August 29, 2023
Michael Connor
Assistant Secretary of the Army, Civil Works
U.S. Army Corps of Engineers
441 G Street, N.W.
Washington, DC 20314
RE: NAO-2012-0080 Surry-Skiffes Creek-Whealton Proposed Meeting Request
Dear Assistant Secretary Connor:
We, the undersigned groups, continue to have significant concerns regarding the Army Corps-managed review of Dominion Energy’s Surry-Skiffes Creek-Whealton 500kV transmission line project across the James River near Jamestown, Virginia. We respectfully request a meeting with you to discuss our concerns prior to the release of a Final Environmental Impact Statement (FEIS) expected this fall.
The Drat EIS released by the Corps’ Norfolk District in November 2020 was seriously flawed and defied the mandate of the U.S. Court of Appeals for the D.C. Circuit to conduct a more thorough review of the project’s impacts and revisit its analysis under the Clean Water Act and National Historic Preservation Act. Among the many deficiencies we noted in our collective comments on the DEIS, the Norfolk District failed to consider new information made available to the agency prior to the release of the DEIS and failed to consult meaningfully with relevant federally recognized tribes.
We fear that with the release of the FEIS, the Norfolk District will simply “re-approve” the already constructed transmission line without addressing the serious concerns previously shared by the National Park Service, the Advisory Council on Historic Preservation, the Environmental Protection Agency, tribal representatives, and the conservation and historic preservation community. Meeting with you prior to an FEIS being issued is imperative to share with you the serious ongoing flaws in the planning process, which can and should be addressed in order to protect nationally significant historic properties, indigenous cultural landscapes, unique aquatic resources, and other important aspects of the local ecosystem.
We invite you to work with us to ensure that the resources and values under your stewardship are ultimately conserved unimpaired for the enjoyment of future generations. We respectfully request that your staff contact Pamela Goddard to facilitate a meeting date and time.
Respectfully submitted,
| Jonathan B. Jarvis 18th Director of the National Park Service 2009 – 2017, retired William J. Cook Partner Cultural Heritage Partners, PLLC Rappahannock & Upper Mattaponi Tribes www.culturalheritagepartners.com Elizabeth Kostelny Chief Executive Officer Preservation Virginia Historic Jamestowne preservationvirginia.org Michael B. Murray Chair, Executive Council Coalition to Protect America’s National Parks protectnps.org | Elizabeth Merritt Deputy General Counsel National Trust for Historic Preservation savingplaces.org Pamela Goddard Senior Program Director Mid-Atlantic Region National Parks Conservation Association www.npca.org Michelle B. Nowlin Clinical Professor of Law Duke Environmental Law and Policy Clinic law.duke.edu |
cc:
Tommy Beaudreau, Shannon Estenoz, Mathew Strickland, Andrew Raddant
U.S. Department of Interior
Charles Sams, Frank Lands, Michael Caldwell, Joy Beasley, Roy Sauvajot, Gay Vietzke, Jonathan Meade
National Park Service
Jerri Marr
Colonial National Historic Park
Reid J. Nelson, Jaime Loichinger, John Eddins
Advisory Council on Historic Preservation
Justin Pidot, Jayni Hein, Thomas Sharpe, Sharmila Murthy
Council on Environmental Quality
Jaime Pinkham, Stacey Jensen
U.S. Army Corps of Engineers, Civil Works
Stepan Nevshehirlian, Carrie Traver
U.S. Environmental Protection Agency
Mark Warner, Tim Kaine
United States Senate
Rob Witman
U.S. House of Representatives
Julie Langan, Roger Kirchen
Virginia Department of Historic Resources