In Joint Comments filed with FERC on July 14, 2017, seven groups urged FERC to include in the final Environmental Impact Statement (EIS) for the ACP a recommendation that the ACP alter its proposal to avoid Virginia Outdoors Foundation (VOF) open-space easements, the same approach to protecting VOF easements that FERC recently took with the Mountain Valley Pipeline (MVP).
The Comments state, “One issue of common and significant concern is the impact the proposed ACP route would have on ten open-space easements held by VOF and, by extension, the Commonwealth of Virginia’s open space land protection program. The proposed route that Atlantic Coast Pipeline, LLC (Atlantic) is pursuing for the ACP would cross ten VOF open-space easements, permanently impacting 54.6 acres of protected property and damaging another 73.8 acres of these properties with construction access roads and other related disturbances. These are just the direct impacts to these parcels; there would also be substantial and irreversible indirect impacts. As VOF has made clear, such a major intrusion on VOF open-space easements would not only impair the conservation values of each of the ten affected properties, it could jeopardize the Commonwealth’s investments in conservation and result in a loss of public confidence in the effectiveness of openspace easements.”
The Comment also points out that it is not VOF but the ACP “that has proposed the Hayfields Farm property as potential mitigation for impacts to VOF’s open-space easements, and it has done so as part of its effort to persuade VOF to grant ‘conversions’ of the open-space easements pursuant to a provision of the Virginia Code. Of note, VOF has not acted on Atlantic’s requests.”
The seven groups who signed the Joint Comment are Southern Environmental Law Center, Piedmont Environmental Council, Highlanders for Responsible Development, The Nature Conservancy, Shenandoah Valley Network, Shenandoah Valley Battlefields Foundation, and Cowpasture River Preservation Association.
Read the full filed Comment here.