The Dominion Pipeline Monitoring Coalition has just published an interactive Critical Zone Mapping System (CZMS) in support of citizen efforts to overcome the continuing failure of the regulatory system. Dominion Energy, with the cooperation of state and federal government, has effectively managed the regulatory process to ensure that essential details and limitations of its plans to avoid environmental harm associated with the Atlantic Coast Pipeline (ACP) are withheld from the public and excluded from the set of facts considered by the regulatory decision makers.
The pattern is well established. The Federal Energy Regulatory Commission, the U.S. Forest Service, and the state environmental agencies have all adopted a deferred-analysis approach to the ACP that delays review of detailed site-specific stream crossing plans, erosion and runoff control plans, and steep slope stabilization plans until after project approval. All rely on future completion of Dominion’s Construction and Operation Plan and so-called Best in Class (BIC) program. All are moving toward project approval without critical information required for objective decision making.
The CZMS addresses this regulatory system failure by providing a framework for evaluation of the risk associated with construction of the ACP and the limitations of the proposed or available control measures. The CZMS includes user-selectable map layers that display a number of the key factors that should be considered during project review and prior to project approval. Among these are layers that indicate slope steepness, soil erodibility, high-excavation areas, stream crossings, surficial karst, and existing dye traces in karst systems.
One of the more-critical map layers identifies those sections of the pipeline corridor and access road system that meet Dominion’s criteria for application of its BIC program. These areas, where the existing ground slope is 30% or more for distances of 100 feet or more, present the greatest risks to downslope water resources due to erosion, slope destabilization, and runoff alteration. Although Dominion has provided what it describes as detailed erosion and runoff control plans, the plans do not include site-specific BIC measures. With very limited exceptions, the actual site-specific details for BIC measures have not been provided to the regulatory agencies and apparently will not be provided until after project approval.