The Draft Environmental Impact Statement (DEIS) for the Atlantic Coast Pipeline (ACP), released December 30 by the Federal Energy Regulatory Commission (FERC), unfortunately exceeded –negatively – the already low expectations most people had for it.  The 3-volume, 2,375-page document was prepared pursuant to requirements under the National Environmental Policy Act (NEPA). Written comments are due Thursday April 6.  There will also an opportunity for people to comment in person at several public meetings; details on those will be forthcoming.

FERC stated that its purpose in preparing the DEIS was to:

  1. identify and assess potential impacts on the natural and human environment that would result from constructing and operating the ACP;
  2. describe and evaluate reasonable alternatives to the ACP that would avoid or minimize adverse impacts on the environment;
  3. identify and recommend specific mitigation measures, as necessary, to avoid or further reduce/minimize environmental impacts; and
  4. encourage and facilitate involvement by the public and interested agencies in the environmental review process.

The agency’s identification of potential environmental impacts was generally comprehensive.  But, it’s analysis and evaluation of those impacts, as well as its judgment about alternatives that the law requires FERC to consider, was seriously wanting.  ABRA’s Steering Committee prior to the release of the DEIS began to develop response plans.  The committee confers further on January 5 to finalize plans to comprehensively analyze the DEIS and to develop plans for mobilizing concerned citizens and communities to become fully engaged in providing critical comments to FERC.  A press release jointly issued on December 30 by several ABRA member organizations (sent in a separate email to the ABRA mailing list that afternoon) discussed some of the shortcomings. Below are some of the conclusions that FERC staff articulates in the DEIS:

  • “Because the Commission does not have a program for or direct the development of the natural gas industry’s infrastructure, either on a broad regional basis or in the design of specific projects, and does not engage in regional planning exercises that would result in the selection of one project over another, we have determined that it would not be appropriate to prepare a programmatic EIS.”
  • “Because a natural gas transportation project is proposed before the FERC, it is not likely that it would lead to additional drilling and production. In fact, the opposite causal relationship is more likely.”
  • “Based on our review of Atlantic’s and DTI’s proposed construction methods, its implementation of impact avoidance and minimization measures, and our consultations with state agencies and other resource managers, along with our recommendations, we conclude that the potential for the ACP to initiate or be affected by damaging karst conditions would be adequately minimized. “
  • “Concerns were raised regarding the potential for construction activities to intercept subterranean streams and “behead” the water source. We conclude the likelihood of intercepting a saturated karst conduit is very low.”
  • “Based on literature reviews and discussions with real estate appraisers, we conclude that the ACP would not result in decreased property values.”
  • “Based on the implementation of impact avoidance, minimization, and mitigation measures, we have concluded that the majority of impacts from construction and operation of the ACP, when added to the impacts of other projects, would not result in a significant cumulative impact on the environment.”
  • “Based on an extensive review of publicly available information, we have found no evidence that karst hazards such as sinkhole development pose a safety or integrity risk to interstate transmission pipeline facilities. For these reasons, we conclude that the ACP would not significantly affect public safety.”

And finally, in one of the most outrageous passages in the DEIS:

  • “Yogaville is located over 4 miles from  the ACP and, therefore, we conclude no direct or indirect impacts on tourism to Yogaville would result from construction and operation of the projects.”  (Note: Yogaville’s property line is only 150-yards from the ACP route, not 4 miles.  Further, the Ashram at Yogaville would be only six-tenths of a mile from the ACP.  The FERC staff is obviously geographically and geometrically challenged.)
DEIS for the Atlantic Coast Pipeline: Sorry, Shallow and Incomplete