Friends of Nelson Board member Marilyn Shifflett has written a thoroughly researched letter to David Paylor, Director of the Virginia Department of Environmental Quality (DEQ), urging DEQ to carefully consider the long-term consequences of pipeline construction and citing abundant evidence of the extensive damage done by companies during construction and their unwillingness to address permanent damage after construction completion.
In her letter, dated July 14, 2017, she writes, “Patterns concerning construction of these projects have emerged that are alarming, to say the least. Included in this letter, are “situations” and violations during pipeline construction that are seen all too often. While the FERC has intervened in a small number of cases; in the majority of these situations, both the FERC and the Army Corps of Engineers in charge of issuing the nationwide permits for wetland and stream crossings have not reacted at all. The VA DEQ is inarguably now reviewing the greatest environmental challenge ever faced in our State from these two proposed mammoth pipelines. Thousands of acres of protective forested land will be stripped, and nearly two thousand streams will be crossed with countless wetland areas impacted. While the task is monumental, it’s vital that the VA DEQ consider the overall behavior of the natural gas industry and ongoing pipeline construction. The following information and related links serve as testament to this industry’s activities after lengthy reviews and permits are issued, and validates the concerns expressed by residents all along the routes of the ACP & MVP. The highly sensitive environmental areas coupled with the steeps slopes of these particular routes exacerbate the issues Virginians will likely be left to deal with if either or both of these pipelines are ever constructed.”
Shifflett goes on to summarize the extensive environmental, regulatory, and compressor station violations by a number of pipeline companies, including Dominion. She points out that “These pipeline companies routinely allow the violations to stack up, simply pay the fines, and consider them part of the cost of doing business. There is no clear intent on their part to honor agreements made to institute ‘best practices.’ The regulatory process often doesn’t react quickly enough to forestall damages, and the violation notice process is complicated and lengthy, allowing these companies to complete projects before damages can be further avoided. Is the VA DEQ prepared to monitor construction of both the ACP and the MVP simultaneously? Is the VA DEQ willing to shut down construction on the entire route through VA when the first violation occurs?”
She cites some specific examples of Dominion violations:
- Dominon G-150 8″ pipeline in WV: These violations are a stark example of Dominion’s lack of commitment to best practices for a pipeline less than one fifth the diameter of the proposed Atlantic Coast Pipeline; a small pipeline constructed on the steep slopes of West Virginia without many of the complications expected from the much larger ACP.
- Dominion Transmission, Multiple Sites, PA & WV: Records from the Pipeline Hazardous Materials and Safety Administration cite Dominion for multiple safety and regulatory regulations.
- Dominion Transmission, Fink Kennedy Storage, West Virginia: Again, Dominion is cited for multiple violations at this site from Sept., 2009 through June, 2010. Dominion has a pattern of lengthy response times to violations at their facilities and seems rarely to take corrective actions until violations and orders are issued. These are not the actions of a company committed to safe operation and concern for residents living nearby.
Shifflett concludes, “The preceding lengthy information is offered as a record of the behavior of the natural gas industry and stands as a testament to concerns expressed by Virginia residents along the routes of these pipelines…. The routes of the ACP and the MVP were chosen for cost savings related to easement purchases and relaxed regulation in sparsely populated areas. The VA DEQ is obligated to look beyond costs to these companies; judging these routes based solely on environmental realities. The majority of the ACP/MVP routes are through terrain unsuitable for a 42” high pressure pipeline and the damage will be irreparable. The deforestation of thousands of acres for right-of-ways, access roads, and temporary work spaces will leave a lasting impact on the Chesapeake Bay and the decades of efforts to clean up this precious Virginia resource. And certainly, the VA DEQ will realize after examining applications from these companies, that they have little to offer in the way of detailed slope analyses, and stream crossing plans that will avoid permanent damage to environmentally sensitive areas. Given the predictable actions of the natural gas industry, approval of the ACP or the MVP will surely lead to additional companies following suit and Virginia will be facing additional damage. With a 14% guaranteed return from FERC approval, Dominion and EQT will not be the only companies looking to profit off the backs of Virginia citizens. Virginia residents have taken the time to thoroughly review these projects and ask that the Virginia Department of Environmental Quality do the same. Please reconsider allotted comment periods, and schedule public meeting only after all reports are available for review by residents.”
Read the full text of Shifflett’s letter here. The letter also appeared in full in The Recorder for July 20. 2017.