Category Archives: DEIS

HDD: A Limited Review by a Company Working for Dominion

[Photo by John Claman:  Piney Mountain,Three Ridges, Reed’s Gap]

On April 17, 2017, the US Forest Service submitted a supplement to a filing made on April 6, 2017, which transmitted Forest Service approval of the primary and contingency proposals for the horizontal direct drilling (HDD) drilling under Reeds Gap and the Appalachian Trail near the sole entrance/exit for Wintergreen. The supplement provides the documents the Forest Service received from GAI, the 3rd-party contractor who conducted the review.

The GAI review should have included – but didn’t – the Dominion Pipeline Monitoring Coalition (DPMC) report, A High Risk Proposal: Drilling Through the Blue Ridge Mountains for the Atlantic Coast Pipeline. Instead of being comprehensive, GAI’s review is limited, stating only, “Based on our review of the geotechnical and geological data provided for the proposed HDD, GAI believes an HDD in this location is feasible.”

DPMC’s Rick Webb says there is, “No real discussion or analysis of the issues or even reference to most of the issues – just an opinion – no reference to the lack of geophysical info for most of the drill-path or the extreme conditions.” The DPMC report on drilling through the mountain includes detailed information on how the HDD could fail, which GAI seems to have ignored, and GAI did not address at all the extreme environmental footprint of the project.

Webb continues, “I expressed concern about an obvious conflict of interest to the Forest Service when I heard that GAI was the reviewer. GAI works for Dominion on the ACP. See: https://gaiconsultants.com/project/atlantic-coast-pipeline-project/

Webb adds, “GAI reps were at the open houses during the EIS scoping period – assuring us of the high-environmental standards and technical capacity of Dominion and the pipeline industry. GAI was also the company that prepared the Erosion and Sediment Control Plans for the recent Stonewall Gathering Pipeline in WV (notable for poor behavior with respect to implementation of the ESC plans on the ground; see http://pipelineupdate.org/2015/08/28/stream-zero/; also in the path of the ACP).”

Note added on April 21, 2017DeSmog reported on April 20, 2017, that after DeSmog’s story linking GAI to Dominion, GAI removed mention of its link to Dominion from its Web page.

You May Still Make Comments

The April 10, 2017, deadline for commenting to FERC on the DEIS has passed. However, comments may still be submitted about new information. Friends of Nelson encourages everyone to file comments if/when there is new information about the ACP, including the proposed route and the compressor station. Comments filed after April 10 will not be legally relevant to the final EIS, but such comments can be referenced in any administrative review or subsequent litigation. If you wish to submit comments on new information, see the instructions on our FERC page.

US Forest Service Comments on DEIS

In their comments to FERC submitted on April 6, 2017, the Forest Service cited shortcomings in both the ACP and MVP proposals and asked FERC to reconsider merging the two proposals into a single pipeline proposal. In the DEIS, FERC said, “Construction and operation of a merged system alternative may hold an environmental advantage when compared to construction and operation of both (ACP) and (MVP) separately.”

But FERC also said in the DEIS, “Pursuing this (merged system) alternative would require significant time for the planning and design, result in a significant delay to the delivery of … natural gas to the proposed customers of both (ACP and MVP), and would limit the ability to provide additional gas to the projects’ customers. When the environmental factors, technical feasibility, and ability to meet the purpose and need of the projects are cumulatively considered, we do not find that the merged system alternative holds a significant advantage over the proposed actions and have eliminated it from further consideration.”

The Forest Service response: “This statement is not supported by the information presented. If the merged system is potentially environmentally advantageous, then it is possible that the merged system is preferable to the proposed actions.”

In addition to discussing the merge of the MVP and ACP, the Forest Service filing also discusses concerns about water pollution, landslides, ridge removal, wildlife habitat, forcing the Forest Service to amend its publicly vetted plans and – most of all – the DEIS implications that project approval as proposed is certain.

Steep Slopes – Compendium of Links


In mid-March 2017, Friends of Nelson released the Steep Slope Report by Blackburn Consulting Services, which concluded that “Dominion has not adequately identified those soils and landforms that are prone to debris flows (and) landslides.” The report also states that “the potential for debris flows in the very steep mountainous portions of Nelson County is underestimated by the reports submitted to FERC by Dominion.”

For ease of reference, we list below links to the Steep Slope Report and related materials:

Steep Slopes Study by Blackburn Consulting:
http://friendsofnelson.com/wp-content/uploads/2017/03/Final-Steep-Slope-Report-March-2017.pdf

Comments on the DEIS by consultant Dr. W. Lee Daniels (he is at Virginia Tech. He also did consulting work for the MVP):
http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20170403-5168

Comments on the DEIS by Blackburn Consulting/Soil Foundations (the guy who did our steep slopes soil study):
http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20170403-5158

Joyce Burton’s comments to FERC on why the DEIS is deficient and misleading, with the unexamined impacts to Roberts Mountain as a illustrated case-in-point, comments inspired by the extremely narrow ridges during the Steep Slopes study (see photo above – top of ridge is only 40 feet wide and the ACP requires a 125 foot right-of-way for construction):
https://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20170404-5061