The undersigned individuals urge the North Carolina Department of Environmental Quality to deny Transcontinental Pipe Line Company’s request for air quality permits for expansions to compressor stations 150 and 155 as part of the Southeast Supply Enhancement project.

Transco seeks to expand its existing compressor stations located near Lexington (station 155) and Mooresville (station 150) with methane gas-fired turbines and gas-fired emergency generators. With this proposed project, station 155 would quadruple in size.

This proposed expansion would worsen nearby air quality and release higher levels of harmful pollutants, including particulate matter, volatile organic compounds, nitrogen oxides, acrolein, benzene and formaldehyde. In its application, Transco does not account for the already high level of pollution that communities near the compressor stations face.

Air monitors operated by local and state agencies near both compressor stations have shown excessive levels of fine particulate matter, or PM2.5, in recent years, with levels in Charlotte violating the federal standard and the amounts in Lexington just below the federal standard. Another air monitor near Charlotte has recorded that ozone levels are worsening each year and are now just below the federal standard.
Compared to the rest of North Carolina, the neighborhood near the Lexington station already ranks in the 84th percentile for PM2.5, the 80th percentile for ozone, and the 75th percentile for toxic releases to air. The Mooresville compressor station is less than one mile away from a block group that is in the 88th percentile for PM2.5, 85th percentile for ozone, and 81st percentile for toxic releases to the air, compared to the rest of the state.

Scientists have found that there is no safe level of exposure to PM2.5, and exposure can cause severe impacts on the cardiovascular and respiratory systems. Exposure to pollution from ozone and nitrogen oxides can also cause adverse respiratory symptoms.

Despite existing unhealthy levels of PM2.5 and ozone pollution in these areas, Transco proposes to increase its emissions of PM2.5 and the pollutants that form ozone (nitrogen oxides and volatile organic compounds). These projects would increase the risk of adverse health impacts for nearby residents.

According to data from the Environmental Protection Agency’s EJScreen tool, the area directly across the street from compressor station 155 is already in the 84th percentile regarding its local-income population level, with low-income defined as household incomes that are less than two times the Federal Poverty Level. This project could burden low-income communities with higher healthcare costs, considering the potential impact of air pollution on residents’ health.

The DEQ must account for existing pollution levels in its review of these applications, and it cannot approve the permits if the projects would contribute to air pollution that would exceed federal health-based standards.

Given the elevated background levels for air pollution and the risk of cumulative impacts posed from the operation of multiple new gas-fired turbines, DEQ must take extra care to ensure it does not authorize operations that would cause or contribute to presumptively unhealthy levels of air pollution. DEQ has authority under 15A NCAC 02D .0501(c) to require a facility to implement more stringent pollution controls in order to prevent exceedances of ambient air quality standards. DEQ should exercise this authority and require Transco to use alternate combustion turbine technology in the form of electric turbines – similar to those installed by Transco at compressor stations 165 and 166 just across the border in Chatham, Virginia, which would significantly reduce the level of on-site air pollution.

We request that the DEQ protect the air quality and health of communities that would be impacted by these projects and deny these air permit applications. If the air permits are granted, then based on a report from the Sierra Club and 7 Directions of Service, we request that the DEQ at a minimum:

• Conduct a thorough review of local ambient air quality and community health in the areas surrounding compressor stations 150 and 155 in order to understand the existing conditions and assess potential health impacts from Transco’s proposed projects.
• Require Transco to install electric turbines rather than gas-fired turbines in order to prevent exceedances of ambient air quality standards for PM2.5 and ozone.
• Request that the Federal Energy Regulatory Commission complete an Environmental Impact Statement due to the project’s large scope, cumulative impacts, and significant environmental threats.

Thank you for your time and consideration.