ENVIRONMENT - BECKETS RUN WOODLAND
“It must follow its Forest Stewardship Plan and its Conservation Plan”
“The requirements of Executive Order No. 13,286, which recognizes
the need for actions to prevent the introduction of, detect,
rapidly response to, and control, populations of invasive species.”
“Beckets Run states that it has met with Dominion representatives
to demonstrate and discuss problems resulting from off-road traffic
on and adjacent to existing and proposed rights-of-way,
but that Dominion has halted negotiations,
indicating it finds Beckets Run’s requested measures
unreasonable and unduly costly. “
Beckets Run Woodlands (Beckets Run), located within the Beckets Run
Biological Diversity Area46 in Forward Township, Pennsylvania, does not oppose the proposed project, but seeks to ensure project impacts will not affect its status as a certified sustainable forestry business.
In comments filed in response to the EA, Beckets Run explains that to retain this status, it must follow its Forest Stewardship Plan and its Conservation Plan (Forest and Conservation Plans).
The Forest and Conservation Plans require Beckets Run to adhere to specific forest conservation practices, e.g., to limit the spread of invasive species and limit the access of off-road vehicles. Beckets Run is concerned that if the Commission does not require Dominion to adhere to similar conservation practices along its proposed right-of-way through the Beckets Run Woodlands, the state and federal agencies that oversee Beckets Run may find that it has failed to fulfill the mandates of its Forest and Conservation Plans.
60.
Regarding invasive species, Beckets Run observes that while Dominion has committed to use certified weed-free mulches, seed mixes, and desirable native vegetation following construction in accordance with recommendations by Natural Resources Conservation Services or in accord with landowners’ requests, it believes these measures are insufficient to prevent and control invasive species that are already on the property.
Whereas weed-free post-construction restoration measures are important, Beckets Run insists they do not deter the spread of invasive species that already exist in current and proposed pipeline rights-of-way.
Thus, Beckets Run proposes monitoring vegetation restoration for invasive species for at least three growing seasons, rather than the two seasons specified in Dominion's ESCP and the Commission's Plan.
Beckets Run asks the Commission to require Dominion to comply with a comprehensive site and species specific invasive species management plan containing provisions similar to its species specific invasive species management plan containing provisions similar to its Forest and Conservation Plans.
61.
Beckets Run is also concerned about off-road vehicles trespassing on pipeline rights-of-way, as this can lead to the degradation of soil, vegetation, and wildlife habitat.
Beckets Run contends that while page 1-27 of the EA lists several measures to control off-road vehicles (i.e., posting signs, installing fences with locking gates, and placing slash, shrubs, timber, boulders, and pipe barriers across the right-of-way), the EA states that it is contingent on the landowner to request such measures through easement negotiations.
Beckets Run states that it has met with Dominion representatives to demonstrate and discuss problems resulting from off-road traffic on and adjacent to existing and proposed rights-of-way, but that Dominion has halted negotiations, indicating it finds Beckets Run’s requested measures unreasonable and unduly costly.
Beckets Run proposes that if Dominion will not negotiate the terms of an easement, then the Commission should require Dominion to develop, disclose, and implement comprehensive plans that address invasive species, off-road vehicles, and reforestation for all phases of the proposed project.
Beckets Run is concerned that Dominion will exercise eminent domain to secure easement without negotiating with landowners and without implementing any measures beyond those required by the Commission certificate conditions.
62
We expect Dominion will make good faith efforts to reach rights-of-way agreements with affected landowners.
Beckets Run’s concerns regarding the restoration and continued protection of the rights-of-way across its property, as outlines in its May 5, 2011 letter, appear reasonable. We direct the parties to continue discussions in Environmental Condition No. 24.
Beckets Run cites the requirements of Executive Order No. 13112 (64 FR 6,183 (Feb. 8, 1999), amended by Executive Order No. 13,286 (Feb. 28, 2003)), which recognizes the need for actions to prevent the introduction of, detect, rapidly response to, and control, populations of invasive species.
mDominion Transmission, Inc - Docket No. CP10-448-000
June 16, 2011
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