indian creek watershed association december 15, 2016 · to: kimberly d. bose, secretary, federal...
TRANSCRIPT
Indian Creek Watershed Association P.O. Box
711 Union, WV 24983 www.IndianCreekWatershedAssociation.org
December 15, 2016
TO: Kimberly D. Bose, Secretary, Federal Energy Regulatory Commission
RE: Massive Post-DEIS Supplemental Information Submitted by MVP Requires Revised or Supplemental Environmental Impact Statement for the Mountain Valley Pipeline (Docket No. CP16-10-000) and Equitrans Expansion Project (Docket No CP16-13-000)
Indian Creek Watershed Association fully supports the important comment submitted October 19, 2016 on behalf of Allegheny Defense Project, Appalachian Mountain Advocates et al. (Accession #20161019-5061), and we would like to offer some additional perspective and information.
As noted in the opening statement of that comment: Public scrutiny of environmental decisionmaking, informed by high quality and accurate information, is essential to Compliance with the National Environmental Policy Act (“NEPA”). 40 CFR §1500.1(b). … FERC must supply information and analysis regarding the MVP Project in a manner that facilitates meaningful analysis and public participation.
By its premature issuance of the DEIS, which was followed shortly by a massive set of new materials submitted by MVP, the FERC has created confusion with respect to what set of materials (and what version of MVP’s pipeline corridor proposals) is under consideration, thereby significantly undermining “meaningful analysis and public participation.”
1. On September 16, 2016, the Federal Energy Regulatory Commission (FERC) issued its DraftEnvironmental Impact Statement (FERC/DEIS-D0272) for the Mountain Valley Pipeline. Thismaterial consists of the main DEIS document plus 23 Appendices, totaling 2,671 pages in theFERC-generated PDF.
The DEIS was issued by FERC at that time despite specific requests from individuals,organizations and officials not to release the Draft Environmental Impact Statement for theMountain Valley Pipeline (MVP) project until MVP had provided information required to fulfilldata requests by the FERC staff, agencies such as the U.S. Forest Service, and members of thepublic. The FERC staff knew in advance that significant amounts of data and analysis would bemissing if they published the DEIS in mid-September, since MVP itself had reported that it wouldnot be able to supply some data requested by FERC staff until September 30, 2016.
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2. Within one month of the DEIS issuance, MVP began to submit massive amounts of“supplemental information” and continued to do so into early November.
• On October 14, 2016 (Accession #20161014-5022), the Mountain Valley Pipeline submitted“supplemental information” in the form of 161 separate files, with a total file size of morethan 2 thousand megabytes (2,379.75MB).
• On October 20, 2016 (Accession #20161020-5175), MVP submitted another cache ofsupplemental information, five files, totaling 1,062 pages in the FERC-generated PDF.
• On October 27, 2016 (Accession #20161020-5212), MVP submitted yet another cache ofsupplemental information, 16 files totaling 248 pages in the FERC-generated PDF
• On November 2, 2016 (Accession #20161102-5046) MVP submitted a response to datarequest, totaling 8 pages.
3. Issues with the newly submitted MVP materials include the following:
• The materials submitted by MVP after the FERC issued its DEIS are based on a newly revised“October 2016 Proposed Route,” complete with revised milepost numbers, new alignmentsheets, revised tables, etc.
• The 161 MVP files posted on October 14 are presented in the FERC’s elibrary in randomorder, rendering them virtually useless. (See Attachment 1 for a downloaded copy of theFERC e-library page for this Accession.) For example, the second file in the list is titled“Attachment H – Date [sic] Responses – Public Part 1 of 2.” To locate Part 2 of thisdocument, you need to scan to the last of the 161 files. A massive disorganized datasubmission such as this is commonly referred to as a “data dump.” Lack of transparency andinaccessibility have been typical of materials submitted by MVP and/or presented by FERCthroughout the application process.
• Despite the huge amount of data, however, critical information is still missing, including forexample, the crossing lengths for 68% of the proposed waterbody crossings (1258 of 1848identified crossings in MVP’s revised tables—a number dramatically at odds with the DEIS,which reports 986 waterbody crossings in its Executive Summary).
4. What MVP submitted shortly after the DEIS was issued validates the public’s assertion lastspring that the FERC should require MVP to submit a comprehensive, coordinated amendedapplication before the FERC’s preparation of the DEIS.
• On April 19, 2016, Indian Creek Watershed Association and Preserve Craig, of Craig County,VA, submitted a comment requesting that the FERC “require Mountain Valley Pipeline, LLCto submit one complete, cohesive application with corrected Resource Reports and otheraddenda in finished form and included in sequential order before the FERC contractor andfederal and state agencies complete their administrative reviews and before setting aschedule for the DEIS.” … The comment outlined some of the issues and noted: “To allowthe MVP application in its current disjointed state poses an undue burden on thestakeholders who are trying to understand the potential consequences of this pipeline on
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the environment.” (Accession # 20160419-5119, p. 1; See Attachment 2 for a description of deficiencies, inaccuracies, and inaccessibility of MVP application materials.)
• On May 6, 2016, 15 organizations and 367 individuals submitted a comment in support ofthis request. (Accession # 20160509-5043; see Attachment 3.)
• On August 10, 2016, Roanoke, Giles, and Craig Counties requested that the FERC staff directMVP to “undertake measures to coordinate the record of information it has filed” in supportof its application. (Accession # 20160810-5194.)
5. MVP’s October 14 Transmittal document disingenuously implies that MVP was providing thepublic with a “service.” In fact, their submittal impedes the stakeholders’ complicated task ofresponsibly reviewing the DEIS and MVP’s proposed route(s).
• MVP states: “By submitting the October 2016 Proposed Route at this time, interestedstakeholders will have the opportunity to review and comment on the October 2016Proposed Route at the public meetings in November 2016 … By the end of this month,Mountain Valley expects to file all revised DEIS tables with strikeouts and underlines” (MVPtransmittal p. 2).
• MVP’s October submittals make mockery of a comment period of 90-day duration whichwas established by the FERC for this DEIS. The public meetings for the MVP route werescheduled for November 1, 2, 3 in West Virginia and Virginia. Clearly, this did not provideadequate time for the public to “review and comment” on the avalanche of files posted byMVP between October 14 and November 2.
• Furthermore, the November meetings were intended for public comment on the DEIS, noton a set of revised materials from MVP that the FERC staff had not reviewed and factoredinto their environmental impact analysis.
6. To comply with the NEPA requirements, the FERC must prepare a Revised or SupplementalDEIS for the MVP Project and provide for reasonable access, review, and comment by thepublic. The public opportunity to meaningfully analyze and provide comment on the proposedroute has been undermined at nearly every stage of the MVP application.
7. One point should not be forgotten: The extended timeframe now required has not beencaused by the public. It has been caused by the inadequacies and inaccuracies of MVP’sapplication materials and by the deficiencies of the FERC/DEIS-D0272. The public should nothave to pay the price of incompetence or inattention by the Applicant or the FERC.
Affected landowners and public citizens are rightfully concerned about the project’s potential negative impacts and have every right to the considerations required by NEPA. Construction of a 42-inch high-pressure natural gas pipeline has never been attempted over the rugged terrain and the unique hydrogeological challenges and vulnerabilities of this region. The risks to pipeline integrity and the potential for environmental damage are significant. (See, for example, Dr. Ernst Kastning’s report on geologic hazards in the karst regions crossed by the MVP, Accession #20160713-5029, and Dr. Pamela
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Dodds’ assessment of hydrogeological impacts of MVP construction on watersheds of Summers and Monroe Counties in West Virginia, Accession # 20160815-5135.)
Given the significant information required by NEPA that was missing in the DEIS, as detailed in the comment by Allegheny Defense Project, Appalachian Mountain Advocates et al. cited above, and the massive amount of new and revised information submitted by the Applicant after the DEIS was issued, the draft statement is clearly “so inadequate as to preclude meaningful analysis” and therefore requires that the agency prepare and circulate a revised draft. NEPA 40 CFR §1502.9(a)
If the application for the proposed route is so difficult for the Applicant to prepare and for the FERC staff to evaluate, maybe that is another indication that the route under consideration is not a prudent or feasible alternative.
Respectfully,
Indian Creek Watershed Association Board of Directors Judy Azulay, President; Scott Womack, Vice President; Howdy Henritz, Treasurer; Nancy Bouldin, Secretary
Email: [email protected]
CC: US Environmental Protection Agency, Region 3 Mr. Jon M. Capacasa, Director, Water Protection Division, [email protected] Barbara Rudnick, NEPA Team Leader, [email protected]
Appalachian Mountain Advocates Ben Luckett, Staff Attorney, [email protected]
Attachments: 1 (pp. 5-16) – Downloaded copy of the FERC e-library page for MVP “Supplemental Information” dated October 14, 2016 (Accession #20161014-5022) 2 (pp. 17-19) – April 19, 2016 Comment of Indian Creek Watershed Association and Preserve Craig calling for FERC to require MVP to submit a comprehensive amended application before setting a schedule for the DEIS (Accession # 20160419-5119) 3 (pp. 20-33) – May 6, 2016 Comment of 15 organizations and 367 individuals in support of the ICWA/Preserve Craig request (Accession # 20160509-5043)
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FERC elibrary listing for MVP Submittal - October 14, 2016: https://elibrary.ferc.gov/IDMWS/file_list.asp (Accessed 12/9/2016). Combined file size total: 2,379.75 MB (Note: This filing was the first time in two years that MVP included descriptive titles on its files; however, FERC’s random sort of the documents makes the elibrary resource unusable.)
File List
Accession Number: 20161014-5022 Description: Mountain Valley Pipeline LLC submits Supplemental Materials
- October 2016 Proposed Route under CP16-10.
Type File Name Size
All PDF
Attachment C_Site Specific Recreational Areas-1.PDF
14823612
No description given
Attachment H - Date Responses - Public Part 1 of 2.PDF
46216226
No description given
Attachment C_01_Wetzel RSS(OCT16PR - ITF).PDF
537533
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-9.PDF
16474556
No description given
Attachment C_02_MVP Access Road Detail Sheets_Quad-2.PDF
8896600
No description given
Attachment C_08_MVP Summers County Alignment Sheets-4.PDF
17366778
No description given
Attachment C_10_MVP Giles County Alignment Sheets-3.PDF
17470134
No description given
Attachment C_09_MVP Monroe County Alignment Sheets-6.PDF
12605233
No description given
Attachment C_10_Giles RSS(OCT16PR - ITF).PDF
6034368
No description given
ATTACHMENT 1
5
Attachment C_04_MVP Braxton County Alignment Sheets-2.PDF
18846902
No description given
Attachment C_04_MVP Access Road Detail Sheets_Aerial-1.PDF
14066416
No description given
Attachment C_05_MVP Webster County Alignment Sheets-8.PDF
14285936
No description given
Attachment C_13_MVP Franklin County Alignment Sheets-2.PDF
17491480
No description given
Attachment C_07_MVP Greenbrier County Alignment Sheets-1.PDF
18826873
No description given
Attachment C_11_MVP Montgomery County Alignment Sheets-3.PDF
19341254
No description given
Attachment C_07_MVP Greenbrier County Alignment Sheets-7.PDF
14173199
No description given
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-8.PDF
15155974
No description given
Attachment E - USGS_7pt5Min_Topo_ROUTECOMPARISON.PDF
35417003
No description given
Attachment C_05_Webster RSS(OCT16PR - ITF).PDF
1426920
No description given
Attachment C_07_MVP Greenbrier County Alignment Sheets-2.PDF
16583552
No description given
Attachment C_12_MVP Roanoke County Alignment Sheets-2.PDF
13727768
No description given
Attachment C_03_MVP Access Road Detail Sheets_Aerial-4.PDF
16700849
No description given
Attachment C_07_MVP Greenbrier County Alignment Sheets-3.PDF
19470532
No description given
6
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-4.PDF
11171258
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-2.PDF
18455099
No description given
Attachment A_Analyses.PDF 2717037
No description given
Attachment C_10_MVP Giles County Alignment Sheets-4.PDF
13192681
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-6.PDF
18153925
No description given
Attachment C_03_MVP Access Road Detail Sheets_Aerial-2.PDF
16119534
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-5.PDF
14925423
No description given
Attachment C_13_MVP Franklin County Alignment Sheets-6.PDF
17640385
No description given
Attachment C_03_MVP Lewis County Alignment Sheets-7.PDF
17497719
No description given
Attachment C_03_MVP Lewis County Alignment Sheets-3.PDF
16185675
No description given
Attachment C_03_MVP Lewis County Alignment Sheets-4.PDF
17709900
No description given
Attachment C_10_MVP Giles County Alignment Sheets-1.PDF
19364291
No description given
Attachment C_12_Roanoke RSS(OCT16PR - ITF).PDF
1007554
No description given
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-6.PDF
16932180
No description given
Attachment C_04_MVP Access Road Detail Sheets_Aerial-2.PDF
17659963
7
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-8.PDF
19040756
No description given
Attachment C_14_MVP Pittsylvania H602 Alignment Sheet.PDF
2581723
No description given
Attachment C_02_MVP Access Road Detail Sheets_Aerial-1.PDF
16985415
No description given
Attachment C_05_MVP Access Road Detail Sheets_Aerial-3.PDF
17107762
No description given
Attachment C_14_Pittsylvania RSS(OCT16PR - ITF).PDF
1596853
No description given
Attachment C_05_MVP Webster County Alignment Sheets-7.PDF
20938033
No description given
Attachment C_09_MVP Monroe County Alignment Sheets-5.PDF
16893168
No description given
Attachment C_13_MVP Franklin County Alignment Sheets-3.PDF
18306556
No description given
Attachment C_08_MVP Summers County Alignment Sheets-5.PDF
17092031
No description given
Attachment C_05_MVP Webster County Alignment Sheets-1.PDF
19145757
No description given
Attachment C_05_MVP Access Road Detail Sheets_Aerial-5.PDF
4746565
No description given
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-5.PDF
17283228
No description given
Attachment C_08_MVP Summers County Alignment Sheets-3.PDF
18043089
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-3.PDF
16704761
No description given
8
Attachment C_04_MVP Braxton County H601 Alignment Sheet.PDF
2276665
No description given
Attachment C_01_MVP Wetzel County Alignment Sheets-2.PDF
17758318
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-7.PDF
19141800
No description given
Attachment C_04_MVP Braxton County Alignment Sheets-4.PDF
12618626
No description given
Attachment C_03_MVP Lewis County Alignment Sheets-8.PDF
13847311
No description given
Attachment G - Line change designations.PDF
24268
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-9.PDF
3275385
No description given
Attachment B - Reroute table.PDF 65389
No description given
Attachment C_MVP Access & Ancillary Map-12.PDF
9739628
No description given
Attachment C_13_MVP Franklin County Alignment Sheets-7.PDF
16247883
No description given
Attachment C_11_Montgomery RSS(OCT16PR - ITF).PDF
2750296
No description given
Attachment C_03_MVP Lewis County Alignment Sheets-6.PDF
18339169
No description given
Attachment C_05_MVP Webster County Alignment Sheets-5.PDF
18552208
No description given
Attachment C_07_MVP Greenbrier County Alignment Sheets-4.PDF
19211532
No description given
Attachment C_06_MVP Nicholas County Alignment Sheets-3.PDF
19668016
9
No description given
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-1.PDF
13660946
No description given
Attachment C_13_Franklin RSS(OCT16PR - ITF).PDF
4716909
No description given
Attachment C_05_MVP Access Road Detail Sheets_Aerial-4.PDF
18454581
No description given
Attachment C_MVP Ancillary Sites Detail Sheets_Aerial-2.PDF
8723388
No description given
Attachment C_05_MVP Access Road Detail Sheets_Aerial-2.PDF
17267110
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-2.PDF
18147595
No description given
Attachment C_03_Lewis RSS(OCT16PR - ITF).PDF
1745050
No description given
Attachment C_03_MVP Access Road Detail Sheets_Aerial-5.PDF
16225733
No description given
Attachment C_03_MVP Access Road Detail Sheets_Aerial-3.PDF
17196790
No description given
Attachment C_03_MVP Access Road Detail Sheets_Quad.PDF
18629287
No description given
Attachment C_08_MVP Summers County Alignment Sheets-2.PDF
16394595
No description given
Attachment C_MVP Access & Ancillary Map-10.PDF
13323140
No description given
Attachment C_14_MVP Pittsylvania Alignment Sheets-1.PDF
17577568
No description given
Attachment C_08_MVP Summers County Alignment Sheets-1.PDF
17739085
No description given
10
Attachment C_07_MVP Greenbrier County Alignment Sheets-6.PDF
20869643
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-1.PDF
15304217
No description given
Attachment C_01_MVP Wetzel County Alignment Sheets-1.PDF
19620467
No description given
Attachment C_04_MVP Access Road Detail Sheets_Aerial-4.PDF
18053932
No description given
Attachment C_03_MVP Access Road Detail Sheets_Aerial-6.PDF
18540986
No description given
Attachment C_Site Specific Recreational Areas-2.PDF
17033601
No description given
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-2.PDF
9191447
No description given
Attachment C_02_Harrison RSS(OCT16PR - ITF).PDF
3070557
No description given
Attachment C_06_MVP Nicholas County Alignment Sheets-4.PDF
19436716
No description given
Attachment C_04_Braxton RSS(OCT16PR - ITF).PDF
2477195
No description given
Attachment C_01_Construction Details_ATWS.PDF
3032543
No description given
Attachment C_05_MVP Access Road Detail Sheets(Quad).PDF
17249561
No description given
Attachment C_02_MVP Access Road Detail Sheets_Aerial-6.PDF
17771787
No description given
Attachment C_MVP Access & Ancillary Map-11.PDF
13210705
No description given
11
Attachment C_07_Greenbrier RSS(OCT16PR - ITF).PDF
7264544
No description given
Attachment C_09_MVP Monroe County Alignment Sheets-4.PDF
15559044
No description given
Attachment C_13_MVP Franklin County Alignment Sheets-4.PDF
17119171
No description given
Attachment C_02_MVP Access Road Detail Sheets_Quad-1.PDF
15672071
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-8.PDF
16830801
No description given
Attachment D - USGS_7pt5Min_Topo Oct 16 Route.PDF
23211191
No description given
Attachment C_09_MVP Monroe County Alignment Sheets-2.PDF
19864978
No description given
Attachment C_05_MVP Webster County Alignment Sheets-2.PDF
18842114
No description given
Attachment C_12_MVP Roanoke County Alignment Sheets-1.PDF
13780587
No description given
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-9.PDF
19122414
No description given
Attachment C_09_MVP Monroe County Alignment Sheets-3.PDF
17371922
No description given
Attachment C_11_MVP Montgomery County Alignment Sheets-1.PDF
19566344
No description given
Attachment C_04_MVP Braxton County Alignment Sheets-1.PDF
14678405
No description given
Attachment C_05_MVP Webster County Alignment Sheets-6.PDF
15952436
No description given
12
Attachment C_03_MVP Access Road Detail Sheets_Aerial-7.PDF
3855989
No description given
Attachment C_13_MVP Franklin County Alignment Sheets-5.PDF
17157031
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-6.PDF
16838411
No description given
Transmittal_MVP October 2016 Proposed Route 101316.PDF
129052
No description given
Attachment C_MVP Ancillary Sites Detail Sheets(Quad).PDF
7475792
No description given
Attachment C_14_MVP Pittsylvania H603 Alignment Sheet.PDF
4028215
No description given
Attachment C_02_MVP Access Road Detail Sheets_Aerial-2.PDF
19561044
No description given
Attachment C_04_MVP Access Road Detail Sheets_Aerial-5.PDF
7416412
No description given
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-3.PDF
12426053
No description given
Attachment C_06_MVP Nicholas County Alignment Sheets-2.PDF
19616561
No description given
Attachment C_03_MVP Lewis County Alignment Sheets-1.PDF
19855598
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-3.PDF
18238940
No description given
Attachment C_13_MVP Franklin County Alignment Sheets-1.PDF
17980076
No description given
Attachment C_02_MVP Access Road Detail Sheets_Aerial-7.PDF
8151315
No description given
13
Attachment C_05_MVP Access Road Detail Sheets_Aerial-1.PDF
13394260
No description given
Attachment C_11_MVP Montgomery County Alignment Sheets-2.PDF
19680967
No description given
Attachment C_06_MVP Nicholas County Alignment Sheets-6.PDF
13256552
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-7.PDF
18359416
No description given
Attachment C_10_MVP Giles County Alignment Sheets-2.PDF
19487973
No description given
Attachment C_11_MVP Montgomery County Alignment Sheets-4.PDF
6465828
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-11.PDF
2480643
No description given
Attachment C_08_Summers RSS(OCT16PR - ITF).PDF
3273839
No description given
Attachment C_05_MVP Webster County Alignment Sheets-4.PDF
20139334
No description given
Attachment C_03_MVP Lewis County Alignment Sheets-2.PDF
16050441
No description given
Attachment C_05_MVP Webster County Alignment Sheets-3.PDF
18061752
No description given
Attachment C_02_MVP Access Road Detail Sheets_Aerial-3.PDF
17872015
No description given
Attachment C_MVP Ancillary Sites Detail Sheets_Aerial-1.PDF
13192201
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-4.PDF
18901473
No description given
14
Attachment C_02_MVP Access Road Detail Sheets_Aerial-4.PDF
19646123
No description given
Attachment C_04_MVP Braxton County Alignment Sheets-3.PDF
19890719
No description given
Attachment C_MVP Access & Ancillary Map(OCT16PR - ITF)-7.PDF
17251841
No description given
Attachment C_03_MVP Access Road Detail Sheets_Aerial-1.PDF
18621827
No description given
Attachment C_04_MVP Access Road Detail Sheets_Quad.PDF
17789694
No description given
Attachment C_03_MVP Lewis County Alignment Sheets-5.PDF
18632095
No description given
Attachment C_01_MVP Wetzel County Alignment Sheets-3.PDF
2323298
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-10.PDF
17969100
No description given
Attachment C_14_MVP Pittsylvania Alignment Sheets-4.PDF
16324100
No description given
Attachment C_01_MVP Access Road Detail Sheets_Quad-1.PDF
19711195
No description given
Attachment C_14_MVP Pittsylvania Alignment Sheets-3.PDF
17274272
No description given
Attachment C_06_MVP Nicholas County Alignment Sheets-5.PDF
16843267
No description given
Attachment C_01_MVP Access Road Detail Sheets_Aerial-1.PDF
19492963
No description given
Attachment C_04_MVP Access Road Detail Sheets_Aerial-3.PDF
13180432
No description given
15
Attachment C_01_MVP Access Road Detail Sheets_Aerial-4.PDF
12903486
No description given
Attachment C_14_MVP Pittsylvania Alignment Sheets-2.PDF
18020328
No description given
Attachment C_09_Monroe RSS(OCT16PR - ITF).PDF
733484
No description given
Attachment C_01_MVP Access Road Detail Sheets_Quad-2.PDF
19361335
No description given
Attachment C_02_MVP Access Road Detail Sheets_Aerial-5.PDF
19231319
No description given
Attachment C_07_MVP Greenbrier County Alignment Sheets-5.PDF
15355180
No description given
Attachment C_06_Nicholas RSS(OCT16PR - ITF).PDF
8150082
No description given
Attachment C_02_MVP Harrison County Alignment Sheets-5.PDF
17462300
No description given
Attachment C_09_MVP Monroe County Alignment Sheets-1.PDF
18964683
No description given
Attachment C_06_MVP Nicholas County Alignment Sheets-1.PDF
18754352
No description given
Attachment H - Date Responses - Public Part 2 of 2.PDF
18361527
No description given
FERC Generated PDF
12292680.PDF 353413
16
Indian Creek Watershed Association, Inc. PO Box 711 Union, WV 24983 [email protected] 304-‐832-‐6020
Preserve Craig, Inc. PO Box 730 New Castle, VA 24127 [email protected] 540-‐309-‐9560
April 19, 2016
In the Matter of the Application of Mountain Valley Pipeline, LLC, Docket No. CP16-‐10-‐000
Request for Comprehensive Amended Mountain Valley Pipeline Application
Indian Creek Watershed Association, Inc., based in Monroe County WV and Preserve Craig, based in Craig County VA hereby request that the FERC require Mountain Valley Pipeline, LLC to submit one complete, cohesive application with corrected Resource Reports and other addenda in finished form and included in sequential order before the FERC contractor and federal and state agencies complete their administrative reviews and before setting a schedule for the DEIS.
In order for individual stakeholders and the state and federal agencies as protectors of the public interest to provide useful comment on the Mountain Valley Pipeline Application—and on the Draft Environmental Impact Statement when that is issued by the Commission—a final sequential and readable edition of the application with MVP’s most current information must be available to all in a timely manner. To allow the MVP application in its current disjointed state poses an undue burden on the stakeholders who are trying to understand the potential consequences of this pipeline on the environment.
BACKGROUND: On October 23, 2015 Mountain Valley Pipeline filed its Application for Certificate of Public Convenience and Necessity and Related Authorizations. On November 5, 2015 the FERC issued a Notice of Applications. Between that date and April 8, 2016, MVP has submitted at least 4751 pages of revisions and supplements to the original application available in public view and an undetermined analogous number of pages in privileged view. Many of these revisions were required by the federal and state agencies who found the original application to be incomplete or inaccurate in substantial sections. The result is an out-‐of-‐order concoction that stretches the definition of a coherent application beyond recognition. (Further requests by the FERC on March 31, 2016 and April 6, 2016 have called for additional information from MVP to be submitted by April 20, 2016 and April 27, 2016 respectively.)
1-‐ MVP was and continues to be delinquent in providing a complete and accurate full application, as witnessed by the FERC’s own requests for additional information, by comments of the US Forest Service and other participating agencies, as well as by comments from members of the public. MVP’s application and subsequent submittals contain multiple examples of missing, sketchy, and incorrect information.
2-‐ Material submitted subsequent to the original application is now separate from its original context. While in some cases MVP has indicated where each addition might fit into the overall
20160419-5119 FERC PDF (Unofficial) 4/19/2016 11:21:17 AM
ATTACHMENT 2
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pattern of the submission, in their current scattered and chaotic electronic state, the various additions and corrections submitted by MVP require a tremendous effort simply to assure stakeholders that they are reading the most recent data sets.
3-‐ MVP materials have largely been submitted without useful document titles or descriptive information, requiring readers to open numerous large documents listed under 11 different (untitled) Resource Reports simply to determine what is in them. Some files contain more than one document, but no ‘contents’ or index appears on opening the file; this results in important information remaining hidden unless readers scroll through every document.
WHAT IS AT STAKE? DUE PROCESS FOR THE STAKEHOLDERS: This timely and important request is necessary both before and during the DEIS comment period.
1. Before the FERC issues the DEIS: Landowners, federal and state agencies, and otherstakeholders have acted in good faith to supplement both the pre-‐filing and application docketswith information designed to correct the inaccuracies and incomplete information submitted byMVP. During the past six months it has become more and more difficult for these stakeholdersto discern the latest set of “facts” through the fog of MVP’s FERC submittals. Clearly, the FERCneeds to establish a schedule wherein stakeholders have ample time to examine a coherentapplication and make the appropriate submittals so that the FERC and its contractor, Cardno,have the most accurate information on which to base a DEIS.
We realize that the disjointed state of MVP’s documents is not the fault of the FERC. To thecontrary, we appreciate that the staff has required additional submittals from MVP in an effortto protect the environment, and we support the staff’s continuing to make such requests.However, the responsibility to coordinate these original and corrected documents must not beshifted from MVP to the stakeholders. Only one comprehensive amended application canprotect the stakeholders’ rights to a reasonable process.
2. During the public comment period for the Draft Environmental Impact Statement: Once theFERC publishes the Draft Environmental Impact Statement, members of the public will have arelatively short period of time to submit comments. Stakeholders, who are frequently affectedlandowners or leaders in their communities, will only be able to respond appropriately to theDEIS if they have already devoted lead-‐up time to become versed in both the broad issues andthe relevant details. The present state of MVP’s fragmented and disjointed submittalsdisadvantages the stakeholders in that regard.
JUST BE FAIR: The FERC has a responsibility to protect the environment by ensuring that pipeline construction complies with NEPA. Information provided by stakeholders is crucial throughout the development and analysis of a Draft Environmental Impact Statement. It is vital that the public continue to have a genuine opportunity to review and supplement the docket; however, the current state of this application clearly impedes the stakeholders from reviewing the facts and opinions as presented by MVP. We, therefore, request the following:
1. A comprehensive amended MVP application. Mountain Valley Pipeline, LLC should be requiredto submit one complete, cohesive application with corrected and inclusive Resource Reports
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and other addenda in finished form and included in sequential order before the FERC contractor and federal and state agencies complete their administrative reviews.
We note that on March 31, 2016 the FERC directed MVP to submit a similar treatment of many elements such as alignment sheets, access roads, and other maps and figures—i.e., to provide a complete set with revised contents indicated. We are essentially requesting that the FERC extend that requirement to the entire application—a new application that denotes what contents (text, figures, maps, etc.) have been revised, so that readers can work through the final text efficiently. This version of the application should make use of the features provided by the FERC online site to include adequate titles and descriptive information for all files.
2. Sufficient time for stakeholder review and input before administrative draft EIS. The FERC staffshould establish a schedule for environmental review that provides sufficient time for thestakeholders to review the comprehensive amended application and to submit additional datato the FERC, and for the FERC contractor to take that information into account before it submitsits Administrative Draft EIS for agency review.
Thank you for your consideration of this request.
Sincerely,
Indian Creek Watershed Association, Inc. Board of Directors: Judy Azulay, Scott Womack, Howdy Henritz, Nancy Bouldin
Preserve Craig, Inc. Bill Wolf, Co-‐Chair Sam Easterling, Co-‐Chair
CERTIFICATE OF SERVICE I hereby certify that I have on April 19, 2016 caused the foregoing request to be served upon each person designated on the official service list compiled by the Secretary in this proceeding.
Judith Azulay, President, Indian Creek Watershed Association
Indian Creek Watershed Association, Inc. is a non-profit corporation formed in 1996 whose mission is to protect Monroe County’s abundant and pure water.
Preserve Craig, Inc. is a non-profit corporation formed in 1991 with the support of more than 80% of Craig County households to preserve and protect our natural, historical,
and cultural resources.
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May 6, 2016
In the Matter of the Application of Mountain Valley Pipeline, LLC, Docket No. CP16-‐10-‐000
In Support of the Request to FERC to Require a Comprehensive Amended Mountain Valley Pipeline Application Made by Indian Creek Watershed Association (WV) and Preserve Craig (VA)
April 19, 2016, Accession No. 20160419-‐5119
As affected property owners and organizations, we deserve a clearly navigable version of the application that fully integrates the changes that have been made since it was originally filed. Additionally, we are asking for a schedule that allows the stakeholders ample time to review the new comprehensive version as well as provides them with an opportunity to correct MVP inaccuracies or omissions in that version BEFORE the Federal Energy Regulatory Commission completes its process of preparing the DEIS.
We are asking the FERC to protect the public interest. To allow the MVP application to continue in its current disjointed state poses an undue burden on the stakeholders who are trying to understand the potential consequences of this pipeline on the environment.
Thus, we the undersigned 15 organizations and 367 individuals, support the complete request described in the Indian Creek Watershed Association and Preserve Craig procedural motion on Docket CP16-‐10-‐000, Accession No. 20160419-‐5119.
* * * * * Organizations:
The Border Conservancy, WV Greenbrier River Watershed Association, WV Headwaters Defense, WV Kanawha Forest Coalition, WV Mountain Lakes Preservation Alliance, VA Preserve Bent Mountain, VA Preserve Giles County, VA Preserve Monroe, WV Preserve Montgomery County, VA Preserve Roanoke, VA Preserve the New River Valley, VA Protect Our Water Heritage Rights Coalition (POWHR), VA and WV Save Monroe, WV Summers County Residents Against the Pipeline (SCRAP), WV West Virginia Environmental Council, WV West Virginia Highlands Conservancy, WV
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 2]
Individuals: Catherine Abernathy, Secondcreek, WV Michael Abraham, Blacksburg, VA Anne Adams, Lewisburg, WV John Albright, Blacksburg, VA Laurie Ardison, Greenville, WV Freda Ascot, Blacksburg, VA Tina Badger, Elliston, VA Jessica Bailey, Moneta, VA Judith Bair, Sinks Grove, WV David Barrick, Newport, Va Joao & Sasha Barroso, Elkins, WV Gaea Bear, Tucson, AZ Mirijana Beram, West Union, WV Mary Berkley, Efland, NC Orus A Berkley, Talcott,, WV Anne Bernard, Boones Mill, VA Steve Bernard, Boones Mill, VA David Biesemeyer, Alderson, WV Michael Biggs, Lindside, WV John Bird, Masontown, WV Ralph Blankenship, Sweet Springs, WV Mark Blumenstein, Alderson, WV S. Thomas Bond, Jane Lew, WV Roberta Bondurant, Bent Mountain, VA Sylvia Bondurant, Union, WV Jobyl Boone, Wirtz, VA Jo Ann Boone, Moneta, VA Blair Boone, Buffalo, NY Susan Bouldin, Talcott, WV Thomas Bouldin, Alderson, WV Ashofteh, & Reinhard Bouman, Meadow Bridge, Tia Bouman Bouman, Lewisburg, Wv Fay Bouman, Meadow Bridge, WV Kirk Bowers, Charlottesville, VA Margaret Breslau, Blacksburg, VA Victor Bridges, Greenville, WV Loretta Brolsma, Greenville, WV James Broussard, Lindside, WV Dia Brousssard, Lindside, WV Roger and Bonnie Brown, Union, WV Anne Brown, Alderson, WV Ann Brown, Greenville, WV Jonathan Bruckmann, Sweet Springs, WV Wanda Buchanan, Lindside, WV
Guy Buford, Rocky Mount, VA John Bush, Blacksburg, VA Virginia Buttel, Lindside, WV Victoria Cameron, Union, WV Kevin Campbell, Adrian, WV Tammy Capaldo, Alderson, WV Michael Carter, Rocky Mount, VA Gladys Carter, Petersburg, AK Steven & MaryAnn Cass, Blacksburg, VA Roger Caulkins, Gap Mills, WV Bob Chamberland, Greenville, WV Chris Chanlett, Hintom, WV Joseph Chasnoff, Lindside, WV Russell Chisholm, Newport, VA Michael Choban, Buckhannon, WV Carol Christensen, Blacksburg, VA Lou Cjanf, Sweet Springs, WV Jenna Cleveland, Newport, VA James and Suzanne Clewell, Greenville, WV Susan Cobb, Gap Mills, WV William Coburn, Peterstown, WV MaryBeth Coffey, Bent Mtn, VA Naomi Cohen, Gap Mills, WV Jeffrey Collins, Lester, WV Chad Cordell, Charleston, WV Anni Corley, Philippi, WV Susan Cornish, Union, WV Beth Covington, Greenville, WV Frank Crabtree, Union, WV Papi Crabtree, Peterstown, WV Becky Crabtree, Lindside, WV Roger Crabtree, Lindside, WV Bonnie Cranmer, New Castle, VA Susan Crenshae, New Castle, VA Darlene Cunningham, Pearisburg, VA Mary Dailey, Meadow Bridge, WV Ellen Darden, Blacksburg, VA Jeanne Dawson, New Youk City, NY Patricia Dawson, Culloden, WV William Dawson, Culloden, WV Richard De Smarais, Union, WV. Melissa De Smarais, Union, WV Jason Dean, Waiteville, WV Meredith Dean, Waiteville, WV
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 3]
Rebecca Dean, Fayetteville, WV Marianne Deaver, Gap Mills, WV Adam DeGrafff, Lewisburg, WV Eddie Deitzler, Zenith, WV Jerolyn Deplazes, Newport, VA Nathan Deplazes, New Castle, VA Nancy Dickinson, Greenville, WV Jeff Diehl, Meadow Bridge, WV Wayne Dillon, Forest Hill, WV Deb Dix, Danville, VA Genene Dixon, lindside, WV Sarah Downer, Blacksburg, VA Dvon Duncan, mcgraws, WV Delwyn Dyer, Blacksburg, VA Rose Edington, Charleston, WV Susan Edlund, Newport, VA Susan Edwards, Newport, VA Cynthia Ellis, Charleston, WV Rhea Epstein, Blacksburg, VA Thomas Erwin, Lindside, WV Lora Feury, Carolina beach, NC Gary Finch, Waiteville, WV Elizabeth Fine, Blacksburg, VA Felecia Fischell, Hardy, VA Harmony Flora, Ronceverte, WV Virginia and David Foss, Lindside, WV Catherine Frerotte, Alderson, WV Jim Frerotte, Alderson, WV Dianne Friedman, Blacksburg, VA Kelly Fry Lane, New Kent, VA John Furrow, Severn, MD James Gaal, Hinton, WV Alecia Gann, Newport, VA Carol Geller, Newport, VA Scott Geller, Newport, VA Clarene Givens, Blacksburg, VA Tracey Godby, Unio, Wv Lucy Goldberg, Floyd, VA Diana Gooding, Weston, WV James Gore, Peterestown, WV Maryanne Graham, Huntington, WVV Conni Gratop Lewis, Charleston, WV Nan Gray, Newport, VA Robert Greenlief, Union, WV Mary Grippo, Pembroke, VA Jennifer Grover, Blacksburg, VA
Nancy Guile, Greenville, WV Joe Gullette, Union, WV Elizabeth Hahn, Blacksburg, VA Tammy Hale, Waiteville, WV Ursula Halferty, Blacksburg, VA Bonnie Hall, New Martinsville, WV Georgia Haverty, Pembroke, VA Steve Helm, Blacksburg, VA Jennifer Henderson, Blacksburg, VA Howdy & Suzie Henritz, Greenville, WV Burtus Hicks, Rocky Gap, VA John Hildreth, Pembroke, VA Michel Hileman, Blacksburg, VA Natasha Hiner, Union, WV Darlene Hines, Callaway, VA Thomas Hoffman, Pearisburg, VA Jennifer Howdock, Ballard, WV Russell Huffman, White Sulphur Springs, WV Paul Hughes, Lewisburg, WV Pamela Humphrey, Newport, VA Paula Humphreys, Lindside, WV Richard Hypes, Bluefield, WV Paul Jacoby, Caldwell, WV Robert Jarrell, Alderson, WV Dale Jenkins, Newport, VA Maury Johnson, Greenville, WV Ken & Lize Jo Johnson, Waiteville, WV Bill Johnson, Peterstown, WV Thomas Johnson, Pence Springs, WV Christopher Johnson, Union, WV Nancy Jones, Peterstown, WV Dennis Jones, Salem, VA Donald Jones, Salem, VA George Jones, Salem, VA Nancy Jones, Peterstown, WV Yvette Jones, Salem, VA Elizabeth Kayser, Catawba, VA Janet Keating, Huntington, WV April Keating, Buckhannon, WV Wanda Keffer, New Castle, VA Bridget Kelley-‐Dearing, Lexington, VA Kathy Kellogg, Gap Mills, WV Keely Kernan, Fort Loudon, PA Thomas Key, Pence Springs, WV Cinda Kinsey, Daniels, WV Gene Kistler, Fayetteville, WV
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 4]
Scott Klopfer, Newport, VA Karman Kregloe, Blacksburg, VA Gail Kregloe, Blacksburg, VA Jackson Kusiak, Hillsboro, WV Jeff LaChance, Lindside, WV Natasha Laity Snyder, Ferrum, VA Mark Laity-‐Snyder, Ferrum, VA Dorothy Larew, Greenville, WV Zane Lawhorn, Princeton, WV Allan Lehr, Alderson, WV Diane Lehr, Alderson, WV Aaron Lehr, Lewisburg, WV Larry Lilly, Sinks Grove, WV Allen Link, Newport, VA George Little, Frankford, WV Autumn Long, Wallace, WV Paul Loos, Alderson, WV Calvin Lucas, Newport, VA Terry Lyon, Vinton, VA Steve Malafy, French Creek, WV Paula Mann, Greenville, WV. Herman Mann, Greenville, WV. Carli Mareneck, Sweet Springs, WV Ryven Mareneck, Sweet Springs, WV Michael Martin, Greenville, WV Douglas Martin, Newport, VA Charles Matthews, Union, WV Michelle Maycock, Christiansburg, VA Julia Mccann, Newport, VA Leslee McCarty, Lewisburg, WV Elizabeth McCommon, Blacksburg, VA Janet McDaniel, Waiteville, WV Elora and Monte McKenzie, Talcott, WV Debbi McNeer, Forest Hill, WV Christine Merritt, Blacksburg, VA Norbert Mietus, Union, WV Dwayne Milam, Alderson, WV Dwayne Milam, Alderson, WV Jody Miles, Portland, OR Craig Miller, Lewisburg, WV Michael Miller, Union, WV Stephen Miller, Peterstown, WV Susan Mills, Forest Hill, WV Linda Mims, Bushnell, FL Peter Montgomery, Blacksburg, Va Merri Morgan, Greenville, WV
Sterl Morris, Lindside, WV Cynthia Morris, Lindside, WV Patricia Morse, Christiansburg, Va Kathleen Mundell, Union, WV Richard Mundell, Union, WV John Muth, St. Augustine, FL Gregory Nelson, Blacksburg, VA Lynda Nelson, Chrisriansburg, VA Nancy North, Hinton, WV Dana Olson, Peterstown, WV Lawrencw Orr, Elkview, WV Donna Pearsall, Blacksburg, VA John Pearson, Venice, FL Jo Perez, Alderson, WV Jana Peters, Princeton, WV Joseph Pitt, Newport, VA Donna Pitt, Newport, VA Tom Polen, Lindside, WV Vernessa Pontius, Union, WV Jean Porterfield, Newport, VA Mike Powell, Newport, VA Richard Pranulis, Alderson, WV Steven Pugh, Athens, WV Betty Pullig, Severn, MD Linda Quinn, Union Hall, VA Dale Quinn, Union Hall, VA James Raines, Lindside, WV Carl Rakes, Blacksburg, Va Ba Rea, Union, WV Elizabeth Reeder, Jumping Branch, WV Richard Reid, Blacksburg, VA Helen Renqvist, Newport, VA Dianna Richardson, Blacksburg, VA G. Paul Richter, Buckhannon, WV Donna Riley, Blacksburg, Va Shannon Ritter, Blacksburg, VA Ray Roberts, Blacksburg, VA Kathryn Robertson, Ireland, WV Michaela Robertson, San Antonio, TX Larry Rogers, Princeton, Mercer county, WV Catherine Rolling, Greenville, WV Sheila Rose, Newport News, VA Selena Ross, Rocky Gap, VA Nicholas Sabia, Waiteville, WV Elke Sabia, Waiteville, WV Roseanna Sacco, Sweet Springs, WV
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 5]
Natalie Sandell, Union, WV Robert Sarver, Lindside, WV Sam Scates, Blacksburg, VA Sandy Schlaudecker, Blacksburg, VA Elizabeth Scott, Winfield, WV Robin Scully Boucher, Blacksburg, VA David Seriff, Blacksburg, VA Cliff Shaffer, Newport, VA Jim Shannon, Union, WV Carol Sheffield, Buckhannon, WV Dawn Shepherd, Newport, VA Sharlotte Shepherd, Newport, VA Joyce Shires, Peterstown, WV Linda Shoupe, Greenville, WV Kelly Shreve, Gap Mills, WV Rich Siebold, Union, WV Kelley Sills, Greenville, WV Chris Sills, Ronceverte, WV Bridget Simmerman, Blacksburg, VA Gerald and Sharon Simpson, Sweet Springs, WV Jessica Sine, Newport, VA Diane Skellie, Union, WV Christina Skogen, New Castle, VA Katie Smith, Carollton, TX Susannah Smith, Rocky Mt, VA Scott Smith, Culloden, WV Martha Smith, Cary, NC Nadine Sonneville, Sweet Springs, WV Mark and Ann Soukup, Gap Mills, WV Sandy Sowell, Culloden, WV Hollis Spott, New Castle, VA Marcia Springston, Forest Hill, WV Janette St Vincent, Clayton, GA Angela & Wil Stanton, Christiansburg, VA Susan Steitz, Ballengee, WV David Steitz, Ballengee, WV Vivian Stockman, Spencer, WV Victoria Stone, Newport, VA Victoria Stone, Newport, VA Marsha Stone, Sweet Springs, WV David Sumrell, Rocky Mount, VA Frank and Ruth Talbott, Union, WV Kathleen Taylor, Rocky Mount, VA
Littleton Tazewell, Talcott, WV Laurel Thomas, Union, WV Stephanie & Michael Thomas, Boones Mill, VA Patricia and Robert Tracy, Blacksburg, VA Fawn Valentine, Alderson, WV Tracy Vaughan, Greenville, WV Jeanne Wahl, Lewisburg, WV David Walker, Newport, VA Richard Wallace, christiansburg, VA Burwell and Michele Ware, Greenville, WV Paul Washburn, Newport, VA James Webb, Second Creek, WV Rachel Weikle, Union, WV David Werner, Rocky Mount, VA Dennis White, Sinks Grove, WV Stephen Whitehurst, Newport, VA Mark Whitey, Beckley, WV Mary Wildfire, Spencer, WV Jo Will, Lindside, WV Lynn Williams, Newport, VA Namcy Willoughby, Blacksburg, VA Judy Winsett, Green Sulphur Springs, WV Bill Wolf, New Castle, VA Scott Womack, Union, WV April Wood, Newport, VA Robert Woodbury, Ballard, WV Jeff Woods, Princeton, WV Jim & Ann Workman, Newport, VA Susan Worrell, Roanoke, VA Luther Wray, Callaway, VA Robin Wright, Sinks Grove, WV Anne Wright, Covington, VA Laurine Yates, Union, WV Laura Yokochi, Salem, WV David Yolton, Newport, VA Jill Young, Lindside, WV M Young, Second Creek, WV Anna Ziegler, Hinton, WV Carl E. Zipper, Blacksburg, VA
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 6]
Additional Comments from Individuals: “It is obvious that we who live, work, and own property in this area are interested and concerned about the transparency of the MVP application. Please help us to have an open communication.”
—Anne Adams, Lewisburg, WV “Projects of this magnitude impact the lives of thousands. We citizens have every right to know exactly what these projects entail; they can be life altering for all in the counties in which they are embedded.”
—Laurie Ardison, Greenville, WV “Future pipelines are a travesty against the environment and citizen's rights!”
—Anne Bernard, Boones Mill, VA “This pipeline would be a disaster for us all, environmentally, and personally. We just got a new well drilled on the edge of our property, after waiting many years to get it, and carrying our drinking water from another source. It is right next to the pipeline's proposed path, which runs across 144 bodies of water in our county alone!”
—Steve Bernard, Boones Mill, VA “Those of us who have sacrificed income and professional opportunities to live in a rural community away from industrial development are now threatened with one of the most polluting and disruptive of industries coming into communities we have built and across land we have owned, nurtured and protected. The traffic, the noise pollution, light pollution, air pollution and water pollution that we choose to live away from now tells us we do not have a right to say "no" to their plans to place pipelines, pumping stations and roads only they will use and profit from on land we have owned for fifty years. It is not right!”
—David Biesemeyer, Alderson, WV “We would also like to now the total acres of land that will be disturbed by this pipeline and a full accounting of the acres of forest that will be removed as well as a comprehensive accounting of all wildlife habitat that will be destroyed”
—Mark Blumenstein, Alderson, WV “I am currently selling organically grown vegetables & free range eggs to Monroe Farm market. My water comes from the water table. The proposed pipeline will be detrimental to my business.”
—Loretta Brolsma, Greenville, WV “The current infrastructure available to transport natural gas to the coast so the gas industry can make money selling gas to Europe is more than sufficient to meet their needs. The proposed pipelines -‐ wherever they would go, would do nothing for WV except devalue our land, threaten our water, poliute our air, add methane to the toxic carbon mess, and leave more WV communities devastated by the fossil fuel industry that is already declining. This is an industry in decline. Rather than waste more money on out of date technology, why not invest in the future?”
—Anne Brown, Alderson, WV
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 7]
“It is next to impossible to track this lost animal through its self created maze! I am in complete agreement with this request. I could say more but you covered it in your request.”
—Guy Buford, Rocky Mount, VA “It would only be common sense for MVP to consolidate the pertinent material in one application form rather than giving it piecemeal which obscures the matter in confusion.”
—Virginia Buttel, Lindside, WV “I do not understand, why FERC that manages the shoreline of Smith Mountain Lake is even considering the MVP. The MVP should not be granted a permit on the fact they are following the watershed in Franklin County VA. The current route of this proposed pipeline will lead to more sedimentation in Smith Mt. Lake. Sedimentation is a serious issue already. Do not grant MVP a permit.”
—Michael Carter, Rocky Mount, VA “Although I am not currently living in the area, I grew up in Monroe County. I am one of the owners of a farm in Greenville, along Indian Creek. MVP needs to submit comprehensive information, for the sake of all those involved in this matter.”
—Gladys Carter, Petersburg, AK “The thousands of pages of corridor data at the Summers County Library were in illegibly small font—even with my glasses on.”
—Chris Chanlett, Hintom, WV “My children own land in Greenville and I own a farm in Sandstone. We want to protect and preserve the natural resources of West Virginia.”
—Carol Christensen, Blacksburg, VA “I urge you to force MVP to stop jerking us around with complicated paperwork that no one can decipher-‐-‐-‐it's a waste of everyone's time and, sadly, that seems to be MVP's purpose. Doesn't FERC work for the People?”
—Beth Covington, Greenville, WV “Transparency, completely informed consent—these are requirements in a democracy .”
—William Dawson, Culloden, WV “PLEASE don't let this pipeline happen!”
—Jeff Diehl, Meadow Bridge, WV “WE do not want the pipe line at all in WV.”
—Genene Dixon, Lindside, WV “I for one have had difficulty accessing materials in your (FERC Library).” —Delwyn Dyer, Blacksburg, VA
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 8]
“Please insure that we have a clear understanding of what MVP is actually applying for. Thank you.”
—Rose Edington, Charleston, WV “It seems honoring this request will ultimately help FERC navigate through their review process and help late comers become up-‐to-‐date in their attempts to become informed decision makers. Without it, it would appear that FERC employees may have a conflict of interest and should be subject to the same $5K investment disclosure that Virginia state elected officials are required to report. Remember, NPR reported just last week that 3 Virginia elected officials each held over $500K worth of stock in Dominion Power.”
—Felecia Fischell, Hardy, VA “All sciences have their taxonomic order. Soil Taxonomy relates mineralogy, climate, time reference, topography, organisms to what exists in a place. Soil does not behave like rock. Soil is alive and behaves uniquely. Soil Taxonomy gives us an idea of how a soil could behave when the mineralogy is named (if the soil is likely to expand when wet, and if the soil has a high clay content). The United States Soil Taxonomy can be applied, and is, Worldwide. Taxonomy is not something to "leave out" of a Federal document.”
—Nan Gray, Newport, VA “Clearly labeled maps are also necessary, please. Maps I have seen are very vague and do not include names of communities, streams, developments and other features likely to be impacted by the amended routes. It is difficult to impossible to determine the impact on our homes, farms, forest and local parks and recreational areas as well as fragile ecosystems and habitats.”
—Jennifer Grover, Blacksburg, VA “The area which I live in is one of the last wilderness areas of WV. It has many streams that feed into Potts Creek that feeds into the Chesapeake Bay. Also many rare animals and plants are in the area.”
—Tammy Hale, Waiteville, WV “Could not agree more with this request and think FERC has an ethical obligation to those affected by the pipeline to review a clear, readable, up-‐to-‐date version of the application-‐-‐and enough time to review and respond.”
—Jennifer Henderson, Blacksburg, VA “This is a very reasonable request.”
—John Hildreth, Pembroke, VA “It's past time that citizens of this country make their opinions known AND supported/implemented by the Public SERVANTS employed to excessive those majority opinions. Stop abrogating your obligations by doing what the oil and gas industry (including the politicians under their control) and do what is right for our environment, communities and citizens.”
—Darlene Hines, Callaway, VA
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 9]
“We are entitled to information that would affect our communities.” —Thomas Hoffman, Pearisburg, VA
“As someone who has worked with environmental consulting firms for MVP. I can tell you first hand, that every time they take a short cut, the people, environment, and waters suffer. I believe MVP to be somewhat resposible, but they will take short cuts if you let them. And then all West Virginians suffer. I have seen it first hand. There must be ample time, and considerate thinking to mitigate environmental impacts. Please please help ensure that best practices and precautions are used...for my sake, your sake, and our children!”
—Paul Hughes, Lewisburg, WV “Please require the MVP group to reference your 24 Dec 2015 requests for clarification by the page and paragraph number in your document. Then we can actually evaluate MVP response and be certain the data is both provided and accurate (as we find many things are neither).”
—Pamela Humphrey, Newport, VA “As an affected landowner, I have been trying to read this, jumbled mess of an application. It is impossible to follow or understand As a former educator, if a student turned something like this in they would receive an incomplete and it would be returned to be corrected and made readable. MVP as a major corporation and should be held to the highest of standards. Too many lives and livelihoods are at risk for them not to be held to this high standard.”
—Maury Johnson, Greenville, WV “Private profit for gas pipeline companies is NOT the Public Interest. Clean water, breathable air, safety and quality of life is the Public Interest.”
—Jackson Kusiak, Hillsboro, WV “This needs to be a clear and transparent process.”
—Jeff LaChance, Lindside, WV “And as there are more changes, and I feel sure there will be, we also want to be informed of those changes before they are made.”
—Dorothy Larew, Greenville, WV “Is the process designed to confuse the property owners on purpose or merely by bureaucratic design?”
—Zane Lawhorn, Princeton, WV “Earlier releases contained mis-‐information, locations were listed in the wrong states, meeting places were in the wrong localities. Little information from MVP is now being followed by reams of information that makes comprehension and intent difficult to ascertain. Many thanks.” —Douglas Martin, Newport, VA
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 10]
“Make this document accessible and at least up to report document standards with clear labeling, etc. It is important that residents and area stakeholders be able to understand the planning and environmental impacts of the project described in the application.”
—Michelle Maycock, Christiansburg, VA “This should be done for the entire route. They are surveying now in Newport, VA and it is maddening to get a straight answer on when and where .....and if things change or difficulties in the site are noted, we get no info. Through extreme efforts and different messages, I think I finally got a real answer, maybe.”
—Julia Mccann, Newport, VA “Seems to me there is an abundance of natural gas at rock-‐bottom prices. No need to risk damaging our way of life with a pipeline that won't benefit anyone but the company building it.”
—Debbi McNeer, Forest Hill, WV “It is extremely difficult to comprehend multiple reports that are re-‐submitted then updated, then resubmitted again. An issue of such importance for the thousands of land owners, the numerous long term environmental concerns, and the permanent change to parks and property necessitates one coherent report for property owners and all concerned parties to review and comment on as a whole...not disjointed parts. It is imperative that FERC compel the applicants for the MVP to submit a complete and corrected application, and provide ample time for the public and effected property owners to thoroughly read the corrected application, and have ample opportunity to submit comments/concerns.”
—Dwayne Milam, Alderson, WV “As residents of West Virginia we ask for help in keeping our state and residents free from outside interests possibly destroying what we, the residents have.”
—Susan Mills, Forest Hill, WV “It is as if you have deliberately made it impossible for the public and especially stakeholders to understand the application. It is unacceptable.”
—M Morgan, Greenville, WV “MVP MUST be more concise in their answers to FERC!!”
—Cynthia Morris, Lindside, WV “To make informed decisions, we should have access to clear and legible communications”
—Patricia Morse, Christiansburg, Va “This pipeline will mean nothing but destruction to WV and to our precious water. It would be criminal to allow it.”
—Kathleen Mundell, Union, WV
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 11]
“Say no to gas lines crossing Peters Mountain and the St Clair fault, which runs along the top of the mountain which supplies Monroe Counties water.”
—Richard Mundell, Union, WV “Everything the government publishes should be in colloquial English.”
—John Muth, St. Augustine, FL “This carnage is ruining a wobderful area. Stop”
—Lynda Nelson, Chrisriansburg, VA “Preserve Giles County completely supports this petition. The changing routes, the amended, and then amended again, and again, data and rhetoric have made it virtually impossible to determine what MVP is thinking as they try to weave and muscle their pipeline through an impossible route, avoiding one hazard just to pass closer to another. We encourage FERC to tell MVP to start over and try to find another route with fewer hazards.”
—Donna Pitt, Newport, VA “The state of WV does not have the DOT/legal/oversight infrastructure required for heavy industry to be a good neighbor. Our region and it's legal/regulatory void is very much different from Oklahoma/Texas. For example, heavy trucking in OK and TX is required to be clearly marked, with loads covered, Mansfield bars, fully licensed and no jake brakes in towns. And no "ghost" trucking companies. The flat land provides many options for road detours when trucks overturn or loose their loads. The FERC needs to do it's job and remember they are there to serve the people, not private industry.”
—Vernessa Pontius, Union, WV “MVP's gross incompetence and obfuscation during the filing process and EQT's record of criminal negligence with their operational pipelines should raise serious concerns about the MVP principals' credibility and should be noted in any FERC ruling on the pipeline filing.”
—Carl Rakes, Blacksburg, Va “Please to allow equal access to MVP reports and changes in one comprehensive document for review by effected property owners and the concerned public.”
—Ray Roberts, Blacksburg, VA “Property owners cannot get a straight answer out of Mountain Valley Pipeline about anything. We are tired of being pressured, bullied and lied to about their path, their rights, eminent domain, etc. We should have the right to read and understand their application, but MVP's documents are as impossible to organize as the environmental information they have provided is vague and inaccurate. We need a voice at the table and we are appealing to FERC to insist on a level fair playing field for all parties involved. This issue is too important and the consequences of this pipeline too devastating to allow this incomplete application to be rubber stamped into approval. Thank You.”
—Kathryn Robertson, Ireland, WV
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 12]
“I really want to know what the actual proposal is please. This will affect me directly.” —Jo Perez, Alderson, WV
“From the dealings my family has had with the MVP it appears that their purpose is to obfuscate regarding their intentions for the route, the protection of the environment, the watershed, the protection of endangered species, the dates they intend to access properties, the people they claim have give signatures permitting access to property for the purpose of surveying, the final destination of the gas that will be transmitted through the pipeline, and the benefits they claim will come to local communities. While claiming to want to work with stakeholders and communities they are either being disingenuous or woefully unprepared to communicate and execute their plans. Either way stakeholders and communities being affected by a business that wants to make a profit by being given the special privilege of the use of emminent domain to destroy this many lives for their own profit should be required to provide information about their plans unless they are deliberately trying to make the information unclear and/or difficult to obtain.”
—Sheila Rose, Newport News, VA “We're a small but proud little community that enjoys our rural lifestyle. We don't want to see it disrupted or put at risk for the sake of this pipeline. Thank you for listening to us.”
—Robert Sarver, Lindside, WV “MVP is projected through some of the most karst topography found in the state of Virginia, the thin-‐unstable limestone could give way to the weight of the pipeline at any time. This risks contamination of the New River Watershed, which supplies clean water to a huge section of Virginia. The majority of the state of Virginia is against this pipeline, and its route. Since when does our Federal Government not stand with the majority of its citizens, this is a democracy, we must listen to the people.”
—Sam Scates, Blacksburg, VA “The route goes right through a sink hole area so needs to not go there, or anywhere for that matter. My water source is at risk!”
—Sandy Schlaudecker, Blacksburg, VA “Clear, concise, and organized material reflect a company that is correctly run. MVP is not exhibiting traits that make me believe that it will be able to handle the complexities of building a pipeline through my watershed, my community, or my state.”
—Robin Scully Boucher, Blacksburg, VA “Even though I currently live in NC my family farm is on Hans Creek Rd in Monroe County. My heart and soul is in and with that land. I love it and will fight for it.”
—Martha Smith, Cary, NC “Do the right thing to inform and protect West Virginians!”
—Sandy Sowell, Culloden, WV
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 13]
“Though not a resident of West Virginia, I am deeply connected to its communities and places and have been for decades.”
—Janette St Vincent, Clayton, GA “Eminent domain is meant to be used for bona fide beneficial land uses for things like highways and schools that can be proven to benefit affected communities. We in Giles County have submitted 100s of pages of environmental, economic, social, historical, and ecological testimony to FERC, prepared by highly knowledgeable academicians, researchers, and other interested individuals with citations. MVP responds with single page fossil fuel industry-‐produced responses with no factual back up -‐ for all intents and purposes they say "it"s this way because we say it is." MVP will benefit the corporations involved and their shareholders, not Virginians and West Virginians. They obfuscate and outright lie out of greed. Fracked gas is not the fuel of the future -‐ fracking production produces huge amounts of methane. Solar, wind, geothermal, wave -‐ sustainable energy needs to be undertaken NOW, not in 15 years when the gas is depleted and sold to overseas and the environment and communities raped. It's abundantly clear that the corporations proposing the MVP are invested in obscuring their agendas and the fcts about the process by making it difficult, if not impossible, to glean accurate information on the process with its myriad changes; FERC filings include maps and charts that aren't readable. This is totally unacceptable inits entirety.”
—Victoria Stone, Newport, VA “I am concerned that every precaution be taken not to disturb the aquifers. A clear comprehensive plan is in everyone's interests.”
—Fawn Valentine, Alderson, WV “We request that FERC fulfill its function and duty to protect the people and the land from corporate enterprises that have the unintended consequences of laying waste to our precious clean waters and destabilizing the sanctuary of our homes.You are our advocate and protector.”
—Jeanne Wahl, Lewisburg, WV “Enough of the smoke & mirrors!”
—David Walker, Newport, VA “Based on my review of publicly available documents posted by Mountain Valley Pipeline, LLC, to FERC Docket CP16-‐10-‐000, the number of errors and inconsistencies, as well as incomplete responses to FERC minimum and specific requirements for information render that body of work unfit for evaluation as part of the Draft Environmental Impact Statement process.”
—Paul Washburn, Newport, VA “Us simple people cannot possibly understand the constant questions and responses from MVP staff. This is impossible to keep up with!”
—David Werner, Rocky Mount, VA
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[May 6, 2016, In Support of the Request for a Comprehensive Amended MVP Application, p. 14]
“My farm and streams very close to Monroe. About 3 miles . My water comes from Monroe. Cove Creek and Sweet Springs”
—Anne Wright, Covington, VA “MVP does not get to bury us in revisions and updates. They must be required to file a clear, orderly, indexed application.”
—Jill Young, Lindside, WV
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