Summary Statement for Chickahominy Power Plant Independent Spatial Analysis - June 4, 2019
In a spatial analysis report for the Chickahominy Power Plant project currently under consideration with the Virginia Deparment of Environmental Quality, a series of concerning project aspects were quantified and mapped using publically available data. While the report itself goes into detail regarding each, a short summary is provided below:
The proposed gas-fired project would be the 5th such siting in the US where a combined output of > 2,500 MW is sited within 1.1 miles of another plant. This is an atypical configuration within the larger field of 1,700 + gas-fired plants. The current application does little to address the combined output and potential impacts of such a configuration on localized populations.
The current application contains little Environmental Justice (EJ) analysis, certainly none that could be considered robust. The only EJ document found in the current application is an appendix printout of EJSCREEN for various project proximities. The spaital analysis in the report, however, details with both maps and tabular results the existence of EJ eligible local populations in close proximity to the project.
In addition to EJ eligible populations based on US Census data, the report further considers the spatial intersection with indigenous tribal lands, further contextualizing and bolstering EJ eligibility for this project.
In addition to the various demographic analyses of the report, consideration is given to the emission modeling methods and results found in the application. Mirroring consistent concerns and issues over modeling protocol found in the public record for this project, the report highlights the absence of any meaningful discussion, mapping or quantification of combined and localized emissions from both the C4GT facility and the Chickahominy plant. In light of this application deficiency, there is no method by which to gauge potential adverse and disproportionate air quality impacts on EJ eligible populations in close proximtiy to the combined projects. As such, the current application is deficient in both informing and protecting the public.