The proposed ACP will cross the greatest concentration of high-integrity forest and ecological core areas in both Virginia and West Virginia. (1) Concerns about increasing fragmentation of these forest areas and damage to ongoing restoration efforts were raised in scoping comments submitted by the DPMC to FERC in April 2015. (2)

One of our major concerns is the impact on the Red Spruce Ecosystem Restoration effort. The largest contiguous Red Spruce Restoration Area is the Cheat Mountain-Upper Greenbrier watershed area in the Monongahela National Forest. Dominion’s “preferred route” for the ACP would bisect this area, increase and maintain fragmentation of the remaining red spruce ecosystem, diminish the prospects for recovery, and impact multiple plant and animal species of conservation concern associated with the red spruce ecosystem. The significance of the remnant red spruce ecosystem is widely recognized. It contains some of the highest concentrations of globally rare plant and animal species within the northeastern states. (3) Pipeline construction through this area would severely damage a remarkably successful ecosystem restoration initiative undertaken in recent years by state and federal resource management agencies, conservation organizations, and citizen volunteers. (4)

Dominion’s Resource Report 3 (9/18/15) included this statement:

In routing the AP‐1 mainline, we focused on avoiding areas of high red spruce cover. . . .We understand the concern that a permanent pipeline easement maintained in an herbaceous state would not allow a contiguous forested landscape as the restoration area matures. . . . We are supportive of MNF’s restoration efforts of the red spruce to provide suitable habitat to support rare species like the northern flying squirrel and the Cheat Mountain salamander, and believe we can have a significant positive influence on the MNF’s planned restoration activities (e.g., expanding restoration efforts outside of the project area, and post construction monitoring of restoration areas) in this area. (5)

U.S. Forest Service comments on ACP route variations (12/11/15) included this statement: 

Although the proposed route would avoid most areas mapped as currently containing medium or high red spruce cover, the route passes between and very close to existing areas of mature, relatively unfragmented red spruce forest. Some of the areas that would be impacted by the route contain relatively mature northern hardwoods that have spruce regenerating in the understory. The impacted areas have excellent potential for spruce restoration, and they are a high priority for ongoing and future restoration efforts that are intended to lessen existing fragmentation and re-connect existing mature spruce forest. . . . Constructing a pipeline through the area would make the existing fragmentation permanent, and would exacerbate it by cutting completely across the Cheat Mountain ecosystem from west to east. . . . Off-site compensatory mitigation may have the potential to improve red spruce ecosystems elsewhere, but it would not address the increase in fragmentation across the core of the largest red spruce ecosystem in the central Appalachians. The fragmentation issue goes beyond the needs of individual species . . .  it is an issue of overall integrity and resiliency of the landscape and its ability to adapt to future changes. The central Appalachians contain the last relatively unfragmented large forest blocks in the mid-Atlantic states. The effects analysis needs to quantify landscape-level changes in connectivity, species flow, and potential adaptation to climate change within large forest blocks like the Cheat Mountain area and the Upper Greenbrier watershed. (6)

U.S. Fish and Wildlife Service comments on potential ACP impacts on federally listed species and their habitats (1/7/16) included this statement:

. . . Cheat Mountain contains many sensitive habitats and is one of the most biodiverse areas in the state for many species . . . . Cheat Mountain also hosts one of the largest populations of red spruce in West Virginia. The Service, along with the U.S. Forest Service, Trout Unlimited, The Nature Conservancy, and other non-profit partners working through CASRI [Central Appalachian Spruce Restoration Initiative], have all focused habitat restoration efforts on Cheat Mountain for many years in an effort to increase habitat connectivity and quality and reduce fragmentation of the spruce/hardwood habitat that exists on Cheat Mountain to benefit a wealth of species. The preferred route of the proposed [ACP] project . . . will result in a permanently maintained [right-of-way] through the restoration area. This will adversely affect the restored area and prevent any future habitat connectivity for the CMS [Cheat Mountain Salamander] and other rare species that inhabit Cheat Mountain. The money and effort that the CASRI partners have expended to restore this area will be negated. . . . the [WV Field Office of the Fish and Wildlife Service] highly recommends avoiding Cheat Mountain and the sensitive habitats that exist there. The fragmentation of forested habitat will adversely impact many rare and imperiled species as well as their habitats, which partnering agencies have worked hard to preserve and restore for many years. (7)


  1. M. Dougherty and E. Byers. 2008. Preliminary Calculation of Landscape Integrity in West Virginia Based on Distance from Weighted Disturbances, Technical Support and Wildlife Diversity Units, Wildlife Resources Section, West Virginia Division of Natural Resources, Elkins, WV.;  Natural Heritage Program, Virginia Department of Conservation and Recreation. 2007. Virginia Natural Landscape Assessment.
  2. Webb, R. 2015. Dominion Pipeline Monitoring Coalition Scoping Comments.
  3. E.A. Byers, J.P. Vanderhorst, and B.P. Streets. 2010. Classification and Conservation Assessment of Upland Red Spruce Communities in West Virginia. West Virginia Natural Heritage Program, West Virginia Division of Natural Resources, Elkins, WV.
  4. The Central Appalachian Spruce Restoration Initiative is a partnership of diverse interest with a common goal of restoring historic red spruce-northern hardwood ecosystems across the high elevation landscapes of the central Appalachian region. See
  5. Resource Report 3:  Fish, Wildlife, and Vegetation. 2015. Atlantic Coast Pipeline, LLC and Dominion Transmission, Inc.
  6. USDA Forest Service. 2015. Comments on Route Variations Affecting National Forest System Lands, Atlantic Coast Pipeline, LLC.
  7. US Fish and Wildlife Service. 2016. Comments on Dominion Transmission, Inc., Atlantic Coast Pipeline Project.