Immediately after FERC issued the Atlantic Coast Pipeline stop work order late on Friday August 10, 2018, Dominion issued a statement saying it was already working with agencies to resolve issues in the stop work order, and separate project sections not impacted by the court ruling could become viable gas infrastructure.
In a letter to FERC on Monday August 13, 2018, Mathew Bley, director of gas certificates for Dominion Energy Transmission, explained that independent segments unaffected by the court ruling could serve as gas transportation infrastructure by themselves.
“Natural gas received via (supply header project in West Virginia), at Marts, can be redelivered by the planned ACP pipeline to its Long Run delivery point into Columbia Gas Transmission Corporation LLC, in Randolph County, West Virginia … The Long Run interconnection thus would provide a substantial, viable, competitive supply option for existing Columbia Transmission shippers, even if other portions of ACP were not constructed. Subject to avoidance of any areas affected by the vacatur of the ITS … Atlantic should be allowed to proceed with construction of this useful component of the ACP.
“The ACP infrastructure from its Buckingham, Va., interconnection with Transcontinental Gas Pipe Line Company LLC (Transco) to points downstream could be used for gas deliveries to markets in both North Carolina and eastern Virginia. These markets are chronically constrained in terms of natural gas supply. Independent of ACP’s proposed construction of pipeline upstream of the Buckingham – including areas affected by the Aug. 6 court order – ACP could receive up to 885,000 Dt/day from Transco for service on the ACP main line and the Virginia lateral.
“Depending on the availability of supply and relative operating pressures on the Transco system, ACP expects that its physical receipts at Buckingham could exceed 885,000 Dt/day. Although this approach would not provide the full benefit of access to the DETI system and the liquid South Point market hub (which customers expect upon completion of the ACP), this portion of the ACP infrastructure … would serve to redeliver gas to Hampton Roads and eastern North Carolina markets, where interstate pipeline capacity is either already fully subscribed, or nonexistent.”
Dominion asked FERC to “promptly allow construction to resume for the independently useful portions of the projects.”
It appears Dominion is tacitly admitting that the entire ACP is not necessary, and gas could be delivered to both existing and future markets by other means.
However, as pointed out by Southern Environmental Law Center in its letter of August 15, 2018 urging FERC to deny Dominion’s request to move forward on certain parts of the ACP, “If these segments do not serve the purpose Atlantic intended them to serve as interdependent parts of the approved ACP, they are separate projects that must go through the approval process set forth in the Natural Gas Act.” (See story above)