4th Cir.

Dan River Basin Association v. Virginia Department of Environmental Quality

June 11, 2026 ·26-1220 ·Panel Decision ·Wynn · By Maria Santos

The Fourth Circuit denied a motion for a stay pending review of a Virginia water quality certification for the Southgate Project. The court found that petitioners failed to make a strong showing that they are likely to succeed on the merits of their administrative law challenges.

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Background

The case involves a petition for review of a decision by the Virginia Department of Environmental Quality regarding a water quality certification for the Southgate Project. The project is a proposed pipeline traversing North Carolina and Virginia. Petitioners sought a stay of the certification pending review, arguing the agency’s decision was arbitrary and capricious due to the pipeline operator’s history of noncompliance and the omission of necessary conditions.

The court’s reasoning

The court applied the arbitrary and capricious standard under the Administrative Procedure Act. It found that the Virginia Department of Environmental Quality provided a rational explanation for its prediction of future compliance, distinguishing the Southgate Project from the operator’s previous Main Pipeline based on terrain and improved practices. The court also held that the certification explicitly incorporated by reference the required erosion and sediment control agreements, refuting the claim that conditions were unlawfully omitted.

Petitioners have not made a strong showing that they are likely to succeed on the merits.

slip op. at 3

What it means going forward

The denial of the stay allows the Virginia Department of Environmental Quality to proceed with the water quality certification, permitting construction activities to continue while the underlying merits of the case remain pending.