Category Archives: Environmental Impact

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.

WhoWhatWhy Article

“Will Activists Be Able to Stop the Atlantic Coast Pipeline?” That’s the question discussed in this excellent article in Who.What.Why. The article accurately reviews both Dominion’s claims about the benefits of the pipeline and the evidence on both lack of need and resulting damage presented by the many organizations and individuals opposing it. It is a fine summary of the arguments – a good article to send to anyone who has not followed the day-by-day pipeline developments.

Excellent Pipeline News Coverage

The Recorder, the weekly newspaper for Highland and Bath counties, provides continually excellent coverage of many issues associated with the proposed Atlantic Coast Pipeline.  Note:  Access to full text of articles is by subscription only.

The April 6, 2017, issue includes these articles:

  • Citizens group demands withdrawal of pipeline statement — “A citizens group has filed a motion to rescind and revise the draft environmental impact statement for the proposed Atlantic Coast Pipeline. In a filing with the Federal Energy Regulatory Commission posted Monday, Friends of the Central Shenandoah states the draft EIS either needs to be withdrawn and revised or supplemented to meet the letter of the law.”
  • Stop the Pipeline’ campaign under way — “The Blue Ridge Environmental Defense League and chapters will take to the highways and byways of North Carolina and Virginia for eight days in April on a barnstorming tour of communities threatened by natural gas pipelines.
  • Things are getting real around here – “Highland County supervisors deserved a meeting much sooner. Dominion Resources, which plans to construct an interstate gas pipeline through part of southern Highland, came before the county board last week — three months after a draft Environmental Impact Statement for the project was issued in late December. Finally, they were given an audience with Dominion officials to ask some questions they’ve posed before, and more specific questions that have not been addressed until now. Of course, the answers were not satisfactory, the way we see it.” The article goes on to discuss in detail the many negatives of the proposed pipeline (and Dominion’s less than helpful answers), including how it goes counter to the county’s comprehensive plan in many aspects, how movement of workers to the proposed construction site would be “equivalent to a third of our entire residents traveling one of only two main arteries into this county, for 10 hours a day, six days a week, for about two years,” Dominion’s lack of specific answers on source of the millions of gallons of water needed for testing. And many more issues.

Conflict of Interest?

According to an April 2, 2017, report in DeSmog, Merjent, an environmental consulting company hired by FERC as an independent third-party contractor to assist in the review of the proposed ACP, has strong ties to Natural Resource Group, Dominion’s main environmental and engineering contractor for the proposed ACP.

Dominion records submitted to FERC say that Dominion hired Natural Resource Group for a variety of tasks, including environmental and permitting services and field surveys, and Natural Resource Group was behind many of the resource reports for the proposed ACP.  But Natural Resource Group, which has been working on the ACP since 2014, is one of Merjent’s clients.  Additionally, “DeSmog has also found that eight Merjent employees currently reviewing the Atlantic Coast pipeline — more than a third of its team members for the project — previously worked for Natural Resource Group.” Is Merjent an independent third-party contractor? Not really!

Read the full article in DeSmog here – and also here in Truthout.

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