20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM United States Department of the Interior NATIONAL PARK SERVICE Northeast Region IN REPLY REFER TO: - . United States Custom House A.l 200 Chestnut Street Philadelphia, PA 19106 APR 28 2015 Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room 1A Washington, DC 20426 Subject: FERC Dockets and PF15-6-000 Notice of Intent to Prepare an Environmental Impact Statement for the Supply Header Project (Dominion Transmission, Inc.) and the Atlantic Coast Pipeline Project (Atlantic Coast Pipeline, West Virginia, Virginia and North Carolina; NPS (ER 15/0127) Dear Secretary Bose: The National Park Service (NPS) is pleased to provide comments on the Notice of Intent (N01) to prepare an Environmental Impact Statement (EIS) for the Supply Header Project (SHP) and the Atlantic Coast Pipeline Project (ACP Project). SHP would involve construction and operation of facilities by Dominion Transmission, Inc. (Dominion), in and West Virginia. The SHP would involve the construction and operation of approximately 38.7 miles of pipeline loop and the modi?cation of existing compression facilities in and West Virginia. The ACP Project would involve construction and operation of 554 miles of variable diameter natural gas pipeline and related facilities by Atlantic Coast Pipeline, LLC (Atlantic), in West Virginia, Virginia and North Carolina. More speci?cally, the ACP Project would consist of the construction of approximately 295.6 miles of new 42-inch diameter pipeline in Harrison, Lewis, Upshur, Randolph and Pocahontas Counties, West Virginia; Highland, Augusta, Nelson, Buckingham, Cumberland, Prince Edward, Nottoway, Dinwiddie, Brunswick and Greensville Counties, Virginia; and Northampton County, North Carolina; approximately 179.9 miles of 36- inch?diameter pipeline in Northampton, Halifax, Nash, Wilson, Johnston, Sampson, Cumberland, and Robeson Counties, North Carolina; approximately 75.7 miles of 20-inch?diameter lateral pipeline in Northampton County, North Carolina; and Greensville, Southampton, Suffolk, and Chesapeake Counties, Virginia; approximately 3.1 miles of 16?inch-diameter natural gas lateral pipeline in Brunswick County, Virginia; and construction and operation of three new compressor stations totaling 108,275 horsepower of compression. These compressor stations would be located in Lewis County, West Virginia; Buckingham County, Virginia; and Northampton 1 20150429?5480 FERC PDF (Unofficial) PM County, North Carolina. Atlantic would also install metering stations, valves, pig launcher/receiver sites, and associated appurtenances along the planned pipeline system. The NPS has concerns regarding potential impacts to the Appalachian National Scenic Trail, Shenandoah National Park and the Blue Ridge Parkway, units of the National Park System; and the Captain John Smith Chesapeake National Historic Trail, administered by the NPS. We also have concerns regarding three National Natural Landmarks (NNLs) which may be directly impacted by the proposed pipeline. While NPS has an administrative and advocacy role for the NNL program, we are not the land managers for the three units in question. We provide more information below, including contact information, for these three units. The Appalachian National Scenic Trail The Appalachian National Scenic Trail (Trail) is a 2,189-mile footpath that traverses through the scenic, wooded, pastoral, wild, and culturally resonant lands of the Appalachian Mountains across fourteen of the eastern United States, from Katahdin in Maine to Springer Mountain in northern Georgia. Conceived in 1921 and completed in 1937, the Trail was built and is still maintained by volunteers, giving rise to its nickname, ?the people?s trail? and is enjoyed by an estimated 2 to 3 million people each year. The Trail was designated as the first National Scenic Trail by the National Trails System Act of 1968 and it is arguably the most famous hiking path in the world. The Trail offers opportunities for viewing spectacular scenery and opportunities for a variety of recreational activities, and lies within a day?s drive of two-thirds of the American population. Furthermore, the Trail is eligible for listing in the National Register of Historic Places (NRHP), and the NPS has prepared documentation to formally list it on the NRHP. The Trail is a unit of the NPS and is currently protected along more than 99 percent of its course by federal or state ownership of the land or by rights-of?way. As shown in the most recent pipeline data from Dominion, the proposed route would cross the Trail within Nelson County, VA. The proposed pipeline would cross the Trail within the Blue Ridge Parkway (see Figure 1). Title 30 of the United States Code (U.S.C.) Section 185, Rights of Way for Pipelines through Federal Lands, speci?cally excludes units of the national park system and many other speci?cally protected federal properties from the Secretarial authority to issue rights-of?ways for petroleum product pipelines and associated facilities. The legislative history of the 1973 amendments to the Mineral Leasing Act demonstrate that Congress clearly intended that National Park System units be exempt from a general grant of authority to issue oil and gas pipeline rights-of?way. The authorities for the National Park System to issue rights~of?way permits, Title 16 U.S.C. Sections 5 and 79, also do not include petroleum product pipelines as a utility to which a right?of?way permit may be issued. Therefore, NPS has no authority to permit the proposed pipeline crossing. Dominion has shared with NPS staff an alternative that would 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM cross the Trail on non-NPS lands in the vicinity of the Wintergreen Resort. We recommend further assessment of this alternative. The NP S, Appalachian National Scenic Trail representative and lead contact is Wendy Janssen, Superintendent, at Wendy ansseanDmS. gov or (304) 535-6279. ATLANTIC COAST PROPOSED CROSSING 0F THE APPALACHIAN TRAIL JANUARY 2015 NPROPOSED PIPELINE ROUTE TRAIL USFS LAND BLUE RIDGE PARKWAY LAND STATE - NPS Nam LAND . EL :9 l; 11w. Mm Figure 1: The ACP proposed pipeline ro ut shown crossing the Appalachian National Scenic Trail and the Blue Ridge Parkway with federal ownership indicated, Nelson County, VA 20150429?5480 FERC PDF (Unofficial) 4/29/2015-4 15 46 PM 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM Blue Ridge Parkway Congress allocated funds for the initial construction of the Blue Ridge Parkway in 1933 and authorized the National Park Service to administer and manage the parkway in 1936. The parkway is in Virginia and North Carolina in the central and southern Appalachian Mountains. It is 469 miles long and connects Shenandoah National Park to the north with Great Smoky Mountains National Park to the south. Created as a national rural roadway with limited access, the parkway was designed for pleasant motoring, a form of recreational driving free from commercial traf?c. The Blue Ridge Parkway travels the crests, ridges, and valleys of ?ve major mountain ranges, encompassing several geographic and vegetative zones ranging from 600 to over 6,000 feet above sea level. It provides visitors with many varied vistas of scenic Appalachian landscapes ranging from forested ridge tops and mountain slopes to rural farm lands to urban areas. The parkway offers a ?ride-a?while, stop-a?while? experience that includes scenic pullouts, recreation areas, historic sites, and visitor contact stations. It is known nationally and internationally for its designed landscape as a scenic motorway. Unlike all but one other unit of the NPS, the Blue Ridge Parkway enabling legislation speci?cally allows the Secretary of the Interior to ?issue revocable licenses or permits for rights- of?way over, across, and upon parkway lands. . (16 U.S.C. 460a~3). An authorization from the Parkway would be needed for the ACP Project. It is important to note that for those Appalachian Trail lands transferred to the Blue Ridge Parkway, the prohibitions of 30 U.S.C. 185 still hold. This includes the lands in the current ACP Project proposed route. We have concerns about the potential impacts of this proposed pipeline on views from key Parkway vistas. As we also detail below, we recommend the EIS include a visual analysis to determine potential impacts. NPS staff can assist in determining key locations and other elements of such an assessment. The NPS, Blue Ridge Parkway representative and lead contact is Mark H. Woods, Superintendent, at mark woods?inpsgov or (828) 348-3405. Shenandoah National Park Shenandoah National Park in Virginia includes 200,000 acres of protected lands that are haven to deer, songbirds, the night sky and a variety of recreational experiences. The cascading waterfalls, spectacular vistas and quiet wooded hollows of the park are located just 75 miles from Washington, DC. Shenandoah National Park also includes the Skyline Drive National Historic District. NPS staff are ready to provide assistance in the assessment of potential impacts to these resources. We also recommend that FERC and the project proponent contact the State Historic Preservation Of?cer at the Virginia Department of Historic Resources to ensure that they are aware of the project. 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM The park enabling legislation directs the NPS to protect the park views and visitor opportunities from key viewpoints like the Skyline Drive overlooks and the Appalachian Trail vistas. We have concerns about the potential impacts of this proposed pipeline on views from key park and Trail vistas. We recommend the EIS include a visual analysis to determine potential impacts. NPS staff can assist in determining key locations and other elements of such an assessment. Shenandoah National Park is also a Class 1 area as designated in the Clean Air Act and Amendments. It is not clear if there will be associated impacts to air quality in the area that may impact park resources and Air Quality Related Values (such as visibility). To date, the proponent has not identi?ed potential point sources of pollutants often associated with large natural gas pipelines. NPS recommends that potential impacts to the Class 1 area be assessed in the EIS. The NPS, Shenandoah National Park representative and lead contact is Jim Northup, Superintendent, at iim 11.0rthup@nps.gov or (540) 999-3500, ext. 3100. The Captain John Smith Chesapeake National Historic Trail The Captain John Smith Chesapeake National Historic Trail (Captain John Smith Trail) was designated under The National Trails System Act (PL. 90-543, as amended through P.L. 111-1 1, March 30, 2009). It commemorates Smith's exploration of the Chesapeake in 1607-1609; shares knowledge of the American Indian societies and cultures with which he interacted; and interprets the past and present natural history of the Chesapeake Bay. The Captain John Smith Trail is located in Virginia, Maryland, Delaware, Washington DC, and New York. The trail is administered by the NPS in coordination with the Chesapeake Bay Gateways and Watertrails Network authorized under the Chesapeake Bay Initiative Act of 1998 and the Chesapeake Bay Program authorized under section 117 of the Federal Water Pollution Control Act, in consultation with other Federal, State, tribal, regional, and local agencies, and private stakeholders. The river-based trail is in closest proximity to the proposed pipeline route in the Wingina, VA area. The proposed Atlantic Coast Pipeline crosses the James River in an area with evocative landscapes along the Captain John Smith Chesapeake NHT route. The proposed route would likely impact archaeological resources contributing to the Captain John Smith Trail route north and southeast of the river; speci?cally, the cultural resources important to American Indians in the region which can be fully understood through Indigenous Cultural Landscapes. For example, the proposed pipeline is within the vicinity of the Indian town Monahassanugh, recorded by Captain John Smith on his map. The NPS Chesapeake Bay Office would like to assist FERC in identifying potential resources in the project area as this process moves forward. NPS can provide assistance to FERC in reaching out to interested parties that could also help in the understanding of resources in the area. 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM Figure 2 shows contact period Villages in the James River area that may prove useful in assessment of the potential impacts of the Project that may concern the NPS. JAMES RIVER Captain John Chesapeake Hatlonai Historic Trait Potentlai Con netting Trait Town or City m" ?k Potentlai interpretive Site Smith Map ?King?s House" (approx) Monacan/Mannahoac Territory Muma?apaaougi?i 33.33 -. 3 3333 t- maria *5 Scottw?ie .- . ill? ED ?6 I: :f?wm? arm-'9- r' 3 ?Manama Bridge were when 3 Figure 2: Contact period Villages in the James River area. The NPS, Captain John Smith Chesapeake National Historic Trail representative and lead contact is Chuck Hunt, Superintendent, at Charles hunt?npsgov or 410-260?2471. National Natural Landmarks (NNLS) The National Natural Landmarks (NN L) Program recognizes and encourages the conservation of sites that contain outstanding biological and geological resources, regardless of landownership type. It is the only natural areas program of national scope that recognizes the best examples of 7 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM biological and geological features in both public and private ownership. Sites are designated by the Secretary of the Interior, with landowner concurrence, and to?date, nearly 600 landmarks have received the NNL designation. The National Park Service administers the program, reports on the condition of the NNLs, acts as an advocate for the protection of designated sites, and raises public awareness of our Nation?s natural heritage. We are concerned as it appears each of these NNLs will be directly impacted by the proposed pipeline route. We encourage FERC to contact each of the listed managers. Blister Run Swamp NNL Randolph County, West Virginia Blister Run Swamp NNL is located within the Monongahela National Forest and contains a nationally signi?cant high altitude balsam ?r swamp. This type of plant community is very rare in West Virginia. The swamp is probably the southernmost eXtension of balsam ?r in the country and represents a disjunct relict population of Canadian boreal species. The site provides habitat for several uncommon and rare plants along with northern birds and mammals occurring here south of their normal range. This swamp also contains perhaps the oldest balsam ?r in the state. Contact: USFS, Monongahela National Forest, Clyde Thompson, Forest Supervisor, cnth.ompson@fs.fed.us, 304~636-1800. 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM BLISTER RUN SWAMP N?LaeunI?? NATIONAL NATURAL LANDHARK County, West ngnla ??qu awn?mm ll cm B5 Gatul?mhmge: m. ?5&2 Figure 3: Blister Run Swamp NNL Gaudineer Scenic Area NNL- Randolph and Pocahontas Counties, West Virginia Gaudineer Scenic Area NNL contains one of the last remaining high elevation old-growth red spruce forests in West Virginia. This 140~acre tract, located Within the Monongahela National Forest, has old growth trees estimated to be near 300 years old. The old growth forest is buffered almost entirely by second-growth red spruce forest. Hobblebush and striped maple are frequent shrubs with ferns, mosses and club mosses common in the herbaceous layer. This site has also been designated by the U.S. Forest Service as a Scenic Area. Contact: USFS, Monongahela National Forest, Clyde Thompson, Forest Supervisor, cnthomoson?fsfedus, 304-636-1800. 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM GAUDINEER SCENIC AREA 13 NNL Boundary NATIONAL NATURAL LANDMARK Randolph and Pocahontas Counties, West Virginia A Warsaw CI 5.216 1145 Calculated Acreage: 143.1 was Figure 4: Gaudineer Scenic Area NNL Great Dismal Swamp MVL- Su?olk County, Virginia The 43,200-acre landmark is located within the Great Dismal Swamp National Wildlife Refuge. The site is a remnant of the original Great Dismal Swamp containing geological and ecological elements unique in the nation. The variety of ?ora andfauna makes it a superb outdoor laboratory for the study of ecological processes. An important feature of the landmark is 3,100- acre Lake Drummond, around the edge of which some reminders of the majestic cypress, which once dominated the swamp, still stand. While the lake bottom is white sand, much of the swamp ?oor is peat, which has been sounded to depths up to eleven feet and aged by radiocarbon dating at 8000+ years and is still forming. Contact: Great Dismal Swamp National Wildlife Refuge, Chris Lowie, Refuge Manager, chris lowie@fws.gg, 757-986-3705 ext. 29. 10 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM IV Figure 5: Great Dismal Swamp NNL GREAT DISMAL SWAMP NNL Boundary NATIONAL NATURAL LANDMARK Chesapeake County, Virginia 2.Catwiated?mage: 493.2543 um wunmm? Route Changes The NPS understands that project planning at this stage may not re?ect the ?nal pipeline route as landowner agreements are ?nalized and alternatives are developed. There are a number of resources within ?ve miles or less of the proposed pipeline route in which the NPS has an interest. Should the route change, these program lands may be impacted. We request to be kept apprised of any further route or overall project changes, and can provide contact information and additional assistance should it be needed. . Six National Historic Landmarks (N HLs) are present in the general vicinity of the proposed route. The NPS administers the NHL program and has responsibilities under the National Historic Preservation Act (NHPA) for review and comment under Section 106. We also have potential concerns over two National Heritage Areas (NHAS), and eight Civil War battle?elds. All are managed by non-NPS entities; however, the NPS has an oversight role. More information on each of these resources follows. 11 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM National Historic Landmarks (NHLs) The NPS manages the NHL program on behalf of the Secretary of the Interior and has responsibilities under the NHPA Section 106 and Section 110(i) to review and comment on projects affecting NHLs. The following NHLs are located within ?ve miles or less of the current proposed pipeline route. Weston State Hospital Woodrow Wilson Robert Russa Moton High School Saylor?s Creek Battle?eld Dry Dock No. 1 No. 101 Portsmouth Location maps are provided for each NHL. We do not anticipate any impacts from the proposed pipeline to these landmarks given the current proposed route. However, the NPS requests to be kept informed should the route change, or any alternatives move closer to these locations. Each of these sites is managed by a non?NPS entity. NPS can provide contact information for these managers should this information not be readily available to FERC. Figure 6: Weston State Hospital NHL and the Atlantic Coast Pipeline 12 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM 0 Figure 8: Robert Russa Moton High School NHL, Saylor?s Creek Battle?eld NHL and the Atlantic Coast Pipeline 13 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM Figure 9: Dry Dock No. 1 NHL, N0. 101 Portsmouth and the Atlantic Coast Pipeline Journey Through Hallowed Ground National Heritage Area We also note the passage of the proposed route through the Journey Through Hallowed Ground National Heritage Area (N HA). National Heritage Areas are places where natural, cultural, historic and recreational resources combine to form a cohesive, nationally distinctive landscape arising from patterns of human activity shaped by geography. National Heritage Areas may be managed by a State or local agency, a commission, or a private nonpro?t corporation. The NPS provides technical and ?nancial assistance for a limited time (usually 10-15 years) following designation. We encourage Dominion to contact the appropriate NHA manager for their input. A list of all National Heritage Areas, as well as contact information can be found at 14_ 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM Shenandoah Vattey Battle?elds NHD grammar: FID 6 Shun ..: amen Ill andoah valley ?elds NHD Figure 10: Journey Through Hallowed Ground NHA, Shenandoah Valley Battle?elds NHD and the Atlantic Coast Pipeline. Shenandoah Valley Battlefields National Historic District The Shenandoah Valley Battle?elds National Historic District was created by Congress to protect and interpret the Valley's Civil War story. See Figure 10 above. It includes fourteen signi?cant Civil War battle?elds and a wide variety of related historic sites across eight counties. Visitors can explore the campaigns of Stonewall Jackson and Philip Sheridan and the effect of those campaigns on the civilian population. Eight of these battle?elds are in the area of the ACP Project. The proposed pipeline passes through two of the battle?elds, directly adjacent to another two, and within a few miles of the remaining four, as noted below (county location appears after the battle?eld name). Cumberland Church, Cumberland (proposed pipeline passes through this site) High Bridge, Prince Edward Sailor's Creek, Prince Edward (proposed pipeline passes adjacent to this site) Rice?s Station, Prince Edward Amelia Springs, Amelia Cheat Mountain, Randelph (proposed pipeline passes adjacent to this site) McDowell, Highland (proposed pipeline passes through this site) Greenbrier River, Pocahantas - The Shenandoah Valley Battle?elds National Historic District is managed by the Shenandoah Valley Battle?elds Foundation. They can be reached at 9386 South Congress Street, New 15 20150429?5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM Market, VA 22844; (540) 740-4545; info@svbf.net and We encourage ERC and the project proponent to contact the Foundation for assistance in understanding potential impacts to these important resources. We appreciate your efforts to consider and address NPS concerns regarding the proposed pipeline. Thank you for the opportunity to provide comments. If you have any questions or need additional information, please contact Mary Krueger, Energy Specialist for the Northeast Region at Mary or 617-223-5066. Sincerely, 1i Eli} amt. Frank Hays 12?" Acting Associate Regional Director Resource Stewardship Science Northeast Region l6 20150429-5480 FERC PDF (Unofficial) 4/29/2015 4:15:46 PM Document Content(s) ER15-0127_ACP-SHP NOI_NPS comments_28Apr2015 (1).PDF..................1-16