May 3, 2016

Sample Scoping Comments – ACP

Scoping Comment Ideas:

There are so many reasons to reject this new pipeline route through Virginia’s national forests.  Here are just a few to help you get started.  Please contact us if you need more.

A right of way for the pipeline should be rejected because….

 Harm to Special Biological Areas:
The new proposed route (GWNF 6) threatens numerous areas designated “Special Biological Areas” that are very important to the overall biological health and diversity of the Forest.  Also, like the initial route, this new path would impact endangered, threatened, and sensitive species.

Previously rejected this route
Dominion previously rejected this proposed route, because construction of a pipeline through this terrain would be especially difficult and would increase the project’s impacts to the environment to an unacceptable degree.  The company has not justified their change in opinion on this matter.

Unstable Karst terrain
The new route would still cross large areas of karst terrain and threaten public and private water supplies to an unacceptable degree.  Also, the route crosses very steep slopes, areas highly prone to landslides, and soils that are easily eroded and will pollute important streams.

Failure to consider other route options
Because Dominion’s earlier analysis of alternatives did not look at this proposed route, it has not been adequately compared to the other possible options in a fair way.

The Forest Plan should not be amended because…

Failure to consider required alternatives
The Forest Service has repeatedly insisted that Dominion must show that no route that avoids crossing the George Washington National Forest, before crossing the Forest may be allowed.  Dominion has still failed to provide such reasons.  No plan amendment should be adopted to allow Dominion to evade that responsibility.

No benefit to the public
Allowance of the new proposed route (GWNF 6) would be in conflict with federal laws requiring protection of high-value biological, recreational, and cultural resources that belong to the public and, in return, the pipeline would provide no benefit to the general public.  The Forest Service has stated that many of these areas are unsuitable for utility construction and no new evidence refutes that judgement.

Shortcuts public process
The regular Forest Planning process allows extensive public participation and a deliberative approach to balance the many resource protection issues and and uses on the Forest.  To amend the current plan, which is to govern management of the Forest for 15 years or more, would short-circuit that process for the profit of private companies.