit my comment?

The Maryland Public Service Commission (PSC) does not allow digital comment submissions. To send a comment directly to the PSC, make sure to include the permit number 9318 and mail it to:

David J. Collins, Executive Secretary
Maryland Public Service Commission
6 Saint Paul Street
Baltimore, MD 21202-6806

To make it even easier for you, we created a tool where you can submit your comment online, and we will print it up and get it to the PSC in time. To submit your comment through our online tool, just CLICK HERE.

The bottom line is please submit a comment!

What is the issue? (Short, short version)

Dominion is asking for two things:
1) to use additional generators to help supply power to its fracked gas export terminal and liquefaction facility in Cove Point; and
2) to throw out numeric monitoring of its emission of volatile organic compounds (VOCs). Dominion is currently restricted by its Maryland Public Service Commission (PSC) permit to emit no more than 2.53 tons of VOCs per year. In one fell swoop, Dominion is saying it plans to emit eight times as much VOCs, and the company is asking to no longer be restricted to stay within any numeric limit for VOC emissions. Of course, this increased amount of VOCs would enter into the air around the facility and the lungs of every living thing near it.

That sounds terrible. What are some more details?

VOCs leak from many types of components (e.g., valves, connectors, piping flanges, etc.). In its original application, Dominion projected that the project would use approximately 15,000 of these components and that fugitive VOC emissions would be up to 2.53 tons/year. In the application for this permit change, Dominion is now reporting that the number of components is going to be closer to 162,700. Using this new, much larger number, Dominion estimates that total VOC emissions would reach 20.1 tons/year.

Because the project is being built in Calvert County, an area that is already getting failing grades for ozone, and VOCs are an ozone precursor, Dominion is obligated to achieve a standard called the “Lowest Achievable Emission Rate (LAER)” for VOC emissions from these components. When it issued its permit for this project, the PSC imposed two separate requirements to implement this standard: (1) It imposed a limit of 2.53 tons/year; and (2) it required implementation of a “Leak Detection and Repair (LDAR) program.”

Based on the projected 700 percent increase of VOCs, Dominion now seeks to modify the certificate of public convenience and necessity (what the PSC calls its permit, abbreviated as CPCN) to remove the 2.53 ton/year VOC limit and to simply rely on Dominion detecting and repairing any egregious leaks (the LDAR program) to satisfy the lowest achievable emission rate standard. This is a significant step away from what the state regulators permitted to protect public health and the environment.

So, how would this affect me?

For one, this would likely mean that the air quality near the facility would get a lot worse because VOCs are known carcinogens. Health effects can include loss of coordination, nausea, and damage to the liver, kidney and central nervous system.

More VOCs in the air would mean worse ozone quality. Even at low levels, breathing ozone can cause chest pains, coughing and throat irritation. It can also aggravate lung diseases like emphysema, bronchitis and asthma. The more ozone pollution a person breathes, the more permanent damage it can do to their lungs.

Against better judgment and steep public opposition, this facility is being built in a neighborhood, with homes as close as across the street, in the most populated area in Calvert County. Within two miles of this facility are 2,365 homes, 19 day care centers, three churches, two schools, two shopping centers, two senior centers and around 7,000 residents. Altogether, there are more than 20,000 people living in the Lusby area and nearly 45,000 living in southern Calvert County. Many of these people would be breathing in these additional VOC emissions every day if this application is approved.

Additionally, a PSC ruling in Dominion’s favor could set a devastating precedent for monitoring VOC emissions throughout Maryland and beyond. Dominion’s justification for this proposed change to PSC monitoring limits is circular logic: that the PSC should remove the limit on fugitive VOC emissions because of the “infeasibility of applying a measurement methodology to the piping and equipment components.” All VOC measurements of emissions are estimates. That has been known for some time. Nonetheless, the threat to public health is so great that estimated values have been set for decades and specific safeguards have been put in place precisely because these are “best estimates.”

Instead of eliminating VOC emission limits, given recent improvements in sensor technology, the PSC and the Maryland Department of the Environment should be pushing to improve the accuracy of the measurement technology, not abandoning it. And the PSC certainly shouldn’t revise its existing permit in a way that would allow Dominion to send any more pollution into our air!

Should the PSC approve Dominion’s request based on the company’s rationale, there would be no reason why the same logic could not be applied to all harmful emissions that are measured using estimates and approximations, not just VOCs. Such a precedent would provide justification in every community that has an existing gas well, pipeline, compressor station or power plant nearby for companies to request the PSC waive limits on VOC emissions because they are too hard to measure. This would set back decades of environmental regulations put in place to protect our health and our lives.

Make sure to click here and check out the factsheet we created for the public hearings.

What can I do about this?

Please submit a comment — and encourage those around you to do so, too! All comments opposing this application help, even if they’re as simple as saying “I urge you to reject Dominion’s application.”

What carries the most weight is when you speak from what’s inside you, and that’s often easier to do, too! If you’re able to follow the nuances of this requested permit change or if you have a technical background, please highlight the specific problematic aspects that you see from Dominion’s application. If you simply live in the area and don’t want you or your family to breathe dirtier air — or you don’t live in the area and you don’t want to see others breathe dirtier air — then just stating that, talking about how this could impact you or your family or others you care about, mentioning any health problems you might already have, and saying how changing this permit in a way that allows Dominion to pump more VOCs into this air has a real chance of making things worse, that really sits with someone when they hear it.

The bottom line is, no matter how this permit change affects you, stating your truth will be the most powerful thing you can say. And each additional comment puts more pressure on the PSC to reject this application.

One more time, how can I submit comments?

Written comments can be received until October 19. Send written comments to:

David J. Collins, Executive Secretary
Maryland Public Service Commission
6 Saint Paul Street
Baltimore, MD 21202-6806

If you send a written comment, please be sure to include the related case number with all comments (9318, in this case). The commission does not respond to written comments. However, a copy of the written comments are recorded and maintained in the correspondence file.

CLICK HERE to use our easy-to-use tool for submitting a public comment.

How can I help spread the word?

Please share this webpage with everyone you know who might be concerned about this. Anybody can submit comments, whether or not they live in Cove Point, Calvert County, or even Maryland. They just have to care — and we need as many people as possible to help us get this application rejected!

Where can I find direct links to the documents on all of this?

Public Service Commission case file for case number 9318:
http://www.psc.state.md.us/search-results/?keyword=9318&x.x=13&x.y=10&search=all&search=case

Dominion’s application letter asking for these changes:
http://webapp.psc.state.md.us/newIntranet/Casenum/NewIndex3_VOpenFile.cfm?filepath=C:\Casenum\9300-9399\9318\Item_200\\DECPCPCNAmendmentJuly102017.pdf

Dominion’s entire application packet regarding these requested changes:
http://webapp.psc.state.md.us/newIntranet/Casenum/submit_new.cfm?DirPath=C:\Casenum\9300-9399\9318\Item_200\&CaseN=9318\Item_200