Shortcomings in the biological evaluation (BE) and geohazard analyses for the Atlantic Coast Pipeline (ACP) filed by Dominion were expressed in filings by the National Forest Service (NFS) with the Federal Energy Regulatory Commission (FERC) on September 30. Some examples of the NFS concerns:
- The ACP filing about landslides “mischaracterizes the hazard of shallow landslides and underestimates the threat to the pipeline”;
- The potential impact for the pipeline and project facilities, including access roads, on slope instability is not addressed;
- The purpose of a BE is to assess the potential impacts of a project on Regional Forester’s Sensitive Species. This document contains a great deal of extraneous material not relevant to a BE;
- Required improvements of access roads need to be described on a site-specific basis for each access road, particularly any areas that require widening or other disturbance of vegetation, rock, or soil. Detailed maps of the proposed access roads (permanent and temporary), construction methods of new and improvements of existing roads and reports of all biological surveys for these sites must be provided for this aspect of the project. Site-specific effects must be analyzed in the BE. Such detail is required to assess impacts to sensitive species located adjacent to or near these roads;
- Finally, the NSF admonishes Dominion to “Spellcheck the entire document.”
The NFS comments on the geohazard analyses are available here; the BE comments are available here.
NFS Expresses Concerns Over ACP Geohazard and Biological Analyses