Nelson BOS Comments to FERC

Central District Supervisor Ernie Reed, writing on behalf of the Nelson County Board of Supervisors, commented to FERC on the proposed Treatment Plans and Mitigation for impacts to cultural and historical resources in the Rockfish Historical District and Warminster Historical District from the proposed Atlantic Coast Pipeline.

The Nelson Board of Supervisors is a consulting party in the Section 106 process for the ACP. The letter outlines the numerous procedural difficulties in the Section 106 process.

After listing deficiencies the letter continues, “The scar left by the ACP across the face of our mountains, farms, rivers and streams and historic places would deform a unique and pristine natural environment rich in cultural memory and traditions that bring home the historic and cultural contributions of generations of Nelson families—white, black, red and brown. This unique and vital interplay of historic and natural landscapes is increasingly rare in this country. Qualities and cultural values that have been carefully stewarded on the land in Nelson over many generations would be altered by the ACP. Moreover, the 29 miles of proposed Atlantic Coast Pipeline (ACP) would bisect Nelson County and destroy the cultural and historical integrity of the entire County in perpetuity.”

The letter notes, “Nelson County’s agricultural, historical, cultural and archeological significance must be treated as a whole by any Treatment Plan mitigating these damages: ie. damage to the parts of the County must be addressed as damage to the whole county.”

Speaking of the December 28, 2017 Memorandum of Agreement for Mitigation of Virginia Forest Fragmentation Impacts of the Atlantic Coast Pipeline, the letter points out that “Areas not directly impacted by the proposed ACP will benefit from these mitigation dollars; for instance, the $5m CACF funds are targeted to be spent totally in Albemarle County at Biscuit Run State Park. Not a single inch of the ACP will be located in Albemarle County. It is noteworthy that not a single penny of these allocated mitigation funds for fragmentation impacts has been allocated to benefit Nelson County.”

After describing the several forest conservation and agricultural-forestal areas in Nelson County that would be bisected or destroyed by the ACP, and noting that “Nelson County forests are scheduled to be totally bisected by a 125’ clearcut for a total of 29 miles. Including clearing for new access roads, nearly 440 acres of Nelson County’s forests will be destroyed,” the letter says, “Rather than mitigation for these egregious violations, the MOA provides funds designated for ‘forest fragmentation’ specifically to build parking lots, roads, bathrooms, etc. at Biscuit Run Park, as previously mentioned, in Albemarle County. ”

The letter concludes, “We are again reminded the extent to which Dominion, our Commonwealth, and federal government have failed to strive for a just compensation of the cultural damages to our communities and people. No individual, government, much less a corporation should be allowed immunity to the damages and liability that may be caused by this pipeline in a single lump-sum payment.”

Read the full letter here.

Thanks to Supervisor Ernie Reed for this well-written letter, and to the Nelson County Board of Supervisors for their position on the proposed treatment plan and mitigation plan outlined by Dominion for the proposed ACP.