Observations Concerning Pipelines and Water Resources
The following general observations assume that the Columbia Gas of Virginia (CGV) project in the Jefferson National Forest (JNF) is a typical example of pipeline construction in steep mountain landscape:
- As documented in the public record, regulatory oversight is minimal and cannot be relied on to ensure compliance with fundamental erosion and sediment control (ESC) requirements.
- The Virginia Department of Environmental Quality (VADEQ) evidently has neither the mandate nor the staff resources to conduct routine compliance inspections of pipeline construction projects.
- The Forest Service does not have the experience, staff resources, or protocol to support review and oversight of pipeline construction projects.
- Pipeline construction companies cannot be relied on to properly self inspect and self enforce strict compliance with fundamental erosion and sediment control requirements.
- Pipeline construction companies request, and the VADEQ grants, variances to critical open-trench limits in even the most extreme mountainside conditions.
- Pipeline construction companies are unlikely to be subject to meaningful penalties or construction delays for noncompliance with ESC requirements.
Implications for Proposed Pipeline Development
This case study is based on a project that is small by comparison to the Atlantic Coast Pipeline (ACP) and the other 42-inch pipelines proposed to cross the central Appalachian mountains. The potential for water resource problems will be greatly multiplied for the proposed larger projects, both in terms of severity and geographic extent.
- The CGV project crossed only one steep mountain; the ACP project will cross twenty or more steep mountains.
- The CGV project was co-located within an existing pipeline corridor; the ACP project will require clearing and excavation of a completely new corridor.
- The CGV construction corridor was 75 to 125-feet wide; the ACP construction corridor will be at least 125-feet wide.
- The permanently cleared corridor for the CGV project is 40-feet wide; the permanently cleared corridor for the ACP will be 75-feet wide.
- The excavated pipeline trench for the CGV project was 6-feet deep and 6-feet wide; the excavated pipeline trench for the ACP project will be 8 to 12-feet deep and and 21-feet wide.
- The CGV project within the JNF crossed no large streams; the ACP will cross a series of high-quality streams and rivers.
- The CGV project within the JNF crossed no major public water supply recharge areas or karst systems; the ACP will cross multiple municipal and private water supply recharge areas and karst systems.
This case study focused on regulatory failures associated with 0.8 miles of national forest. Whether these failures result from a lack of agency resources, a lack of established process, or a lack of political will, there is little reason to expect better results when the same agencies deal with multiple projects on a vastly greater scale. The VADEQ and the Forest Service will be faced with a job that vastly exceeds their current capabilities.
- The ACP will cross approximately 180 miles of mountain landscape, including about 120 miles of mountain landscape in Virginia.
- The ACP will cross 30 or more miles of national forest.
- The Forest Service has insufficient staff and no established protocol in place for review and inspection of pipeline construction projects.
- The VADEQ has insufficient staff and no clear mandate in place for review and inspection of pipeline construction projects.
- The Forest Service and the VADEQ cannot be relied upon to ensure that pipeline construction will comply with ESC and storm water management requirements.