Editor’s note: The following column is an open letter sent by the Friends of Nelson County to Kimberly D. Bose, secretary of the Federal Energy Regulatory Commission.

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A recent public presentation on the potential for hazardous landslides in the mountainous areas of Nelson County VA highlighted longstanding concerns about the dangers of routing the Atlantic Coast Pipeline (ACP) through the county’s steep terrain. In this letter, we call your attention to the potential for catastrophic slope failures if ACP overcomes its numerous legal challenges and begins construction. We ask you to consider the following information and its implications for your handling of the Atlantic Coast Pipeline.

At a public meeting on June 30, geologist Dr. Anne Witt, geohazards specialist with the Virginia Department of Mines, Minerals and Energy (DMME), presented her analysis of the landslides triggered in Nelson County by Hurricane Camille in 1969. In that horrific storm event, 125 people are known to have lost their lives as landslides triggered by severe rainfall swept down valleys in the middle of the night carrying whole families to their deaths.

The information Dr. Witt presented stems from her ongoing research assessing the landslide potential of steep slopes in Nelson and western Albemarle counties. Her work will contribute to a new Virginia Hazard Mitigation Plan being prepared with support from FEMA and the Virginia Department of Emergency Management. Using LIDAR (Light Detecting and Ranging) technology to map the bare earth beneath vegetative cover, she unveiled a multitude of historical slides on Nelson’s steep slopes. Noting that previous slides are strong indicators of potential future slides, she concluded that Nelson County’s steep slopes have greater landslide potential than had previously been recognized.

Dr. Witt’s presentation sharpened the concerns raised by a 2017 study of soil and geologic concerns commissioned by Friends of Nelson and Friends of Wintergreen. The final report by Blackburn Consulting Services, LLC — “Report Analysis and Field Verification of Soil and Geologic concerns with the Atlantic Coast Pipeline (ACP) in Nelson County, VA” — was submitted as part of FERC’s EIS review for issuance of the ACP permit. We strongly believe the Blackburn report was not given sufficient consideration in the Commission’s decision.

Blackburn scientists reviewed the material Dominion submitted to FERC and conducted field analyses of actual conditions in a sample of sites where the pipeline would traverse steep slopes in Nelson County. In their report, Blackburn concluded that: “…many of the statements made in the materials submitted to FERC represented gross generalities … [and] … underestimate the true risks that this project imposes on Nelson County and its residents.”

Key findings of the Blackburn study include:

» Landform and soil characteristics: “The Appalachian Mountains of the Eastern United States have long been recognized as uniquely susceptible to debris flows.” Steeply sloping, concave, colluvial landscapes like those found in Nelson County are the predominant source of landslides. Evidence of many past slides shows high potential for future slides.

» Mapping soil conditions: Dominion used regional-scale soil maps to guide their route selection, but the scale of these maps is too gross for selecting a least-impact route for the pipeline. They were never intended for siting a major infrastructure project.

» Vegetation: Trees are key to holding steep slopes in place during heavy rains, and removing their roots and trenching greatly increases the chances of landslides. Likely difficulties revegetating, acknowledged by Dominion, would lead to erosion and sedimentation immediately and for many years in the future.

» Soil stabilization and erosion control: Site-specific studies of landslide potential must be done to provide a solid basis for control measures. “In Dominion’s fillings it is commonly indicated that they will address these concerns during the construction process. We recommend that these additional examinations be performed — and that appropriate, site-specific stabilization plans be developed and made available for stakeholder comment — before the pipeline is approved by FERC.”

» Expansion of the corridor: Conducting more detailed topographic analyses, site-specific soil analyses and mapping historical debris flows on the 125’ ROW “… simply is not enough …” because vulnerable sites may adjoin the corridor’s boundaries and clearing/trenching activities may trigger problems well beyond the 125’ boundaries. “We believe an additional analysis of a minimum of a 200-foot buffer on both sides of any proposed limits of impact is required.”

The permit the commission issued ACP constitutes a recipe for disaster. Dominion’s “best in class” erosion and sedimentation control measures have failed repeatedly in the work they have already done in West Virginia. Similar stabilization measures employed by the Mountain Valley Pipeline builders have led to over 300 violations, legal action by the Virginia Attorney General, and events like sections of pipe carried great distances by floodwaters. MVP is demonstrating what will likely happen if and when ACP begins construction on Virginia’s steep slopes.

Dominion assures concerned citizens that the ACP will be safe. However, according to the Pipeline and Hazardous Materials Safety Administration, 11,993 pipeline failures have been reported in the U.S. over the past two decades. In January 2018, at the dedication of the 36-inch Leach XPress pipeline near Wheeling West Virginia, the president of TransCanada said “This is truly a best-in-class pipeline, and we look forward to many years of safe, reliable and efficient transmission on behalf of our customers.” Six months after those words were uttered, the pipeline ruptured and exploded due to land subsidence. For these reasons, we are wary of pipeline companies’ promises, especially as regards steep slopes.

At present, two federal permits for the ACP have been vacated. Another three federal permits, as well as two state permits, are in the courts or being challenged. The outcomes of these trials are uncertain. At the same time, renewable energy generation and storage are emerging as fully competitive with coal and natural gas on a levelized cost basis; other regional pipelines have been built or re-engineered and can provide needed gas at lower cost than the ACP; the State Corporation Commission recently has forced Dominion to revise its inflated projections of future energy demand; and scientists have shown that fracking, transporting and burning gas contributes as much to the buildup of climate-changing greenhouse gasses as coal.

The International Panel on Climate Change’s recent report on climate change — which was soon supported by a report from an interagency panel of U.S. government scientists — made it alarmingly clear that we must quickly shift away from fossil fuels. The new energy economy is rapidly emerging, and the ACP would be a major impediment to that necessary emergence. As former FERC commissioner Norman Bay warned, overbuilding pipelines would likely result in these unnecessary projects becoming “stranded assets” that profit their builders and stockholders at the cost of captive customers and future generations.

We call on FERC commissioners to bring a halt to this unnecessary and dangerous project.

Kimble is president of Friends of Nelson County; Wellman is vice president of the organization.

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