Atlantic Coast Pipeline LLC (ACP) has asked FERC to continue work on a substantial portion of the 600-mile route, arguing in a filing this week that segments of the system are unaffected by a federal appeals court decision to vacate key permits and serve public needs that are independent of the broader project.

If approved, work could be cleared to start again across hundreds of miles. The Federal Energy Regulatory Commission ordered all work to stop in response to the court’s decision. In addition to the broader work stabilization plan ACP was required to submit ahead of the stoppage, the Commission last Friday also gave the project three days to submit evidence that parts of the pipeline unaffected by the court’s decision serve an independent public need.

ACP has since identified several areas. Project infrastructure from its Buckingham, VA, interconnection with the Transcontinental Gas Pipe Line (Transco) to points downstream is unaffected by the court’s decision and could be used for gas deliveries to markets in both North Carolina and eastern Virginia, the company said in its request to resume work.

“These markets are chronically constrained in terms of natural gas supply,” the pipeline’s backers said. “Independent of ACP’s proposed construction of pipeline upstream of the Buckingham — including areas affected by the Aug. 6 court order — ACP could receive up to 885,000 Dth/d from Transco for service on the ACP main line and the Virginia lateral.”

If authorized, that portion of the project could restart work on over 300 miles of the project.

Another component of ACP, the 37.5 mile Supply Header Project (SHP) in Pennsylvania and West Virginia, is also unaffected, the company said. SHP is designed to receive 1.5 Bcf/d of natural gas on the Dominion Energy Transmission Inc. (DETI) system, which has been authorized to make various ACP-related upgrades. Customers would supply gas at various receipt points and the Dominion South Point hub. Those volumes would then be redelivered at an interconnection called Marts.

“SHP infrastructure will facilitate additional natural gas supplies to and from Dominion South Point among multiple suppliers, markets and interconnected pipeline systems — including at least a portion of the ACP,” the company said.

ACP, backed by Dominion Energy Inc., Duke Energy Corp., Piedmont Natural Gas and Southern Company Gas, noted that DETI was not a party to the judicial proceedings that invalidated its permits.

The U.S. Court of Appeals for the Fourth Circuit vacated a right-of-way issued by the National Park Service authorizing ACP to cross the Blue Ridge Parkway, which links the Shenandoah National Park in Virginia to the Great Smoky Mountains National Park in North Carolina, and provided more reasoning for an earlier decision to vacate an incidental take permit issued by the U.S. Fish and Wildlife Service.

Natural gas received via SHP at Marts could also be redelivered to the Long Run delivery point into the Columbia Gas Transmission system in Randolph County, WV. That interconnection, which is also not affected by the vacated permits ACP said, could accommodate 300,000 Dth/d for shipments downstream.

Additionally, ACP on Wednesday filed supplemental information covering other minor work that serves an independent purpose.

The project also filed its temporary work stabilization plan this week to minimize environmental impacts and shore-up safety along affected portions of the route. ACP highlighted plans to install pipeline in areas that have already been trenched, strung or welded, a stretch covering about 10 miles. The company said it would also need to complete work at associated facilities and be allowed to inspect work sites. If approval to restart construction is not issued by Sept. 1, then the plan would need to be revised, ACP added.

The Mountain Valley Pipeline, which has also been ordered to stop all work for similar reasons, recently submitted its work plan, which required additional pipeline installation. It was approved by FERC on Monday.

FERC has already approved another ACP request to complete work at three “critical” locations in West Virginia as well.

The company has been cleared to finish two road bores in Upshur and Harrison counties. It also may complete upgrades at an existing compressor station in Wetzel County to prevent environmental and safety impacts, and to avoid interrupting service on DETI’s existing natural gas system.

One road bore, ACP said, is 90% complete. Deep excavations exist on both sides of the crossing and the company said the crossing pipe would need to be tied into the main line in order to safely close the excavations. At the other crossing, a road is shuttered, and if work ceases, ACP said, the closure would be prolonged and the entry pit could collapse. The compressor station is regularly used to pump storage gas into an existing DETI storage pool. The company was initially required to finish upgrades to prevent service impacts to customers.

Environmental groups, which signaled opposition to MVP’s plans, said they would oppose ACP’s request to continue work in areas that serve an independent public need, arguing that it amounts to three separate projects without permits.

ACP would originate in West Virginia, pass through Virginia and into North Carolina to move 1.5 Bcf/d of Appalachian natural gas to the Southeast.