Category Archives: FERC

Recent Letters to the Editor

Recent letters to the editor have commented on pipeline-related issues:

Vicki Wheaton’s April 20, 2017, letter in the Farmville Herald points out the “double-insult” of FERC’s hearing, supposedly for Buckingham County, which was held not in Buckingham but at the Moton Museum in Prince George County. Moton Museum showcases the struggle for civil rights and social justice in education. Ironic that Buckingham residents of the African-American community threatened by both the pipeline and the compressor station had to go to the Moton Museum to speak against the violation of their community by Dominion.

Doug Hornig’s April 22, 2017 letter to the Daily Progress discusses State Senator Creigh Deed’s refusal “to take a position on the Atlantic Coast Pipeline, the one issue on which thousands of his constituents are looking for leadership. His reluctance to stand up to Dominion Resources, on behalf of those he allegedly represents, is an egregious betrayal of trust. It raises the ugly question of whether his voice — like so many of his fellow legislators’ — has been silenced by Dominion’s campaign donations.”

Ernie Reed’s April 24, 2017 letter to the Daily Progress wonders why “an energy company that holds a public service monopoly throughout most of Virginia must resort to using ratepayer income to service legislators on their payroll, to fund philanthropic donations that communities become addicted to, and to finance public-relations advertising campaigns such as the one that touts the so-called ‘benefits’ of the ACP.”

In Case of Emergency….


Describing how Dominion would work with local law enforcement and emergency responders to evacuate people if an ACP “pipeline incident” should occur is only one of the 111 requests FERC has made to Dominion for more specific information and clarification. Many of FERC’s requests for information were items flagged in comments filed about the Draft Environmental Impact Statement (DEIS) for the Atlantic Coast Pipeline (ACP).

Consider the plight of parents of the 430 students in an elementary school that is only 650 feet from the Mariner East 2 pipeline currently under construction in Pennsylvania. They were barred from a meeting between district and township leaders, first responders, and officials from Sunoco Logistics to discuss emergency evacuation plans in the event of a catastrophic explosion or leak.

FERC to Dominion: More Information Needed


In their weekly update, Allegheny-Blue Ridge Alliance (ABRA) reports, “The Federal Energy Regulatory Commission (FERC) wasted little time in following-up with Dominion Transmission, Inc. (DTI) to seek additional information and clarifications on numerous items, many of which were flagged in comments filed about the Draft Environmental Impact Statement (DEIS) for the Atlantic Coast Pipeline (ACP). On April 11, five days after the DEIS comment deadline, FERC wrote DTI making 111 specific requests for supplemental information, requesting that the company submit its responses by May 1 (20 days from the date of the agency’s letter).”

In the letter to Dominion, FERC asked Dominion to:

  • Conduct a thorough review in order to limit the number of access roads necessary to construct and operate the ACP, noting the very large number of temporary and permanent access roads in the current proposal
  • Incorporate small route changes and/or workspace design revisions to avoid or minimize impacts on the numerous point and area features and known and suspect closed depressions within the current project workspace that were identified in the updated Karst Survey Report filed on February 24, 2017
  • Incorporate a route variation to avoid the Valley Center area in Highland County where there is an abundance of karst features, caves, and sinking streams
  • Identify the location and temporary and permanent impact acreage of high quality wetlands
  • Provide an updated table of forest fragmentation analysis using the proper data sets, since the forest fragmentation data that DTI had submitted February 24, 2017, in response to a FERC request of October 26, 2016, was not in compliance with the agency’s requested data parameters.
  • Provide a status report on the survey, evaluation, and effect assessment of properties along the project route through Nelson County, Virginia. Include access roads and off-right-of way facilities. Report also on agency and local informant communication regarding the properties and historic districts.
  • Describe in more detail how Dominion would work with local law enforcement and emergency response to promote the safe evacuation of landowners in remote areas should a pipeline incident occur. Consult with each landowner where the proposed pipeline crosses a private egress that is the sole access to/from the property to determine if a site-specific evacuation procedure is requested.

Read the letter from FERC to Dominion here.

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.

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.