Where Are the Plans?

A June 30, 2017, article in the Richmond Times-Dispatch announces that, “Virginia has informed federal energy regulators that it will expand its review of two proposed interstate natural gas pipelines to protect water quality beyond the stream and river crossings covered by a general federal permit.” DEQ’s Director, David Paylor, tries in the article to explain the agency’s plans (the new plans? the original plans?), acknowledging that the agency’s position had sown public confusion about whether the state would review all potential effects on water quality from construction of the proposed pipelines. According to the Richmond Times-Dispatch article, DEQ “is preparing additional conditions for certifying the protection of water quality under the Clean Water Act and submitting them for public comment in a series of hearings next month,” three on the ACP and two on the MVP.

The announced hearings will be on August 7, 8, 9, 10, and 14, 2017. Where are the plans? What are the “additional conditions”? When will they be available to the public for review?

DEQ has hired a company with business ties to Dominion to review the plans. [Remember the story of the fox guarding the hen house?] Has that company seen the plans? Has Dominion even submitted any site-specific plans to DEQ for review? Such site-specific plans provide the information needed for a meaningful analysis of water resource risks and mitigation measures.

Why is DEQ initiating a public comment period, scheduling hearings, and preparing to recommend project certification to the State Water Control Board without making the promised plans available to the public?

Dominion Pipeline Monitoring Coalition (DPMC) points out that “If the detailed erosion and sediment control and stormwater management plans are on the DEQ pipeline review website, they are certainly not easy to find. We have not found them. We are looking for site-specific plan view and cross-section diagrams of corridor and access road construction, showing the extent of excavation, the disposition of spoil, and the locations and specifications for erosion and runoff control and slope stabilization structures? We also want to see the post construction runoff calculations that should be part of stormwater management plans.”

And DPMC asks, “Is the DEQ colluding with Dominion to hide site-specific erosion and sediment control and stormwater management plans from the public? Is the DEQ attempting to ensure that there is no independent technical evaluation of the project during the all-important 401 review process? This would be ‘above and beyond’ an abdication of responsibility.”

Where are the plans?