If permitted, both the ACP and the MVP will cross steep-sided, highly erodible and landslide-prone mountains, sensitive and complex karst hydrology, high-integrity forests, and high-quality streams and wetlands. The scale of the projects and the risks are unprecedented. Yet the companies propose to wait until after completion of environmental review, until after permitting, and until after initiation of construction to identify engineering solutions for a range of significant geohazard and water problems confronting the pipelines. This amounts to gaming the regulatory system, it will not provide the regulatory agencies with the information needed for permitting decisions, and it is non-compliant with the National Environmental Policy Act. Even so, FERC, the Army Corps of Engineers, and the Virginia DEQ seem willing to play along.

In contrast, the U.S. Forest Service is asking for site-specific mitigation details for selected high-hazard locations on or near National Forest lands along the proposed pipeline corridors.

In October 24th and 25th submissions to FERC, the Forest Service identified subsets of high-hazard locations selected to represent worst-case scenarios for analysis and design, noting that: “Similar hazards on other smaller pipeline projects in the central Appalachians have led to slope failures, erosion and sedimentation incidents, and damage to aquatic resources.” For these selected locations, the Forest Service requested site-specific designs that illustrate the hazards, the specific techniques that will be used to minimize the hazards, and documentation for the effectiveness of the proposed techniques. The Forest Service further indicated that the selected locations are merely representative sites selected to demonstrate whether stability can be maintained for the purpose of making a preliminary determination of Forest Plan consistency, and that additional high-hazard locations may need to be addressed on a site-specific basis.

Big Ridge – Allegheny Mountain

This ridge in the George Washington National Forest in Virginia’s Highland County is among the high-hazard areas identified by the Forest Service in its request for site-specific project plans. The proposed ACP corridor would follow the narrow ridge crest, requiring extensive excavation for the 125-foot construction corridor and multiple access roads. The streams on either side of the ridge support native brook trout.

**************************************************************************
The DPMC has initiated a Critical Zone Mapping project to extend the identification and analysis of high-hazard areas beyond the National Forests. A team of experts has convened to evaluate erosion and runoff control issues, slope-failure potential, other geohazards, and water resource problems associated with the proposed ACP corridor, access roads, stream crossings, and staging areas.

**************************************************************************
MORE INFO:

US Forest Service information requests submitted to FERC
Request for ACP design details, 10/24/16
Request for MVP design details, 10/25/16

The Forest Service submissions to FERC referenced slope failures on pipelines in W.Va. In 2014 Dominion was cited for water violations associated with 14 slope failures on its G-150 project.
W.Va. Department. of Environmental Protection Consent Order

Submission to FERC on hazards of pipeline construction on steep slopes
Peggy Quarles letter, 10/31/16

Lessons Learned from Constructing Pipelines in West Virginia.
Mitigation of Land Movement in Steep and Rugged Terrain for Pipeline Projects, Golder Associates, Inc. 2016

Forest Service Questions ‘Best-in-Class’ Measures
The Recorder, 10/27/16