We, the undersigned residents of Virginia, call on the Virginia Department of Environmental Quality (DEQ) to:
1) Determine that Chesterfield and Henrico Counties are particularly affected by the proposed Chesterfield Energy Reliability Center (CERC) and, in accordance with state law, hold a minimum 30-day public comment period following any DEQ hearing on the permit;
2) Provide 30-days of notice prior to the DEQ Response to Comments Hearing; and
3) Reject Dominion Energy’s Prevention of Significant Deterioration (PSD) permit application.
DEQ’s mission is to protect and enhance Virginia’s environment to promote the health and well-being of the Commonwealth's residents and visitors. Its vision is that all Virginians enjoy cleaner water and better air quality.
The proposed CERC is fundamentally at odds with DEQ’s mission and vision. The facility would worsen local air quality by emitting over 2.2 million tons of carbon dioxide-equivalent per year, more than 100 tons of fine particulate matter (PM2.5) annually, and significant increases in hazardous air pollutants (HAPs).
According to public health models, increased emissions of PM2.5, sulfur dioxide (SO₂), nitrogen oxides (NOₓ), and volatile organic compounds (VOCs) from the proposed CERC would impose $13 to $21 million in annual health-related costs on Virginians, $3.3 to $4.8 million of which would fall on Chesterfield County alone.
The proposed site at the Chesterfield Power Station operated for almost 80 years as a coal-burning facility. A recent study found heavy metals associated with coal ash embedded in the James River’s banks, the largest tributary to the Chesapeake Bay. Dominion is still working to remove millions of cubic yards of toxic coal ash from on-site ponds, including the one in Chesterfield.
Communities in Chesterfield and Henrico have already borne decades of air and water pollution. Adding a new fossil-fuel facility to this site would compound that legacy, placing a disproportionate burden on local residents. Nearby communities, including Hopewell, Petersburg, Charles City County, and Prince George County, already shoulder disproportionately high cumulative pollution burdens. CERC would only worsen this injustice.
In accordance with state law for localities “particularly affected” by proposed fossil-fuel facilities over 500 megawatts, written public comments must be accepted for at least 30 days after any public hearing.
Finally, we respectfully urge DEQ to reject Dominion’s PSD permit application. The permit confirms the facility would emit significant quantities of carbon dioxide, PM2.5, NOₓ, carbon monoxide, VOCs, methane, lead, and other harmful pollutants. Cleaner, more affordable alternatives exist. Virginians deserve an energy future aligned with DEQ’s mission: one that protects public health, improves air quality, and safeguards our environment for generations to come.
References:
Virginia DEQ, CERC PSD Permit Application (2024), https://www.deq.virginia.gov/home/showpublisheddocument/27961/638767579192800000.
PJM, 2024 Load Forecast Supplement, Resource Adequacy Planning Dept., p. 25.
Dominion Energy, CERC CPCN and Rider CERC Application, Case No. PUR-2025-00037, filed under Code of Virginia § 56-580(D), 56-46.1, and 56-585.1(A)(6).
Abt Associates & UNC-Chapel Hill, COBRA v5.2 Tool (EPA, 2025); Dominion, CERC Air Permit Application (March 2025); COBRA run used 2028 analysis year, 2% discount rate, and Table 3-6 of Dominion’s application.
Frankel et al., “Trace Metal Impacts of Coal Ash on Chesapeake Bay Tributary,” Environmental Toxicology and Chemistry, vol. 44, no. 3, March 2025, pp. 802–811, https://doi.org/10.1093/etojnl/vgae073.
