Have you seen a more beautiful bee? This amazing bee, known as the rusty patched bumble bee (RPB) is unfortunately federally endangered. On October 15, 2018, Wild Virginia’s David Sligh filed public comment to express concerns about how this bee will be effected by the Forest Service’s Duncan Knob Gypsy Moth Proposal. These comments raise important concerns about how this project will impact the bees and the need to further study these effects before the project moves forward. Read the full comments here and continue reading below to learn about the background and main points of our latest comments.
Background on the Duncan Knob Gypsy Moth Proposal
The forest service originally filed the Duncan Knob Gypsy Moth Proposal in May of 2017, which has been met with various concerns. Wild Virginia filed comment in July 2018. The Forest Service originally proposed the project to mitigate the effects of an infestation of gypsy moths on National Forest Service Land comprising part of Duncan Knob. The Forest Service’s stated goal with the project is to promote oak regeneration and salvage trees effected by the gypsy moth. In Wild Virginia’s comments from July we argued that “the benefits of cancelling this project far outweigh the costs of implementing it,” citing concerns with interfering with the health of the forest through implementing the proposal of removing the gypsy moths.
Rusty Patch Bumble Bee found on private land near Duncan Knob
Rusty Patch Bumblebee Concerns
Wild Virginia’s main concerns with the rusty patched bumble bee and this project revolve around the use of a categorical exclusion instead of an environmental assessment. As will be discussed below, there are large potential impacts of this project on this endangered species, so the Forest Service must conduct an environmental assessment if it chooses to continue with the project in order to stay in accordance with the National Environmental Policy Act. The categorical exclusion simply does not go far enough to assess the impacts this project could have on this endangered bee.
With regard to rusty patched bumble bees and this project the first question one must answer is whether or not these bees actually live in this area. The U.S. Fish and Wildlife Service admits that there is uncertainty and many unknowns about the habitat and range of the Rusty Patched Bumble Bee. This alone raises concerns about this endangered species. Why implement a project in an area where there are still questions about the presence of an endangered species? However, the U.S. Fish and Wildlife Service in relation to the Atlantic Coast Pipeline (ACP) identified a High Potential Zone (HPZ) in which the rusty patched bumble bee may be found. One must pay special attention to this because a number of areas of the Duncan Knob Gypsy Moth project fall in the HPZ. This means there is evidence that habitats and populations of the bee will be affected by the project.
Activities proposed for the ACP overlap with those proposed for this project, so analysis around concerns for the rusty patch with the ACP can be applied to this project. These detrimental activities include the clearing of the bees’ foraging habitat and human disturbances, which may harm or kill the rusty patch. Clearly there are uncertainties and concerns about harm so an environmental assessment is necessary to determine how this project will affect the bee before moving forward.
On September 13, 2018, the United States Forest Service published two advanced notices of proposed rulemakings (referred to as ANPRMs). The notices aim to streamline regulations regarding the exploration and development of oil, gas, and locatable minerals in national forests and grasslands. Locatable minerals are recognized as a mineral by the scientific community and make the the land more valuable for mining than for agriculture. Examples include gold, silver, limestone and copper.
A 30-day public comment period regarding the implementation of existing regulations and these new proposed rules ends October 15.
The two proposals, 36 CFR 228 Subpart A: Locatable Minerals, and 36 CFR 228 Subpart E: Oil and Gas Resources, are trying to expedite the Forest Service review process of projects in order to speed up development and benefit those who are trying to develop land instead of those who are trying to protect it. Speeding up the review process hurts the quality of environmental reviews and the ability of the public to submit comments. Activities related to excavating locatable minerals, oil or gas require a thorough environmental review.
In recent years, the Forest Service has experienced issues with staffing and funding because they have diverted so much of their budget to fighting wildfires. Thus, it is extremely important for experts and citizens to have appropriate time to weigh in on potential Forest Service projects.
What you can do:
The Forest Service must not be allowed to abdicate its responsibility of protecting our national forests and grasslands. Please make a public comment today to ensure our wild areas are given priority over energy developers.
For comments regarding locatable minerals:
Electronically: Go to the Federal eRulemaking Portal: http://www.regulations.gov. In the Search box, enter FS-2018-0052, which is the docket number for this Advanced Notice of Proposed Rulemaking. In the Search panel on the left side of the screen, under the Document Type heading, click on the Notice link to locate this document. You may submit a comment by clicking on “Comment Now!”
By hard copy: Submit by U.S. mail to: USDA-Forest Service. Attn: Director—MGM Staff, 1617 Cole Boulevard, Building 17, Lakewood, CO 80401.
For comments regarding oil and gas:
Electronically: Go to the Federal eRulemaking Portal: http://www.regulations.gov/. In the Search box, enter FS-2018-0053 which is the docket number for this Advance Notice of Proposed Rulemaking. In the Search panel on the left side of the screen, under the Document Type heading, click on the Notice link to locate this document. You may submit a comment by clicking on “Comment Now!”
Mail: Address written comments to USDA-Forest Service. Attn: Director-MGM Staff, 1617 Cole Boulevard, Building 17, Lakewood, CO 80401.
There is still timefor you to tell the Virginia Air Pollution Control Board to deny Dominion’s application for a permit to release air pollution that will threaten the health and well-being of residents in the Union Hill neighborhood and beyond. The public comment period has been extended to September 21, 2018, so don’t wait – let your voice be heard.
Buckingham Compressor Station for the
Atlantic Coast Pipeline Air Quality Permit
Public Comment Period Ends 9/21/18
Submit your comments to:
DEQ, Piedmont Regional Office
Re: Buckingham Compressor Station
The draft permit prepared by the Department of Environmental Quality (DEQ) is woefully deficient, failing to provide the analyses and the levels of protection the law requires.
Dozens of people spoke at a public hearing on September 11th, most explaining technical and legal problems with the proposal and opposing issuance of the permit. Please add your voice to that strong message, to let the citizen members of the Air Board know you oppose this illegal and unethical proposal to victimize citizens for private profit.
What to say?
Even if you lack technical expertise, you can raise important issues the Board is legally-obligated to consider.
The Atlantic Coast Pipeline (ACP) is not needed to supply energy to the areas Dominion claims would be served and
DEQ has failed to properly consider whether the placement of the facility is appropriate or to acknowledge the violation of environmental justice principles.
DEQ officials have stated that the Department and the Board lack authority to consider issues related to the need for the project and proper siting of the station. State law explicitly contradicts this position. The State of Virginia not only has that authority, it has a solemn obligation to exercise it.
The Air Board, in approving permits, “shall consider facts and circumstances relevant to the reasonableness of the activity involved,” including:
The character and degree of injury to, or interference with, safety, health, or the reasonable use of property which is caused or threatened to be caused;
The social and economic value of the activity involved;
The suitability of the activity to the area in which it is located; and
The scientific and economic practicality of reducing or eliminating the discharge resulting from such activity. Code of Virginia § 10.1-1307.E.
No Need for the Pipeline and Compressor Station
A mountain of evidence proves that Dominion’s claims about the need for gas to be supplied by ACP are untrue. Importantly for this permit review, DEQ has refused to acknowledge this information or to incorporate it into its analysis of Dominion’s application for the air permit.
This deficiency is directly pertinent to the “reasonableness of the activity involved” and the “social and economic value of the activity involved,” which the Air Board must consider. Code of Virginia § 10.1-1307.E. Weighing against the lack of need for the project are the social and economic costs that will be imposed on the communities directly affected by the compressor station.
Unfair Targeting of Communities of Color and Impacts to Vulnerable Populations
The disproportionate impacts the compressor station would have on the African American community in and around Union Hill are clearly shown. The Federal Energy Regulatory Commission (FERC) relied on incorrect and incomplete information about the local community to dismiss environmental justice and siting concerns. The Air Board must demand that DEQ provide and analyze correct data on these issues and must reject this permit unless and until the Department does so.
The Air Board is required to consider these facts in an analysis of the “character and degree of injury to, or interference with, safety, health, or the reasonable use of property which is caused or threatened to be caused” and the “suitability of the activity to the area in which it is located.” Code of Virginia § 10.1-1307.E. The Board must reject the draft permit prepared by DEQ and require that all pertinent siting considerations be investigated and analyzed before it considers the proposal further.
FERC relied on incorrect data from Dominion to conclude in its final environmental impact statement on the ACP that, on average, there are 29.6 people per square mile in the area surrounding the pipeline’s path in Buckingham—that number was provided by the U.S. Census Bureau. However, a survey of the community by Friends of Buckingham showed that FERC’s number was off by about 500 percent.
“Members of the anti-pipeline group Friends of Buckingham went door-to-door to survey the Union Hill area. They spoke with 64 percent of the people living in the 99 households within that square mile, and of those 158 residents, 85 percent are African American.”
“The FERC report didn’t mention Union Hill, where a third of the residents are descendants of the freedmen community that was once enslaved there, and where there are freedmen cemeteries and unmarked slave burials on the site where Dominion wants to build its compressor station, according to Yogaville resident and cultural anthropologist Lakshmi Fjord.”
DEQ has also failed to account for the fact that these areas have unusually large percentages of elderly people and children, both of which are especially sensitive to the kinds of air pollutants the compressor station would emit.
Recently, Governor Northam’s Advisory Council on Environmental Justice (ACEJ) found evidence thatACP would have “disproportionate impacts for people of color and for low-income populations due to gas infrastructure expansion.”
Are the Atlantic Coast Pipeline and the Mountain Valley Pipeline Necessary?, Synapse Energy Economics, Inc., September 12, 2016. (“The region’s anticipated natural gas supply on existing and upgraded infrastructure is sufficient to meet maximum natural gas demand from 2017 through 2030. Additional interstate natural gas pipelines, like the Atlantic Coast Pipeline and the Mountain Valley Pipeline, are not needed to keep the lights on.”)
Natural Gas Industry Admits New Pipelines Aren’t Needed, Natural Resources Defense Council, February 5, 2018. (“a spokesman for Williams, owner of the Transco pipeline, a would-be competitor of ACP, indicated ‘the infrastructure is in place right now to meet the current demand.’”)
“Is the deer crossing the road, or is the road crossing the forest?” – Freequill
Αn insurance company analyst, Master Naturalist, Department of Transportation employee, and conservation biologist walk into a bar. What do they have in common?
Now that I have your attention, it was not a bar, but, rather, the meeting room of a public library — and, on July 17, I found myself in that very room.The four were gathered as part of the Virginia Safe Wildlife Corridors Collaborative (VSWCC) — a nascent group formed to reduce animal-vehicle collisions on roads and provide safe passages for wildlife. Bringing together groups like the Virginia Department of Transportation (VDOT), the Virginia Department of Conservation and Recreation, the Highway Loss Data Institute, and conservation groups like the Wildlands Network and Wild Virginia, VSWCC takes a multi-stakeholder approach to a complex, multi-disciplinary issue in road ecology.
Who is the Collaborative?
The Collaborative includes an analyst from Highway Loss Data Institute, who provides insurance companies with crash data; a conservation biologist from William & Mary, who does GIS mapping of animal habitat near interstates; a veterinarian from the Wildlife Center, which cleans up the carnage from crashes; an employee of VDOT — who researches animal passageways and measures to mitigate wildlife crashes; and Wild Virginia Director Misty Boos. Also involved are members of the Virginia Department of Game and Inland Fisheries, which releases statewide Wildlife Action Plans to determine the species of greatest conservation need in Virginia; the coordinator of the Virginia Master Naturalists Program, which provides training in ecology, animal and plant identification, and the scientific method; and a member of the Wildlands Network, which works to promote habitat connectivity, the Collaborative’s bigger-picture goal.
In the modern age, animal core habitats have become increasingly fragmented. Due to human construction, land mammals move two to three times less than they used to, which means a limited ability to mate, feed, and migrate. Coupled with the fact that fragmentation reduces species richness and nutrient cycling, and climate change forces relocation, the threat of species extinction looms more ominously.
As stated on the Wildlands Network website: “Connecting wildlife habitats is critical to conserving biodiversity in the face of climate change, which will increasingly trigger geographical shifts for wildlife populations, plant communities, and ecological processes.”
The Wildlands Network spearheaded the Eastern Wildway Initiative, which seeks to create a continuous unobstructed stretch of wildlife habitat along the East Coast, from Quebec to the Gulf of Mexico. This wildway would contain some of the country’s most beloved wild places, from the Adirondacks to the Shenandoah Valley to the Great Smoky Mountains and Everglades National Park. The region harbors a wide range of climates, eco-regions and enormous biodiversity–in fact, the southeastern U.S. is one of the world’s biodiversity hotspots. Wild Virginia is working to contribute to the Eastern Wildway as they work to improve habitat connectivity in Virginia.
Large Animal Crashes
The group’s primary concern is human safety, which is threatened by vehicle crashes with large animals like deer and bear. VDOT tracks bear and deer carcass data, and VDOT’s Bridget Donaldson has used this data to pinpoint hotspots for deer and bear crossings. According to Donaldson, deer make up1 in 6 animal-vehicle collisions in Virginia, which puts the state in the top ten for deer-vehicle collisions nationally.
VDOT has begun building fencing to funnel animals into existing underpasses beneath large highways. On Interstate 64, 8 foot-high fencing now guides animals to a box culvert beneath the roadway and a bridge spanning a river. Cameras installed at the site show animals coming up to the fence, and turning around to find another way around, rather than crossing the interstate. It’s estimated that this is reducing crashes at a cost savings of$300,000 per stretch of fencing. The fencing includes jump outs: sections of fencing angled at the top to allow deer to pass one way — out of the road — but not the other. Recently, VSWCC has installed cameras in Buffalo Creek and Cedar Creek, which will be continuously monitored during November, deer breeding season.
At this point, you might be asking: why did the bear cross the road? But, in all seriousness, what is the biological impetus for large animals moving around so much? When mating, large-scale movement is crucial for genetic exchange and enhancing genetic diversity. Otherwise, inbreeding within the same area can hurt a species, reducing the biological fitness of a population.
Animals are naturally accustomed to moving around not only when mating, but when searching for food. Bear, whose food is scarce during winter months, must eat large amounts of food during the summer to survive, so they move constantly move to find it.
In the effort to reduce large-animal collisions, the Collaborative hopes Virginia will follow in the footsteps of other admirable states. In Montana, a56-mile stretch of highway boasts 41 overpasses and underpasses for animals like deer, bear, coyotes, and bobcats. In Wyoming, underpasses for moose and elk andoverpass bridges for pronghorn have reduced collisions tremendously. In Southern California, biologists have erected underpasses for thethreatened desert tortoise, which long-tailed weasels and foxes have also benefited from. In Washington, squirrels cross over a major road on anarrow rope bridge between trees.
Outside of the U.S., the Netherlands has over 66 overpasses and ecoducts (wildlife bridges) to protect species like the endangered European badger, wild boar, and various species of deer. The Netherlands also boasts the longest wildlife overpass in the world, ahalf-mile long natural bridge which spans a railway line, park, roadway, and sports complex. In Australia, abridge on Christmas Island helps 50 million red crabs migrate over a busy road.
Small Mammals and Herps
VSWCC also has a Small Mammals and Herps Working Group. One animal the Collaborative focuses on is salamanders, whose core habitat is the vernal pool, a type of wetland generally devoid of fish. When breeding, salamanders must migrate back to their vernal pools, which often means crossing roads. To curtail salamander-vehicle collisions, the Collaborative is looking to use drift fencing to guide salamanders through plastic tubes under interstates. Other states — likeMassachusetts andVermont — have had success with similar projects.
A mass migration of salamanders in Charlottesville has led volunteers toblock off roads to aid their crossing, during which the majority of salamanders normally die. Because of volunteer efforts in February, the development company owning the road (Polo Grounds Road) agreed to construct a salamander tunnel underneath it later this year.
The Small Mammals Work Group is also considering possible efforts toward the eastern spotted skunk (which is very slow) and the northern flying squirrel (whose habitats are often fragmented). It is also looking at ways to improve habitat connectivity diamondback terrapins at sites near the Virginia coast.
Goals for the Future
Moving forward, the group looks to influence public policy by making animal-vehicle collisions a priority for state lawmakers. According to VSWCC, policy must protect both core habitats for animals and the “corridors” that enable safe passage between them.
In 2016, a Virginia congressman introduced theWildlife Corridors Conservation Act to the House of Representatives, which helped bring attention to the issue at the federal level. The Collaborative hopes to introduce a similar bill to the Virginia General Assembly in 2019.
VSWCC also hopes to follow other states’ lead in increasing opportunities for citizen science, creating systems for reporting animal crashes by taking photos, obtaining GPS coordinates, and collecting user data about animal carcasses on roads. The Collaborative’s next meeting is October 15. Hopefully, the Collaborative will soon have opportunities for volunteer involvement. In the meantime, keep your eye out for roadside critters on your daily commute!
On Wednesday, June 11th — a beautiful, sunny morning — at the top of Reddish Knob, I had the rare pleasure of meeting Eric Gilchrist. At 64 years old, Eric has spent the past two months ascending mountains on a mission: climb every peak in the George Washington National Forest (GWNF) over 4,000 feet. Eric’s environmentalism is deeply motivated by his passion for the outdoor spaces by which he is surrounded, which he feels a preservationist instinct to protect. Thus, Eric has dedicated his “peakbagging” project to Wild Virginia, asking friends and family to pledge money, all of which will go toward the organization. Of the 32 peaks in the forest over 4,000 feet, Eric has climbed 13, and raised $1,500 along the way. (You can pledge your donation to support Eric’s peakbagging the GW here.)
Most climbs have elevation gains of between 1,000 and 2,500 feet. Some of his favorite peaks thus far have been Freezeland Flats in Ramsey’s Draft Wilderness and the Switzerland-esque high-mountain meadow of Cole Mountain. Undoubtedly, his least favorite was the poorly-named “Big Knob,” which was only accessible via a road torn up by four-wheel drive vehicles.
Wild Virginia member Ernie Reed and I met Eric at the top of Reddish Knob, one of the highest points in Virginia, and a region steeped in history. Atop Reddish Knob, in 1999, Bill Clinton famously demanded that then-chief of the Forest Service Mike Dombeck craft a policy to protect unroaded areas in our national forests. This gave way to the 2001 Roadless Rule: a groundbreaking policy calling for protection of 58.5 million acres of roadless area within the national forests.
Years ago, Eric and Ernie set out to find the “wildest” place in Virginia: the region that is farthest from a road on all sides, that could be designated as wilderness. What they found was in the heart of Little River Roadless Area, a 27.3 thousand acre region of potential wilderness of which Reddish Knob is a part.
After meeting at Reddish Knob, the three of us peak-bagged Bother Knob, which gave me both a hearty sense of admiration for the fitness of my two hiking companions and a collection of nasty bush-whacking cuts on my bare legs. (That 40 extra years of wisdom Ernie and Eric have on me is really starting to make itself known.)
Talking to Ernie for any brief period of time is like dipping your toes into an unending pool of environmental knowledge, soaking up bits of passion along the way, remembering why you’re outraged and why you care so much. On this trip, it was particularly interesting to pick his brain about the absurdity of fracking policy. (Fracking — drilling into the Earth to extract gas and oil from shale — has had disastrous water quality and human health impacts, but, in 2005, president George Bush’scongress made it exempt from the Clean Water Act, the Safe Water Drinking Act, and the Clean Air Act, in what was famously termed “the Halliburton Loophole!”)
For a snack at the summit, Eric brought us his famous homemade pancakes made from banana, egg, cinnamon, and rolled oats.
Born in Staunton, Eric is a Central Virginia native, but he cites some of his first, most precious memories as exploring the Grand Tetons during his childhood in Idaho. After moving to Western Pennsylvania, Eric attained a B.S. in Man-Environment Relations from Penn State and went on to pursue an MBA there. After a 20-year stint as an account executive for large computer companies in the ‘80s and ‘90s, Eric longed to nurture his environmentalist roots. Upon returning to Central Virginia, Eric began volunteering for various environmental nonprofits. In 2002, he joined the board of the Shenandoah Ecosystems Defense Group, which now holds the catchier, less verbose title: Wild Virginia. On the board in 2002, he met Ernie, now one of his best friends, and the rest is history. After 12 years on the board, Eric resigned in 2014. Aside from Wild Virginia, Eric has done energy efficiency work in Charlottesville and helped found the Local Energy Alliance Program (LEAP), a nonprofit that conducts energy assessments and helps homes convert to solar energy. Eric also helped found Appalachian Sustainable Development, an organization that contracts with loggers to make available sustainable, locally-sourced lumber.
In the past decade, Eric has taken his sustainability to a new level through his latest project: building a completely eco-friendly house. Eric spent five years building an 800 square-foot house made entirely from wood harvested from right off his property, in GWNF. The small, cozy house is designed with a number of features that make it energy-efficient: it has no interior doors or hallways; triple-pane windows; a heavily-insulated roof deck; a metal roof; and the house is oriented toward the south. With windows on the south side, they get solar gain during the winter — heat is stored in thermal mass during day and released into the house in the evening. In the next couple years, Eric hopes to go off the grid. The house boasts a tiny wood stove, cabinets made from local wood, and radiant floor heating heated by a domestic water heater. In essence, this means that Eric’s family gets hot water for bathing and cooking from the same power source that heats the floor. The house’s walls are 12 inches thick, which means more thermal mass, modulating the indoor temperatures more evenly, and for longer periods of time.
Eric hopes to finish peak-bagging in October, after a brief interlude to vacation in Canada in August. What will Eric do next to save the planet? Only time will tell. In the meantime, I hope he cooks many more batches of healthy, homemade pancakes for those hard-working Wild Virginia interns.
Through a Freedom of Information Act request, David Sligh of Wild Virginia and the Dominion Pipeline Monitoring Coalition (DPMC) has acquired almost all of the comments citizens (around 10, 000 of them) submitted to State Water Control Board through the Virginia DEQ. Individuals and conservation groups explain why the Corps of Engineers’ blanket permit is not sufficiently protective of our state waters. DEQ has promised to supply the rest by today.
Wild Virginia and DPMC are currently scouring the comments and will publish our summary of the whole body of information early next week. The vast majority we’ve seen so far are form emails and letters that contain no useful information the Board can use in making a decision whether to take new action. By contrast, the comments by landowners and technical experts contain much detailed, site-specific, and scientifically-based evidence of the dire threats to the thousands of waterbodies MVP and ACP propose to dig and blast through, under a lax Corps approval.
“Once there were brook trout in the streams in the mountains. You could see them standing in the amber current where the white edges of their fins wimpled softly in the flow. They smelled of moss in your hand. Polished and muscular and torsional. On their backs were vermiculate patterns that were maps of the world in its becoming. Maps and mazes. Of a thing which could not be put back. Not be made right again. In the deep glens where they lived all things were older than man and they hummed of mystery.”
-Cormac McCarthy, the Road
Wild Virginia has long advocated for the protection of watersheds home to brook trout populations in George Washington National Forest (GWNF), which provide enormous ecological, cultural and economic benefits.
The state fish of Virginia, West Virginia and Pennsylvania, brook trout are a species of fish native to eastern North America that has thrived in the Appalachian Mountains for millions of years. They inhabit clear, coldwater streams, primarily at high elevations. Brook trout require particularly clean water and cannot thrive in stream temperatures higher than 70 degrees Fahrenheit. A healthy stream can inhabit between 30 and 40 trout families.
Brook trout spawn during the fall, incubate during the winter, and hatch eggs in the early spring. The species prospers in closed-canopy forests, whose shade-cover regulates stream temperature. Since they require pristine habitats with high water quality conditions, an abundance of brook trout is indicative of a biologically robust watershed. For this reason, declining brook trout populations can serve as an early warning that the ecological health of an entire system is at risk.
When regions of forest were heavily clearcut in the early twentieth century, warming occured due to a lack of canopy cover, reducing brook trout populations. Because of their sensitivity to temperature changes, brook trout were largely replaced by rainbow and brown trout during this time. Brook trout populations have since declined extensively, for a variety of reasons (reduced water quality from runoff and acid rain, rising stream temperatures, and the like.)
Brook Trout & Climate Change
Currently, the livelihood of brook trout populations native to GWNF are threatened by anthropogenic climate change. Climate change is a long-term change in the statistics of weather, leading to irregularity in temperature and precipitation patterns. Both air temperature and precipitation are major drivers of stream temperature and flow, which determine population dynamics. For every degree Celsius that air temperature rises, water temperature rises eight tenths of a degree. Thus, the projected 4 degree Celsius rise in air temperature due to climate change would cause a 3.2 degree rise in stream temperatures.
Climate change is especially problematic for trout, because they require cold water habitats, which — due to human activity — are becoming increasingly rare and fragmented. Because of climate change, brook trout are shifting to higher elevation streams, with stream temperatures suitable for survival.
As climate change produces warmer winter temperatures, brook trout’s life cycle will be disrupted, as trout may emerge too early, when there is not sufficient food for survival.
One consequence of climate change for regions of GWNF and Shenandoah National Park (SNP) is high precipitation during the winter and early spring months. Longitudinal studies in SNP have found high winter/early spring precipitation to have strong negative effects on trout abundance, as flooding from extreme precipitation can threaten vulnerable eggs as they hatch. Additionally, high summer air temperatures — which will also increase with climate change — reduce trout abundance, and will force brook trout to either evolve or die off in the next two decades.
Another effect of climate change is acid rain: rainfall made acidic by atmospheric pollution and the burning of fossil fuels. In the Appalachian Mountains, acid rain has impacted between 60 and 80 percent of brook trout spawning habitat.
So, at this point, you may be asking: what can we do to save the trout? According to fishery biologist Ben Letcher, some solutions including putting more shade-producing trees along river banks; adding logs into streams; and limiting the number of wells removing cold spring water from the watershed.
Ultimately, brook trout populations are severely hindered by logging, development, and conversion of forested lands to be used for agriculture. To reverse this trend, it is indispensable that we prioritize increases in canopy cover and late-successional forest habitat in order to stabilize temperatures, continually monitor water quality, reduce sediment loads in streams, and create opportunities for brook trout populations to thrive and expand their habitat.
Over the past year, Wild Virginia asked Virginians affected by the Atlantic Coast Pipeline and the Mountain Valley Pipeline to share their stories on our interactive map. Dozens of Virginians contributed beautiful photos and thoughtful comments, all reflecting a common sentiment: these pipelines will not benefit Virginians.
Trees have been cleared in Virginia for both pipelines. Construction of the Mountain Valley Pipeline is underway. The company continues to accrue violations and public outrage as sediment damages waterways, roads, and property. Most recently, an appeals court granted a stay on an Army Corps permit, temporarily preventing construction across four major rivers and hundreds of associated streams in West Virginia – roughly 80 miles of pipeline.The ruling sets an important precedent: that an Army Corps permit, what the VA State Water Board used to determine that our water was sufficiently protected, is insufficient.
Now, the Virginia State Water Quality Control Board is reconsidering their original clean water certification – whether our water is actually adequately protected from ACP and MVP construction. This means it’s time to get involved!
Construction of the ACP has not begun in Virginia. The pipeline awaits approval of their erosion and sediment control plans from the Virginia State Water Control Board and the Department of Environmental Quality. These approvals may occur any day. This means it’s time to get involved! (There is no time to waste!)
We made a video highlighting some of these stories along the path of the ACP. Please check it out below, and explore and add your own story our map.
What you can do?
Now, we’re asking for more photos and comments to increase the visibility of the destruction both pipelines are already causing. If the MVP or ACP is affecting you, please considering sharing your story with us directly on on the map or on Twitter, Facebook, or Instagram.
Then, sign our petition urging Governor Northam to direct the DEQ to conduct a thorough, fair evaluation of the impact pipeline construction will have on Virginia’s water.
Contact Governor Ralph Northam’s Office directly: 804-786-2211
If you need a refresher or are taking a first dive into learning about the proposed Atlantic Coast and Mountain Valley Pipelines, Wild Virginia Conservation Director David Sligh is here to help. He explains what’s going on with these projects and why they pose so many threats to Virginians and the Southeast. He also offers some ideas on how anyone who opposes the pipelines can make a difference (down at question four).
Do We Need the Pipelines?
In short, no. We do not need the ACP, a 600-mile-long pipeline that would carry natural gas from West Virginia into Virginia and North Carolina, or the MVP, a pipeline that would source the same fracked gas and have the same destinations.
“If you look at the growth in overall energy demands in VA and NC in the last decade, there’s been a pretty small percentage of growth over the whole period,” David says. A 2016 study of this area’s energy demand for natural gas found existing pipelines can supply more than enough fuel through 2030.
And, while ACP originally claimed the pipeline gas was intended and needed primarily for VA and NC, it now states the gas may go to South Carolina and other areas. Similarly, after getting their original approval, MVP says it will build an addition spur into North-central NC.
Local energy needs can also increasingly be met with renewable sources — David says while pipeline companies like Dominion give “lip service” to these options, they simultaneously oppose the regulatory changes that would empower growth in the wind and solar sectors. He explains:
That’s because they can make such huge profits from fossil fuel projects — for example, the Federal Energy Regulatory Commission allows them to charge ratepayers additional amounts to provide them with up to 14 percent profit just on the cost of building these pipelines, and this profit is not dependent on showing a need for the gas.
Also, FERC has not carried out the legally required “valid needs analysis” relating to energy demand for the pipelines. Because of this, FERC Commissioners Cheryl Lafleur and Richard Glick supported a request for a FERC rehearing.
Why Are the Pipelines a Bad Idea?
The pipelines directly threaten local drinking water, homes, endangered species’ habitats, parks, economies and other vital interconnected systems and attributes of the Southeast. They simply cannot be safely built. David says:
Building a 42-inch, high-pressure gas pipeline across the Allegheny Mountains, the Great Valley of VA and the Blue Ridge Mountains has never been done, for good reason … The companies would have to build on mountain slopes that in many cases are greater than 50 percent and where landslides are common. They would have to blast away mountain ridges and claim they would restore these areas to former contours, which is impossible. They would cut across large areas where limestone geology, termed karst, lies beneath the soil and forms caverns and conduits through which pollution from land disturbance can move to wells and springs quickly, without any filtering. ACP proposes to bore a hole over 4,500 feet through the Blue Ridge and push the huge pipe through the hole. Finally, together, the two projects would cross well more than 1,000 streams and wetlands, many of which have exceptional resource values and are also very sensitive to disturbance.
Also, if the pipelines are built, the industry will use them to validate an avalanching investment in natural gas for decades to come.
What Are the Current States of the Projects?
“FERC issued what are inappropriately termed Certificates of Public Convenience and Necessity for both MVP and ACP last October,” David says. At this point, the companies were empowered to take landowner’s property rights.
In December 2017, the Virginia State Water Control Board issued water quality certifications that require the companies to submit additional plans, some related to erosion and sediment control, before construction. David says the ACP’s certification will not be officially in effect until the plans are approved. The Board also said it might take other actions at that point as well. Over the winter, both companies began permitted tree felling. In March 2018, the VA DEQ approved the MVP’s additional plans and construction has now begun.
David says “court challenges to actions taken by the Board, FERC, Forest Service and Bureau of Land Management are still in progress against both pipelines.” One suit already resulted in a court order stating an ACP permit from the U.S. Fish and Wildlife Service under the Endangered Species Act was wrongly issued and must be redone. This order led to an ongoing dispute between citizens and the ACP over whether it must stop construction overall or only in some areas.
Recently, the VA Board ordered the DEQ to hold a public comment period relating to waterbody crossings, which ended June 15 — over 13,000 opinions were submitted. The more than 1,000 planned water crossings “have so far been covered under a blanket permit issued by the Army Corps of Engineers [and] should receive additional scrutiny and regulation by VA,” David says.
“The public is now pleading with the Board to act quickly to head off further work on either project before any additional reviews can be finished,” he adds.
The push for an immediate and thorough review of the ACP’s potential effects in VA is very important because the MVP project has already broken the law, allowing large loads of mud to flow off construction sites into streams and onto private properties.
“While WVA officials have already issued four Notices of Violation, the VA DEQ has been largely unresponsive and has taken no effective action,” David says.
On June 21st, the federal Fourth Circuit Court of Appeals granted a stay of a Corps of Engineers permit, which prevents MVP from constructing through any streams or wetlands in West Virginia until court hearings scheduled for September.
How Can People Help?
Here are three powerful steps David says you can take if you’d like to join the movement against ACP and MVP construction:
Join in calling on the Water Control Board to conduct the additional reviews of waterbody crossings.
Join Wild Virginia to help us continue to lead the efforts to stop and/or avoid damage from these pipelines and to oppose any destructive projects in our region, so we can preserve as much of Virginia’s wild and natural land and resources as possible.
Who is David Sligh? Wild Virginia Conservation Director David Sligh has 35 years of experience in environmental law. He has a bachelor’s degree in Environmental Science from the University of Virginia and a law degree from Vermont Law School. He is a member of the District of Columbia Bar. Dave has worked as a Senior Environmental Engineer for the Virginia Department of Environmental Quality; Founder and Director of Virginia PEER, the state branch of Public Employees for Environmental Responsibility; Southeast Regional Representative for American Rivers; Upper James Riverkeeper; Adjunct Instructor of Environmental Science at the University of Tennessee at Chattanooga; and as a consultant and adviser to citizen groups around the country.
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A grassroots membership, non-profit organization dedicated to preserving wild forest ecosystems in Virginia's National Forests through education and advocacy