Category Archives: Dominion

Dominion Refuses Route Change Recommended by Own Contractor

As this April 6, 2018, comment to FERC makes clear, Dominion not only ignores expert citizen input, but also ignores the recommendations of the experts they themselves hired.

Little Valley, Bath County, VA, near ACP mile marker 93 of the ACP, is underlaid by limestone and is characterized by numerous karst features including springs and sinkholes. Most Little Valley residents depend entirely on spring water for all household and agricultural needs. Little Valley Run is a high quality spring-fed stream that holds native brook trout year round. The Valley Center area of Highland County is very similar to Little Valley and faces many of the same threats from the ACP.

Dominion has constantly assured citizens that their concerns about problems associated with placing a pipeline of this size through limestone aquifers were being addressed. Dominion hired GeoConcepts, an engineering firm with expert knowledge of karst topography, to evaluate and make recommendations regarding the proposed route.

The comment to FERC states that it has now become evident that Dominion has been routinely ignoring the advice of GeoConcepts, which proposed a route that would avoid karst areas in both Bath and Highland Counties – a route that was rejected by Dominion. Further, this route, which would have avoided karst areas in Valley Center, Little Valley, and Burnsville, would seem to be almost identical to one proposed by the Virginia Department of Conservation and Recreation in a letter to FERC in August 2017.

“It seems clear that Dominion has no intention of voluntarily facing the problems that they have created for themselves by ignoring the reality of the terrain they have chosen for the ACP. Both GeoConcepts and the Virginia DCR have recommended a route that would avoid the degradation of sensitive karst areas in both Bath and Highland Counties. We are relying on the members of the State Water Control Board to hold Dominion to their promises to protect the most precious resource we have — our water.”

Read the full comment here.

The ACP’s Fake Plans

Section of design sheet for ACP Milepost 85 area, one of only six areas in Virginia for which detailed site-specific pipeline construction plans have been obtained. Colors are added for clarity. Heavy wire mesh will be used to hold a 120% slope area in place above the stream. The indicated unnamed tributary drains to a native trout stream.  Higher resolution version here.

On April 9, 2018, Dominion Pipeline Monitoring Coalition summarized the current status of Dominion’s construction plans for the Atlantic Coast Pipeline.  Dominion Energy asserts that the ACP has received an unprecedented level of regulatory review, and it’s time to get on with it. Meanwhile it withholds its real construction plans while expecting broad waivers from environmental conditions and standards.

Dominion has persistently failed to make site-specific construction plans available to the regulatory agencies and the public. It has instead provided low-resolution plan sheets and generalized descriptions of environmental control practices. We now know that Dominion has plans that it has not shared with government decision makers, and we know it seeks exemption from critical regulatory requirements.

The curtain was pulled back in February 2018 when, after protracted delay, Dominion submitted site-specific plans to the Forest Service for six high-hazard locations in Virginia. Based on these plans we know that:

  • the steepest mountainsides will be held in place using heavy-wire mesh fastened to underlying bedrock with 8 to 15-foot or longer “nails”
  • excess spoil resulting from trench and workspace excavation may be spread on ridgelines or deposited adjacent the pipeline corridor
  • trenches will be dynamited through high-quality streams and backfilled with concrete

It also seems that Dominion is ignoring or perhaps intends to seek a wholesale variance from the State Water Control Board’s requirement that it reduce the width of the construction corridor from 125 feet to 75 feet within 50 feet of streams and wetlands to minimize the extent of riparian buffer disturbance. The most-recent available plans indicate that the width of construction disturbance at stream crossings remains 125-feet wide.

And it remains unclear if Dominion expects to receive a general variance allowing it to exceed the 500-foot open trench limit imposed by Virginia Erosion and Sediment Control regulations. Dominion has indicated that it will seek open-trench variances that will cover 99% of the pipeline corridor in western Virginia, including even the steepest mountainsides.

For more information see the April 9, 2018, post on the Dominion Pipeline Monitoring Coalition Web site:  Fake Plans for the ACP

Volunteers, Citizens Deserve Information

In an April 4, 2018, editorial, The Recorder reminds us of something we all know already: “Openness and transparency are not Dominion Energy’s strong suits, as we’ve learned over the last four years. It just doesn’t seem to share well with others.” The editorial discusses The Recorder‘s efforts to have a reporter attend a Bath County meeting to discuss the how-to details of responding to emergencies related to Dominion’s proposed Atlantic Coast Pipeline construction and operation.  Dominion first closed the March 20, 2018, meeting to the public, then (after the finally agreeing a reporter could attend) cancelling the meeting, then hurriedly rescheduling a hush-hush meeting in a venue over which Dominion had control of attendees and thus could deny attendance by press and public.

The Recorder says, “To their credit, both Dominion and EMS representatives offered to give us the meeting details later, which they did, but it’s much harder to report the facts and discussion when a reporter is not there to hear context and perspective.

“Emergency rescue and fire volunteers have said dozens of times that understanding the essential plans for handling any emergency during and after pipeline construction was critical to their knowledge base.

“What personnel will Dominion have on hand while construction takes place? What are their skills and certifications? What kind of personnel does Bath County need to augment its own volunteer base? Who responds first? Do our rescue squads, first responders, deputies, and firefighters have the right kind of equipment to handle sudden illness, fire, or accidents in the rough mountain terrain where this pipeline is planned? If there is extra or specialized training needed, will Bath County be able to secure that before construction starts?

“Some of these questions were answered last week; some were not.

“There are dozens of important questions, and neighboring residents want to know these things, too. Everyone needs assurance our county is prepared for the kinds of emergencies that have not arisen here before.

“Bath County citizens, and especially emergency volunteers, deserve answers. We are encouraged that last week’s meeting provided some answers and put a few minds at ease.

“But we are endlessly discouraged that Dominion makes getting answers so difficult for the general public.

“It’s not like these are state secrets, folks. Open up.”

Dominion’s Assault on the Blue Ridge


An update from the Pipeline Compliance Surveillance Initiative, Alleghany-Blue Ridge Alliance:

As reported previously, aerial photographs of apparent unauthorized construction work where Dominion Energy proposes to drill through the Blue Ridge Mountains for the Atlantic Coast Pipeline were obtained during recent surveillance flights conducted by the Pipeline Compliance Surveillance Initiative (CSI), a program of the Allegheny-Blue Ridge Alliance (ABRA). Requests for investigation and clarification were submitted to FERC and the Virginia DEQ.

In response to media inquiries concerning “noncompliance with restrictions against earth disturbance and construction prior to receipt of required approvals,” Dominion spokesman, Aaron Ruby, asserted that the company is doing nothing of the sort, and that it is instead doing a geotechnical survey. See Pipeline prep area allegedly being constructed, citizen group files against FERC, News Leader, 3/23/18

CSI Investigator, David Sligh, has responded on behalf of ABRA, objecting to Mr. Ruby’s characterization of the construction activity and noting that over a year ago, when pipeline opponents objected to inadequate geotechnical study of the proposed drilling, Dominion responded by declaring that geotechnical investigation had been “fully accomplished.” See Dominion’s pipeline story doesn’t add up, Letter to News Leader, 3/30/18

The Backstory and a Warning 

Dominion intends to drill 4,639 feet through the Blue Ridge under the George Washington National Forest, Appalachian National Scenic Trail, and Blue Ridge Parkway. Dominion’s plans call for use of horizontal directional drilling (HDD) and contingency use of direct pipe installation (DPI) if the HDD operation fails. Given the topographic and geophysical challenges at the site, the Forest Service initially conditioned any authorization for ACP construction on prior successful completion of the proposed HDD or DPI operations. This condition would have avoided a situation in which significant investment associated with premature ACP construction would be put at risk and in direct conflict with established legal protection of highly valued public resources. Should the HDD and DPI prove impracticable after ACP construction is underway, there will be a strong incentive for allowing an open-cut crossing of the Appalachian Trail and the Blue Ridge Parkway.

The proposed drilling operations will have an extreme environmental footprint, requiring extensive excavation for entry and exit workspace, pipe pullback, fabrication, and testing workspace, as well as siting of heavy equipment for pipe handling, and a network of access roads – all on steep mountainsides with multiple stream crossings. As with other aspects of the ACP, the public and regulatory review agencies have not had access to detailed construction plans. The areas and amount of excavation required for construction have been imprecisely specified at best.

The Dominion Pipeline Monitoring Coalition published a report in early 2017 describing both the risk of failure and the unavoidable environmental damage associated with the plans for drilling through the Blue Ridge. This report described the risk factors confronting both the HDD and contingency DPI operations. Although detailed geophysical investigation of the drill path is standard practice for assessing the feasibility of prospective HDD and DPI operations, the information considered during environmental review was limited in both scope and reliability. No subsurface borings were completed at or near the HDD endpoints and geophysical survey data were obtained for less than 25% of the drill path. See A High-Risk Proposal: Drilling Through the Blue Ridge Mountains for the Atlantic Coast Pipeline

Now, we learn that Dominion Energy is belatedly collecting data that should have been collected and made available during environmental review. 

Dominion Energy knows how to game the system:  defer collection and analysis of essential environmental data until after the review process is concluded and approvals have been obtained. 

Further info:

CSI Incident Report – submitted to DEQ, 3/13/18

Request for Investigation – Submitted to FERC, 3/22/18

From the ABRA Update: ACP in Highland County

ABRA Update #174 for March 29, 2018, highlights the excellent reporting of The Recorder on Dominion’s efforts to ram the ACP through the problematic terrain of Highland County:

    • Pipeline, comp plan at issue tonight – The Recorder – 3/28/18.  Highland County tonight will stage its first effort to give citizens a local face-to-face encounter with Dominion over the $6.5 billion interstate gas pipeline project, rife with delays and setbacks, and how it could affect the county’s future.
    • Valley Center is central proof ACP must move – The Recorder – 3/28/18.  In all the hundreds of thousands of confusing bits of information pushed from Dominion to the Federal Energy Regulatory Commission, Valley Center gets consistently and, might we offer, intentionally, overlooked.
    • But wait, there’s more … – The Recorder – 3/28/18.  Need more evidence Dominion’s pipeline will cause irreparable damage?