Dear Dr. Fine,
As you may know, on March 3, the Federal Energy Regulatory Commission (FERC) issued a certificate of approval for the AIM project, part of which is a major build-out of the natural gas compressor station in Burrillville.
This is a follow up of our recent meeting in which we urged you to block Spectra Energy’s proposed pipeline expansion. My impression when we left was that we had failed to convince you of the relevance to Rhode Island and to Burrillville in particular of the health concerns raised in Fossil Free RI’s letter of November of last year. Much of those concerns were echoed in the report of Dr. Howard Zucker, Commissioner of Health in New York, the report that convinced governor Cuomo to ban fracking in New York.
As you can read in the attached paper, well heads in frackville and compressor stations anywhere have a lot in common. I have highlighted in the following quote what is wrong with the FERC procedure used to issue the certificate of approval mentioned above:
In the present study we consider estimates of emissions from well pads, compressor stations and processing plants to gauge individuals’ possible exposures and the health risks those exposures pose. This is necessary because much of the publicly accessible emissions data has been collected to provide average exposures over a lengthy period of time and because the data collection is intended to document compliance with regional air quality standards. To assess health impacts, it is, therefore, necessary to look at human exposures in the short term. What matters from a health perspective is the content and intensity of exposures at the individual level. The critical questions are: What is a person, in a given household, exposed to? How high do those exposures climb? How often is that resident exposed to these high levels? What happens physiologically when a particular toxic comes in contact with the body?
Analogous reasoning applies to the radioactive contamination released by scheduled and unscheduled blowdown events. To average effects of radiation over space and time, as FERC does in its estimates, is unjustified given that the exposure profiles for communities near compressor stations are unknown and certainly not isotropic in space nor homogeneous in time. In this context I note that we were told by Doug McVay at RIDEM that problems pertaining to radon are RIDOH’s not RIDEM‘s.
At the end of this email you will find two more quotes and references all pointing in the same direction. Here I would like to draw your attention to the following:
TITLE 23 Health and Safety
CHAPTER 23-1 Department of Health
The department of health shall […] adopt proper and expedient measures to prevent and control diseases and conditions detrimental to the public health in the state.
This was part of the message that we tried to deliver to you last Friday at the end of our protest march from Burrillville to Providence. Unfortunately, you were out of town at the time. Title 23 makes it clear to any reasonable citizen that your department would be derelict in its fiduciary duty if it were to let the pipeline expansion in Burrillville proceed without a thorough investigation, if at all.
As I understand that you will be leaving your position of Director at the Department of Health at the end of this month, I copied in Dr. Nicole Alexander and I attached the letter Fossil Free RI sent to you in November of last year.
Given that the certificate of approval for the AIM project has been issued, time is running out quickly and I urge you to act without delay.
Professor of Physics
Formaldehyde is another volatile compound that exceeded health-based risk levels near compressor stations in Arkansas, Pennsylvania, and Wyoming. As with benzene, there are known sources of formaldehyde emissions along the production chain. Formaldehyde is a product of incomplete combustion emitted by natural gas-fired reciprocating engines at compressor stations
Most emissions are related to ongoing activities, i.e., gas production and compression, which can be expected to persist beyond initial development and which are largely unrelated to the unconventional nature of the resource. Regulatory agencies and the shale gas industry, in developing regulations and best practices, should consider air emissions from these long-term activities, especially if development occurs in more populated areas of the state where per-ton emissions damages are significantly higher.