The March, 2018, issue of The Highlands Voice described the Pipeline Compliance Surveillance Initiative (CSI), developed by the Allegheny-Blue Ridge Alliance and member organizations.  The idea is to monitor the construction of the proposed Atlantic Coast Pipeline (ACP).

Now the Compliance Surveillance Initiative (CSI) has begun its work.  On surveillance flights on March 5 and March 11 it observed and photographed what it believes to be a violation.  Dominion proposes to drill through the Blue Ridge Mountains.  The CSI has taken aerial photographs of apparent unauthorized construction work where Dominion Energy proposes to drill.

Dominion is operating under a Notice to Proceed issued by the Federal Energy Regulatory Commission (FERC).  It authorized was tree cutting by non-mechanized means.  It did not authorize earth disturbance and construction. Now it appears road construction and equipment staging area construction have been done, which was not described in the project descriptions in the permit applications to those agencies.

Dominion says that it was not doing earth disturbance and construction. Rather, it says, it was doing a geotechnical survey.  This is difficult to square with previous interactions.  Over a year ago pipeline opponents had objected to pipeline approval because inadequate geotechnical study of the proposed drilling.  At that time, Dominion responded that geotechnical investigation had been “fully accomplished.”

Requests for investigation and clarification were submitted to Federal Energy Regulatory Commission and the Virginia Department of Environmental Quality.

A little background

Dominion intends to drill 4,639 feet through the Blue Ridge under the George Washington National Forest, Appalachian National Scenic Trail, and Blue Ridge Parkway. Dominion’s plans call for use of horizontal directional drilling (HDD) and contingency use of direct pipe installation (DPI) if the HDD operation fails. Given the topographic and geophysical challenges at the site, the Forest Service initially conditioned any authorization for ACP construction on prior successful completion of the proposed HDD or DPI operations. This condition would have avoided a situation in which significant investment associated with premature ACP construction would be put at risk and in direct conflict with established legal protection of highly valued public resources. Should the HDD and DPI prove impracticable after ACP construction is underway, there will be a strong incentive for allowing an open-cut crossing of the Appalachian Trail and the Blue Ridge Parkway.

The Dominion Pipeline Monitoring Coalition published a report in early 2017 describing both the risk of failure and the unavoidable environmental damage associated with the plans for drilling through the Blue Ridge. This report described the risk factors confronting both the HDD and contingency DPI operations. Although detailed geophysical investigation of the drill path is standard practice for assessing the feasibility of prospective HDD and DPI operations, the information considered during environmental review was limited in both scope and reliability. No subsurface borings were completed at or near the HDD endpoints and geophysical survey data were obtained for less than 25% of the drill path.  To see the report, go to http://pipelineupdate.org/environmental-review/ and click on A High Risk Proposal.