The Pipeline Compliance Surveillance Initiative (CSI) is a program developed by the Allegheny-Blue Ridge Alliance and its member organizations to support citizen efforts to ensure strict application of environmental laws and regulations in the construction and operation of the Atlantic Coast Pipeline (ACP). The need for citizen oversight of pipeline construction has been made clear by observations of recent pipeline projects and inadequate regulatory agency response to repeated violations and water resource harm.
Pipeline CSI will focus first on the approximately 200-mile section of the proposed ACP route extending from Harrison County in West Virginia to Buckingham County in Virginia. The extreme earth disturbance required for construction of the ACP in this area of steep mountain sides, high-quality streams, and karst valleys presents an unacceptable risk to water resources.
You can help! Here are the various ways volunteers can participate:
Work independently or with other organizations to observe and report incidents of both downstream surface water impact and noncompliance with construction requirements.
May be organized by coordinators affiliated with local or other regional organizations.
Access for viewing pipeline construction areas will ordinarily be limited to public roads or other public vantage points.
General guidance for citizen observers is provided on the Pipeline CSI website.
Can submit incident reports to CSI Central by using methods provided on the Pipeline CSI website or by methods provided by other organizations.
Stream Monitoring Program Volunteers
Participate in monitoring programs managed by local watershed groups and regional programs such as the Trout Unlimited/West Virginia Rivers Pipeline Monitoring program or the Isaak Walton League Save Our Streams program.
Take part in training and certification conducted by the monitoring programs.
Follow protocols and reporting methods established by the monitoring programs.
Can submit incident reports to CSI Central using methods provided on the Pipeline CSI website or by methods provided by the stream monitoring programs.
Research and Administration Volunteers
Monitor ACP filings to FERC including the Environmental Compliance and Weekly Status Reports.
Monitor FERC docket for inspection reports, variance requests, and other ACP constructionrelated documents.
Review construction-related documents provided by regulatory agencies.
CSI First Responders
Teams dispatched by CSI Central to investigate reported incidents of surface water impacts or noncompliance with pipeline construction requirements.
Recruited based on professional or scientific background related to water resources or erosion and sediment control and stormwater management.
Collect data and investigate reported incidents following Pipeline CSI protocols.
Pipeline Air Force
Pilots recruited and trained to fly routine pipeline surveillance flights and incident response flights.
Photographers recruited to obtain aerial imagery of pipeline construction areas.
Drone operators recruited and trained to obtain aerial imagery of pipeline construction areas.
Pipeline Air Force participants will follow Pipeline CSI protocols.
CSI Incident Review
Provide input to the Pipeline CSI Environmental and Forensic Review Teams evaluating incidents of surface water impacts or noncompliance with construction requirements.
Access to review information will be provided through the online CSI Mapping System.
Review assistance is requested from professionals with erosion and sediment control and stormwater management backgrounds, as well as from other knowledgeable individuals.
Training will be scheduled for interested participants, and information concerning regulatory and technical requirements will be provided through the Pipeline CSI website.
A video from Water Is Life. Protect It, and the Interfaith Alliance for Climate Justice: Red Terry, speaking from the tree stand on her own property on Bent Mountain, in the path of the Mountain Valley Pipeline, where local officials and MVP’s private security are trying to starve her out.
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.”
“This is a more comprehensive view of what happened yesterday [April 9, 2018] when the MVP’s tree-cutting crew, Northern, tried to cut trees on Poor Mountain. Deepest of appreciation for the courageous protectors on the ground in the snow facing the intimidation of chainsaws, security teams and police in order to give witness to this illegal and immoral act. The MVP LLC is in direct violation of their own argument to Federal Judge Elizabeth Dillon who awarded them immediate possession of property to cut trees based on testimony that the deadline for cutting was March 31 and they would suffer ‘irreparable harm’ if they were not allowed early entry. What does that mean? They do not have all the permits necessary to cut and the restrictions on cutting are fairly clear in terms of protections of endangered species and protected waterways. They were ‘allowed’ to cut BUT ONLY UNTIL MARCH 31. ….
As documented in the [above] video and observed by a certified legal observer, the notice of violation was clearly stated to the security official and the crew. They chose to proceed regardless. They are now officially engaging in illegal tree-cutting after being issued a warning based on legal evidence provided in a necessary and appropriate Citizen’s Notice of Violation and should be held accountable to the law.”
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
The 10th Annual Kite Festival, organized by the Rockfish Valley Foundation, was held on April 8, 2018, a windy, sunny, chilly day.
Richard Averitt asks, “Did you know The Atlantic Coast Pipeline is planned through the heart of the kite festival? This festival and the community it builds is what we love about Nelson County and we will never let Dominion take that away.”