As you may have heard, the State Water Control Board has opened a 30-day comment period to revisit the adequacy of the Army Corps of Engineers Nationwide 12 Permit for stream crossing sites along the Atlantic Coast Pipeline ACP. For the record, there are 189 stream crossings and 43 wetland crossings on the proposed pipeline route in just Augusta County! In the Deerfield Valley alone, the pipe and access roads would cross the Calfpasture and its tributaries an incredible 71 times. And on Back Creek in eastern Augusta the crossings total 49 times. The cumulative impact on the quality of our water is staggering.
Some of the Water Board members—who are charged with protecting the quality of our water—are concerned that the blanket Nationwide 12 permit does not look at the unique and special properties of individual places nor does it properly assess the combined effects on water quality. Remember, water flows downstream and what it picks up in our headwaters will be carried to the next crossing and the next and the next….
In order to better understand the problems and concerns, the Board has opened this comment period asking for specific and detailed comments about the crossings and streams referenced in this list. The official announcement uses the word “technical” a lot, but what they really need to know is how you enjoy and depend upon your stream or wetland (mention it by name) aesthetically, recreationally, for daily living, or for agricultural needs, and why the blanket Nationwide 12 Permit does not ensure you and your downstream neighbors will be able to enjoy your stream in the same way if the pipeline gets built.
Here are some examples where the Nationwide 12 Permit falls short and ways you can equip the Board to advocate for better protections for our streams or wetlands:
- Nationwide 12 does not consider cumulative impacts to water quality where there are multiple crossings along the same stream and its tributaries, such as the 71 crossings of the Calfpasture and 49 of Back Creek.
- Without doing individual stream crossing review, the total threat to Staunton’s water supply is not understood – All of Staunton’s water comes either Gardner Spring or the reservoir in the National Forest, both located in the county and both downstream of intense pipeline construction. Since the ACP project began, city officials have been asking for individual wetland and stream crossing reviews in order to protect the city’s water supplies.
- The proposed permit does not carefully examine on a case-by-case basis the unique characteristics of our special places. That is why your comments are so important! They need to hear what you and your neighbors know about the streams and wetlands that surround you – their special aquatic life, wildlife, recreational uses, and other features. Just don’t forget to mention your stream by name!
- Without detailed review and research of our headwaters, there is no way for the pipeline developers and regulators to know what our frequent hurricane deluges do to the river bottoms and stream banks where the pipe is proposed to be buried. If you have information or pictures of what happens to a specific crossing during flood conditions, let the Board know. An exposed and fractured pipe is an environmental and safety concern!
Our friends at Wild Virginia have crafted a guide to help build comments to ensure they meet the Board’s criteria. Although we’re all frustrated that no one is considering things like the dangers of fracked gas, the lack of need or public benefit, the use of eminent domain for private gain, or visual scarring, this is not the place to mention those concerns and could even get your comments discarded. So, make sure to refer your comments to streams and wetlands in this list and stick to why the Nationwide 12 Permit will fail to protect the quality of your water. Several members of the State Water Control Board have said that “their eyes and ears are open” to facts and reasons behind our insistence that there must be detailed individual crossing review of Virginia’s precious waters.
Comments due June 12 (previously May 30):
Include in your comments:
- The name(s), mailing address(es) and telephone number(s) of the person(s) commenting,
- Pictures, maps, news clippings or other visuals to help emphasize your concern.
by email – NWP12InfoOnACP@deq.virginia.gov
by mail – DEQ, P.O. Box 1105, Richmond, VA 23218
or deliver to – DEQ, 1111 East Main Street Richmond, VA 23219