The Virginia Outdoors Foundation (VOF) wrote the Federal Energy Regulatory Commission (FERC) on March 10 reiterating its concerns over the proposed crossing of 10 conservation easements held by the VOF, but also setting forth several recommended conditions that should be imposed should the Atlantic Coast Pipeline be approved by FERC. The VOF letter, noting that the FERC Draft Environmental Impact Statement referred to the proposed easement conversions as “minor,” commented:
The VOF has consistently taken the position that construction, maintenance and operation of the interstate gas transmission line is inconsistent with the open space protections afforded by the subject easements. Therefore, the construction, operation and maintenance of the ACP will constitute a conversion of the easement property as outlined in Va. Code § 10.1-1704. VOF has stated on many previous occasions that the impact is very significant and by no means “minor”.