If Dominion thinks U.S. Forest Service lands would make a more convenient route than others for its proposed 550-mile natural gas pipeline, the federal agency has said, not so fast.

In recent remarks on the ACP’s proposal to the Federal Energy Regulatory Commission, the Forest Service identified 335 issues that in its view aren’t adequately addressed. One of its concerns:

Why is the pipeline using these public lands at all?

Forest Service policy requires a compelling reason for energy projects to cross its lands; it can’t simply be for lower cost or expediency.

“The ACP’s discussion should clearly articulate why the project cannot reasonably be accommodated off NFS lands,” the agency wrote. “This discussion should not cite lower costs or less restrictive locations as the sole purpose of crossing NFS lands.”

Grassroots leader Nancy Sorrells of Augusta County Alliance called it “a powerful, powerful report. They’re commenting on tens of thousands of acres, and they validated the issues we raised about karst, caves, invasive and endangered species.”

The reason the comments are so powerful is that while FERC can authorize the entire pipeline, only the Forest Service can decide if it will cross public lands.

“It’s a separate decision,” Forest Service spokeswoman JoBeth Brown said. “They could be approved for the pipeline, but may or may not be allowed to use Forest Service lands.”

From the first of its 57 pages, the tone of the Forest Service document is one of authority as it puts the ACP through its information paces. It even calls out the proposal on its too-casual naming convention – the proper name is Appalachian National Scenic Trail, not Appalachian Trail – and objects to a misrepresentation of Trail management goals as “biased and deceptive.”

There’s good reason for being thorough, says NFS Special Project Coordinator Jennifer Adams. Because FERC has siting authority for the pipeline, it will be doing the environmental impact study on which the Forest Service has to rely.

“The agency’s comments help not only the ACP understand, but also help FERC understand what’s important to include in the environmental study,” Adams said. “The intent is to be clear in saying for us to make a decision about the use of the land, it must have A, B and C in front of it.”

Dominion will include its responses in its final reports to be filed with FERC later this summer, spokesman Frank Mack said.

Separately, FERC announced Wednesday it’s inviting affected property owners to provide additional comments on the alternative ACP routes Dominion proposed.

Comments need to be filed with the commission by Sept. 4.