Although this September 2, 2017, Roanoke Times article is about the proposed Mountain Valley Pipeline, the same issues of steep slope construction will be faced by the proposed Atlantic Coast Pipeline. As indicated in this article, MVP seems to say that if they can’t do what they want, they will do things that are even worse. We suspect Dominion would use the same tactics.
“Mountain Valley Pipeline reacted forcefully after its plan to establish a permanent access road through a conservation easement on Poor Mountain was nixed by the federal commission reviewing the project. The company’s protest, filed with the Federal Energy Regulatory Commission, offers a glimpse of some of the challenges and risks Mountain Valley could face burying a 42-inch diameter natural gas pipeline on remarkably steep slopes in Roanoke County. For example, Mountain Valley described scenarios ‘that would require up to 10 winch tractors daisy-chained together to move a single load of materials, equipment, fuel or personnel up and down the slopes’ if use of the access road is denied.”
Read the full article here.
Davis Creek area, August 1969
Friends of Nelson has submitted extensive comments on the proposed 401 Water Quality Certifications for the Atlantic Coast Pipeline to Virginia’s Department of Environmental Quality (DEQ). The comments include:
- A letter written by Board member Jim Bolton related to activity on steep slopes and in slide-prone areas such as found in Nelson County, including patterns of recurrent destructive landslides and resulting debris flows and fans, and similar rapid erosional processes; includes links to supporting documents and U.S.G.S. maps and documents
- A letter by Board member Joyce Burton on water quality issues, specifically those related to activity on the steep, landslide-prone slopes found in Nelson County
- Comments on FERC’s Draft Environmental Impact Statement (DEIS) for the ACP prepared by Dr. W. Lee Daniels on behalf of Friends of Nelson in April of 2017 addressing (among other things) disposal of excess spoil, risks posed by acid forming materials (AFM) in the soils along the pipeline route and inadequate procedures to mitigate them, and adverse impacts of the proposed soil disturbances on farmland productivity, with the overall conclusion that the project as proposed could potentially negatively affect soils and water quality in Nelson County and surrounding landscapes.
- August 2017 memo by Dr. Daniels confirming that his April 3, 2017, report is also clearly applicable to the current DEQ review process
- A bound copy of Blackburn Consulting Services, Nelson County Report, Report Analysis and Field Verification of Soil and Geologic Concerns with the Atlantic Coast Pipeline in Nelson County, VA, dated March 2017, discussing pipeline construction and the potential for increased landslide risk and increased soil erosion, especially on steep slopes
It is DEQ’s responsibility to safeguard our Virginia’s water resources. Building the ACP in terrain that is as steep, difficult to stabilize, and nearly impossible to successfully revegetate such as that found in much of Nelson County poses an unacceptable risk to our precious water resources. ACP has not committed to adhering to the same standards and safeguards on private lands as on Forest Service lands, leaving Nelson’s steep, landslide-prone slopes particularly vulnerable.
Contrary to what has been implied in their aggressive marketing campaign, ACP’s “Best in Class” (BIC) program for managing the challenges of steep slope and narrow ridgetop construction is still “under development,” and other slope instability/landslide risk reduction measures have not yet been adopted. Because of this, and because of the inadequacy of ACP’s landslide risk analysis on non-USFS lands along the route, neither stakeholders nor the DEQ can thoroughly assess the likelihood and magnitude of the slope stability-related environmental effects of the project nor the sufficiency of their plans for the multiple sites that we anticipate to be at high risk.
The cited inadequacies in the ACP’s plans are not isolated aberrations, but rather constitute an underlying pattern of inadequate analysis and planning which has the potential to severely impact Virginia’s waterways.
Lots of interesting news stories in the last week. What have you missed? Click on the In the News tab above for many other current stories or use the archives links in the dropdown menu for earlier stories.
New from Dominion Pipeline Monitoring Coalition!
The DPMC has published an interactive Critical Zone Mapping System (CZMS) in support of citizen efforts to overcome the continuing failure of the regulatory system.
The CZMS provides a framework for evaluation of the risk associated with construction of the ACP and the limitations of the proposed or available control measures. The CZMS includes user-selectable map layers that display a number of key factors that should be considered during project review and prior to project approval. Among these are layers that indicate slope steepness, soil erodibility, high-excavation areas, stream crossings, surficial karst, and existing dye traces in karst systems.
One of the more-critical map layers identifies those sections of the pipeline corridor and access road system that meet Dominion’s criteria for application of its so-called “Best in Class” program. These areas, where the existing ground slope is 30% or more for distances of 100 feet or more, present a high risk to downslope water resources due to erosion, slope destabilization, and runoff alteration.
Although Dominion has posted what it describes as detailed erosion and runoff control plans, the plans do not include “Best in Class” measures. With limited exceptions, the actual site-specific details for application of the “Best in Class” program have not been provided for regulatory agency and public review, and apparently they will not be provided until after project approval.
These high-risk “Best in Class” areas represent almost half the length of the proposed ACP pipeline corridor and access road system in the mountainous counties of Virginia and West Virginia.
Among the more-extreme of the “Best in Class” measures is the use of heavy steel wire mesh to hold steep mountainsides in place after pipeline construction. Click here for a larger version of this image.
For more information see: The ACP Critical Zone Mapping System
DCMP photo: The centerline of the proposed ACP along the ridge crest of Little Mountain. Extreme excavation will be required for pipeline construction and maintenance of a permanent right-of-way.
Dominion Pipeline Monitoring Coalition has published a new report on construction of the proposed Atlantic Coast Pipeline across Little Valley in Virginia’s Bath County: Little Valley: High-Hazard Pipeline Construction.
The Little Valley area, like much of the proposed ACP route through the mountains, presents extreme challenges for pipeline construction due to steep slopes, high-excavation requirements, erodible and slip-prone soil cover, and interconnected karst ground water systems.
Examination of regulatory documents and available project plans for construction of the pipeline corridor and access roads in the Little Valley area reveals a general failure of the review process conducted by the Federal Energy Regulatory Commission and raises concerns about permitting by the Virginia Department of Environmental Quality.
Little Valley exemplifies the significant risk posed by Dominion’s persistent failure to conduct critical studies to assess environmental hazards and to provide the detailed project plans needed for informed agency and public review of the project.
The Virginia Department of Environmental Quality announced in April 2017 that it would conduct a stream-by-stream review prior to issuing a Water Quality Certification for the ACP. We now know that the VADEQ instead plans to narrowly limit its review, and that it will rely on U.S. Army Corps of Engineers permitting for stream and wetlands crossings. The USACE generally authorizes pipeline projects under a previously issued blanket (nationwide) permit without analysis of individual stream crossings or the cumulative effects of multiple stream crossings.
To date, it seems that neither the VADEQ nor the USACE have received complete applications from Dominion, and it has not been confirmed that Dominion will be required to submit site-specific construction and environmental mitigation plans with the level of detail needed for meaningful review by the regulatory agencies and the public.
“Walking the Line: Into the Heart of Virginia” presents “Why this fight?” A conversation with some, not remotely all, of the organizations and volunteers working to stop the Atlantic Coast and Mountain Valley fracked-gas pipelines.
With Nancy Sorrells of Augusta County Alliance, Kirk Bowers of the Sierra Club Virginia Chapter, Lee White of Walking the Line and Cville Rising, Joyce Burton of Friends of Nelson, Joseph Jeeva Abate of Yogaville Environmental Solutions – YES and Malik Olson of Walking the Line and Cville Rising.
This is such a good fight for so many reasons and we haven’t yet even talked about the unlawful use of eminent domain. We will. Go to http://walkingtheline.org/ to learn more. Join us!