· 625 Liberty Avenue, Suite 1700 | Pittsburgh, PA 15222 844-MVP-TALK |...

625 Liberty Avenue, Suite 1700 | Pittsburgh, PA 15222

844-MVP-TALK | [email protected]

www.mountainvalleypipeline.info

January 15, 2016

Ms. Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

888 First Street NE

Washington, DC 20426

Re: Mountain Valley Pipeline, LLC

Docket No. CP16-10-000

Responses to Data Requests issued December 24, 2015

Dear Ms. Bose:

On December 24, 2015, the Office of Energy Projects (“OEP”) of the Federal Energy

Regulatory Commission (“Commission”) issued data requests to Mountain Valley Pipeline,

LLC (“Mountain Valley”) on behalf of itself and other federal and state cooperating agencies

with respect to Mountain Valley’s certificate application in Docket No. CP16-10-000. On

January 13, 2016, Mountain Valley submitted a letter to the Commission stating that Mountain

Valley would begin submitting responses to the data request and provide a more detailed

schedule for any outstanding responses on January 15, 2016.

Mountain Valley submits herewith responses to a large majority of the data requests issued on

December 24, 2015. For any responses or responsive materials that are currently outstanding,

Mountain Valley has indicated the projected filing date in the response section of the

respective data request. Mountain Valley anticipates filing a substantial portion of the

outstanding items by January 22, 2016, one week from today, and another portion in February

2016. Mountain Valley will continue to update OEP regarding any schedule changes.

If you have any questions, please do not hesitate to contact me at (412) 553-5786 or

[email protected]. Thank you.

Respectfully submitted,

Mountain Valley Pipeline, LLC

Matthew Eggerding

Counsel, Midstream

cc: All Parties

Paul Friedman, OEP

Lavinia DiSanto, Cardno, Inc.

Doug Mooneyhan, Cardno, Inc.


Mountain Valley Pipeline Project


Responses to Environmental Information Request

Dated December 24, 2015

1


Request:

General

1. File copies of, or provide an anticipated submittal date for, all outstanding plans and

studies that Mountain Valley indicated were pending, such as, but not limited to:

a. Project-wide Erosion and Sediment Control Plan (ESCP);

Response:

The Erosion and Sediment Control Plans for the project are in development. Due

to the differing state and regulatory requirements, the plans will be produced in

two applications, one for Virginia and one for West Virginia. Mountain Valley

expects to submit it by February 26, 2016.

b. Karst-specific ESCP;

Response:

Karst-specific erosion and sedimentation control plans will be submitted to FERC

as part of the overall Project erosion and sedimentation control plan. Mountain

Valley expects to submit it by February 26, 2016 (see response to subpart (a)).

c. a track change version of proposed changes to the FERC staff’s Wetland and

Waterbody Construction and Mitigation Procedures (FERC’ Procedures, May

2013 version) and the Upland Erosion Control, Revegetation, and Maintenance

Plan (FERC’s Plan, May 2013 version);

Response:

Mountain Valley Pipeline will adopt the FERC staff’s Wetland and Waterbody

Construction and Mitigation Procedures (FERC’s Procedures, May 2013 version)

and the Upland Erosion Control, Revegetation, and Maintenance Plan (FERC’s

Plan, May 2013 version) during construction and restoration of the Project with

the exception of the stream and wetland variance requests identified in Resource

Report 2 tables 2-A-3, 2-A-4, and 2-B-2.






2

d. Spill Prevention, Control and Countermeasures Plan;

Response:

The Spill Prevention, Control and Countermeasures Plans for the project are in

development. Due to the differing state and regulatory requirements, the plans

will be produced in two applications, one for Virginia and one for West Virginia.

Mountain Valley expects to submit it by February 26, 2016..

e. Compensatory Wetland Mitigation Plan;

Response:

A compensatory wetland mitigation plan is in development. Mountain Valley

expects to submit it by February 26, 2016.

f. Project Blasting Plan;

Response:

A Draft Blasting Plan was included as Appendix 6-B in Resource Report 6 of

Mountain Valley’s application. As stated in Section 6.4.1.1 of Resource Report 6,

Mountain Valley, per Section III of the FERC Plan, will develop the Final

Blasting Plan in consultation with appropriate agencies. The construction

contractor will prepare a detailed Blasting Plan for each distinct blasting area and

submit it to Mountain Valley for approval. Those final blasting plans will be filed

with the Commission prior to construction. The construction contractor will also

be required to apply for and comply with any state or local permitting regulations.

g. Dust Suppression Plan;

Response:

A Fugitive Dust Control Plan is included in Attachment General 1-g.

h. Migratory Bird Habitat Conservation Plan;

Response:

The Project Migratory Bird Habitat Conservation Plan is in development.

Mountain Valley expects to submit it by January 22, 2016.






3

i. Unanticipated Discovery of Contamination Plan;

Response:

An unanticipated discovery of contamination plan will be submitted to FERC as

part of the overall Project SPCC plan. A final SPCC plan is in development

Mountain Valley expects to submit it by February 26, 2016 (see response to

subpart (d)).

j. Mine Subsidence Plan;

Response:

The Project Mine Subsidence Plan is in development. Mountain Valley expects

to submit it by January 22, 2016.

k. Geotechnical Landslide Evaluation;

Response:

Mountain Valley Pipeline has completed the field reviews of the 26 areas listed in

Table 6.4-6. The results and recommendations from said reviews, including

mitigation measures, are being compiled. Mountain Valley expects to submit it

by February 26, 2016.

l. Karst Area Geology and Geotechnical Report;

Response:

The Karst Area Geology and Geotechnical Report was a remnant from an earlier

reporting format for Mountain Valley Pipeline. The referenced document

currently does not exist. With the October 2015 filing, the report was integrated

into Resource Report 6 text.

m. Plan for the Unanticipated Discovery of Paleontological Resources;

Response:

Attachment General 1-m contains a Plan for the Unanticipated Discovery of

Paleontological Resources. It identifies the paleontological setting, procedures,

and training requirements for reporting and assessing the significance for the

unanticipated discovery of paleontological resources.






4

n. Cultural Resources Avoidance, Testing, and Treatment Plans;

Response:

Site avoidance measures will be presented as a formal plan to FERC, WVDCH

and VDHR after the completion of Phase I and II surveys in the late spring of

2016. For sites determined eligible for listing in the National Register of Historic

Places that cannot be avoided, treatment plans to mitigate adverse effects will be

developed in consultation with the State Historic Preservation Officer (SHPO),

FERC, the Advisory Council on Historic Preservation and other consulting parties

and documented in a Memorandum of Agreement.

o. Historic Properties Management Plan;

Response:

A draft Historic Properties Management Plan (HPMP) is in development. Pending

SHPO review and concurrence of all applicable cultural resource report materials

(including addendum reports which address areas previously not accessible for

cultural resources survey), the HPMP will be finalized and filed with FERC.

Mountain Valley anticipates that the HPMP will be finalized in late spring of

2016.

p. Trash Management Plan; and

Response:

The Trash Management Plan will be site-specific and the responsibility of the

construction contractor to develop. This will be submitted to the Commission

with the Implementation Plan.

q. Plans of Development for crossing the Jefferson National Forest.

Response:

The Preliminary Plan of Development for the Jefferson National Forest is in

development. Mountain Valley expects to submit it to the United States Forest

Service and FERC by January 22, 2016.

Respondent: Megan Neylon

Position: Senior Environmental Coordinator

Phone Number: 724-873-3645

Date: January 15, 2016






5


Request:

Resource Report 1 – General Project Description

1. Fully describe all project components, and include an assessment within all applicable

resource reports (RRs), such as a 1,000-foot-long, 24-inch-diameter pipe needed for the

Columbia WB Interconnect, 475 feet of suction and discharge pipe needed to connect at

the Bradshaw Compressor Station, and any other pipe or facilities needed to connect to

aboveground facilities or for any other purpose.

Response:

WB Interconnect:

This station will deliver natural gas from the Mountain Valley H-600 pipeline into Columbia Gas

Transmission (Columbia) Line WB and WB-5. This interconnect will contain a Columbia

electronics building (used to house equipment such as gas chromatographs, flow computers and

communications equipment, etc.) a Mountain Valley Pipeline electronics building (used to house

equipment such as a flow computer and communication equipment), and a meter building and a

control valve building. Interconnect piping will be below grade except for connecting to above

grade equipment, which includes two (2) gas filter separators, two (2) 16” gas ultrasonic meters,

three (3) 12” overpressure protection control valves and three (3) 12” flow control valves. The

station will be surrounded by a chain-link fence. The Columbia tap location, on the WB pipeline

right-of-way, is approximately 1,000 feet east the Mountain Valley Pipeline H-600, requiring the

approximate 1,000 feet of 24-inch diameter piping.

Descriptions of the meter stations and suction/discharge piping are located in the response to

Resource Report 1, Request 7. Descriptions of the mainline valves and suction/discharge piping

are located in the response to Resource Report 1, USEPA Request Page 1-9.

Bradshaw: The 42-inch suction piping will come off of the Mountain Valley pipeline at

approximate MP 2.8 and extend approximately 550 feet to the Bradshaw pig receiver. The 42-

inch discharge piping will come off of the pig launcher and extend approximately 550 feet back

to the Mountain Valley pipeline. See the response to Resource Report 1, Request 23 for updated

plot plans.

Harris: The 42-inch suction piping will come off of the Mountain Valley pipeline at approximate

MP 77.5 and extend approximately 100 feet to the Harris pig receiver. The 42-inch discharge

piping will come off of the pig launcher and extend approximately 100 feet back to the Mountain

Valley pipeline. See the response to Resource Report 1, Request 23 for updated plot plans.






6

Stallworth: The 42-inch suction piping will come off of the Mountain Valley pipeline at

approximate MP 154.2 and extend approximately 100 feet to the Harris pig receiver. The 42-

inch discharge piping will come off of the pig launcher and extend approximately 100 feet back

to the Mountain Valley pipeline. See the response to Resource Report 1, Request 23 for updated

plot plans.

All impacts associated with these facilities have been included in the relevant resource reports.

Respondent: Ricky Myers

Position: Engineering Manager








7


Request:


2. Provide details for the interconnect with Roanoke Gas as described in section 1.1.2 such

as milepost (MP), volume of gas delivered, a plot plan, and other pertinent details.

Provide complete descriptive information and maps for any “interconnecting piping” to

any facility which appears to be currently undetermined as discussed in section 1.2.2.3

and ensure that relevant data is provided for such facilities in all of the RRs. Provide

actual or estimated receipt or delivery volumes for each interconnection. In addition,

section 1.2.2.3 stated the project would have four interconnects; however, the addition of

the Roanoke interconnection would be five. Clarify the correct number of

interconnections.

Response:

There are four (4) interconnects included in the scope of the Mountain Valley Pipeline Project:

Mobley Interconnect, Sherwood Interconnect, WB Interconnect, and Transco Interconnect. An

interconnect consists of station piping, gas conditioning equipment (i.e. filter separator), custody-

transfer flow meter(s), flow control valves, overpressure protection control valves, isolation

block valves, and an electronics building to house instrumentation and communication

equipment. These interconnects also include the pipeline tap. Interconnects are designed,

installed, operated, and maintained by Mountain Valley.

There are two (2) taps included in the scope of the Mountain Valley Pipeline Project: Roanoke

Gas and Webster. For a tap, Mountain Valley designs and installs the pipeline tap, tap valve and

appurtenant piping to the edge of the Mountain Valley permanent right-of-way. The

interconnecting company, such as Roanoke Gas, is responsible for land acquisition and

applicable permits and approvals. The interconnecting company is also responsible for the

interconnect design and installation at its cost.

The Roanoke Gas tap is preliminarily sized for 5,000 Dth/day. No additional facilities will be

installed by Mountain Valley. Roanoke Gas will be responsible for designing and installing at

their own cost and to Mountain Valley’s specifications all necessary equipment for the

interconnect. A generic representation of a transmission delivery interconnect is shown in

Attachment RR1-2 hereto. Roanoke Gas will be responsible for land acquisition and obtaining

all required permits and approvals.

At this time, a definitive tap location in Franklin County, Virginia has not been finalized. The

tap location is preliminarily reflected at approximate MP 262.67 as shown in Resource Report 1,






8

Figure 1.2-1 (project map) and Resource Report 1, Appendix 1-C (contractor yards, page 10 of

10). Although a preliminary plot plan has not been developed due to the unknown specific site

specifications, several equipment alignment options are possible depending on the acquired site

parcel. An approximate plot size to accommodate the necessary equipment shown in Attachment

RR1-2 and the associated construction area would be approximately one acre. Final location will

be determined by Roanoke Gas and Mountain Valley and will be based on criteria such as

terrain, existing land uses, size of the parcel, proximity to residences, and land acquisition.

The Webster tap will also be constructed by Mountain Valley and handled in a similar manner as

explained above for Roanoke Gas. The Webster Interconnect equipment will be designed and

constructed as part of the Equitrans Expansion Project (Docket CP16-13-000) and will

interconnect Equitrans Pipeline H-306 with Mountain Valley Pipeline H-600. The Webster tap

location is at approximate MP 0.8 and is preliminarily sized for 630,000 Dth/day.










9


Request:


3. Describe the nature, purpose, capabilities, dimensions, height and width (in feet), and

design of each communication tower at the three compressor stations. Include a typical

plan and profile drawing. Clarify whether the towers would emit any light or sound.

Include an analysis of impacts from construction and operation of the towers on

environmental resources (such as visual resources, migratory birds, and bats), and

measures to avoid, reduce or mitigate impacts in all applicable RRs. Identify any permits

or approvals needed for the communication towers, and the status of applications, and

include the regulations either in table 1.7-1 or in a stand-alone table.

Response:

Each of the three compressor stations will have a 60 foot tall communications tower for the

purpose of supporting one to three radio antennas for communications throughout the

compressor station facilities. The tower, with a concrete foundation, is made up of three vertical

posts connected by reinforcing bars for the entire height. Attachment RR1-3a is a typical

drawing with dimensions and installation details. Attachment RR1-3b is a picture to serve as an

example and assist in visualizing the description. There are no lighting or other devices

supported by these towers, therefore, they are not a source of light or sound. Each tower will be

located within the compressor station fence and will not require additional earth disturbance and

require no permits, or operating licenses. These towers will be operated in compliance with

Federal Communications Commission, Part 15 requirements. A visual assessment of visual

impact of these towers is being provided in response to Resource Report 8, Request 30. See also

the response to Resource Report 3, Request 15 regarding migratory birds and bats.










10


Request:


4. Describe measures that would be implemented to protect forest, waterbodies, wetlands,

residences, and other sensitive resources in areas where slash and/or brush would be

burned. In terms of air quality, indicate if burning would affect any non-attainment air

basins. Summarize all applicable local, state, and federal laws and regulations regarding

the burning of brush and slash and include the regulations either in table 1.7-1 or in a

stand-alone table.

Response:

As stated in Section 1.4.1.1, burning will be on a case-by-case basis and will not occur within the

Jefferson National Forest unless required by the United States Forest Service. All burning will be

done in accordance with the applicable permits and local ordinances, which will be determined

as areas are identified where burning may occur. A discussion on state regulations pertaining to

burning was provided in Section 1.7 of Mountain Valley Pipeline’s application. Burning will

occur in upland areas away from residences as well as stream and wetland resources.

A Fire Prevention and Suppression Plan was included in Resource Report 1, Appendix 1-H of

Mountain Valley Pipeline’s application. The plan was developed based on the experience of

Mountain Valley Pipeline’s operator in working throughout the region and identifies best

management practices for the burning of brush and slash in the construction right-of-way.

Mountain Valley Pipeline has included an updated Fire Prevention and Suppression Plan as

Attachment RR1-4. Mountain Valley updated the plan to clarify that the Project will not affect

the George Washington National Forest.

Resource Report 9 of Mountain Valley Pipeline’s application stated that all counties crossed by

the Project are in attainment for all criteria pollutants. Therefore, no substantial impacts are

anticipated from burning activities, should they occur.

Respondent: John Uhrin

Position: Construction Director








11


Request:


5. Section 1.4.1.1 stated that brush/slash not burned may be chipped and blown off the

right-of-way in accordance with landowner agreements. Indicate the measures that

Mountain Valley would implement to make certain that chips blown off the right-of-way

would not have adverse impacts on nearby wetlands, streams, sensitive habitats, and

special-status species.

Response:

A 300-foot survey corridor was surveyed for potential rare, threatened and endangered species,

cultural resources, and wetland and waterbody resources during the field survey effort. This data

will be utilized during the chipping process to ensure that resources are protected from potential

adverse impacts resulting from chips being blown off the right-of-way. Mountain Valley Pipeline

will not blow chips into these sensitive areas.










12


Request:


6. Provide the following for the back-up very small aperture terminal (VSAT) service:

a. a description of the equipment needed for this service (including dimensions); and

b. locations for all VSAT equipment.

Response:

a. The VSAT system is comprised of a 4foot diameter Prodelin dish antenna

mounted to a 2.5-inch rigid metal conduit approximately 6.5 feet above grade and

connected with RG6 coaxial cable to an iDirect 3000 modem installed in an IT

cabinet. Attachment RR1-6a is a typical drawing with dimensions and installation

details. Attachment RR1-6b is a picture to serve as an example and assist in

visualizing the description.

b. VSAT services are currently planned at the Bradshaw Compressor Station, Harris

Compressor Station, Stallworth Compressor Station, Mobley Interconnect,

Sherwood Interconnect, WB Interconnect, Transco Interconnect, and all thirty-six

of the mainline valve locations.










13


Request:


7. Provide a detailed description of the meter stations, and explain the purpose of each.

Include a description of proposed equipment, locations of equipment, and site

dimensions. Include a typical plot plan drawing for the meter stations in Appendix 1-C.

Response:

Site dimensions and equipment locations for each meter station are included in the plot plan

drawings in Attachment RR1-7. Attachment RR1-7 contains Critical Energy Infrastructure

Information and is labeled “Contains Critical Energy Infrastructure Information – Do Not

Release”.

Mobley Interconnect:

The Mobley Interconnect will receive natural gas from Equitrans existing line H-302 via a 36-

inch pipeline installed by Equitrans and discharge into the Mountain Valley Pipeline H-600.

Components at the station will include four (4) gas filter separators, three (3) 20” ultrasonic gas

meter runs, two 20” flow control valve runs, and a pig launcher. The pig launcher attaches

directly to the Mountain Valley Pipeline. This station will contain an electronics building (used

to house equipment such as gas chromatographs, flow computers and communications

equipment). The station will be surrounded by a chain-link fence. The purpose of the gas filter

separators are to prevent any residual dirt or dust from the pipeline from entering the meters for

accurate measurement. The ultrasonic gas meters will measure the volume of gas flowing

through the site for billing and mass balances on the pipeline. The purpose of the flow control

valves are for Gas Control Operations use to control shipper volume nominations on the pipeline.

The purpose of the pig launcher is to have the ability to install pipeline inspection tools in the

pipeline. The purpose of the chain link fence is to establish a site security boundary.

Sherwood Interconnect:

The Sherwood Interconnect will receive natural gas from a third-party upstream pipeline and

discharge at the Sherwood Gas Processing Plant into the Mountain Valley Pipeline H-600.

Components at the station will include two (2) gas filter separators, one 12” ultrasonic gas meter

run, one (1) 10” overpressure protection/flow control valve run. The discharge of the meter

station will tie into the Mountain Valley Pipeline via approximately 50-feet of 16-inch pipeline.

This station will contain two electronics building (used to house equipment such as gas

chromatographs, flow computers and communications equipment). The station will be






14

surrounded by a chain-link fence. The purpose of the gas filter separators are to prevent any

residual dirt or dust from the pipeline from entering the meters for accurate measurement. The

purpose of the overpressure protection control valve is a safety apparatus to prevent maximum

pressure exceedance of the pipeline. The ultrasonic gas meters will measure the volume of gas

flowing through the site for billing and mass balances on the pipeline. The purpose of the flow

control valves are for Gas Control Operations use to control shipper volume nominations on the

pipeline. The purpose of the chain link fence is to establish a site security boundary.

WB Interconnect:

The Columbia Interconnect will deliver natural gas from the Mountain Valley Pipeline H-600

into Columbia Gas Transmission’s (Columbia) Line WB and WB-5. This station will contain an

electronics building for Columbia’s equipment (used to house equipment such as gas

chromatographs, flow computers and communications equipment), an electronics building for

Mountain Valley Pipeline equipment (used to house equipment such as a flow computer and

communication equipment). There will also be a canopy installed over the meter runs and a

canopy over the control valve runs. Components at the station will include two (2) gas filter

separators, two (2) 16” gas ultrasonic meter runs, three (3) 12” overpressure protection/flow

control valve runs. The station will be surrounded by a chain-link fence. The purpose of the gas

filter separators are to prevent any residual dirt or dust from the pipeline from entering the meters

for accurate measurement. The purpose of the overpressure protection control valve is a safety

apparatus to prevent maximum pressure exceedance of the pipeline. The ultrasonic gas meters

will measure the volume of gas flowing through the site for billing and mass balances on the

pipeline. The purpose of the flow control valves are for Gas Control Operations use to control

shipper volume nominations on the pipeline. The purpose of the chain link fence is to establish a

site security boundary. In order to access Columbia’s approved tap location, approximately

1,000 feet of 24-inch diameter pipe is required to be constructed from the Mountain Valley

Pipeline H-600.

Transco Interconnect:

The Transco Interconnect will deliver natural gas from the Mountain Valley Pipeline H-600 into

Transco pipelines at Transco’s Station 165. Specifically, Transco owns four (4) pipelines (A –

30”, B – 30”, C – 36”, D – 42”) coming into their station 165 and three (3) pipelines (A – 30”, B

– 30”, C – 36”) leaving station 165. Mountain Valley Pipeline plans to have taps on each of

Transco’s suction and discharge pipelines. The planned interconnect station will contain an

electronics building for Transco operated equipment (used to house equipment such as gas

chromatographs, flow computers and communications equipment) an electronics building for

Mountain Valley Pipeline operated equipment (used to house equipment such as a flow computer

and communication equipment), a meter building will enclose the meter runs and a control valve

building will enclose the control valve runs. Components at the station will include five (5) gas

filter separators, six (6) 16” ultrasonic gas meter runs, four (4) 16” overpressure protection/flow






15

control valve runs, two (2) 26” overpressure protection security valve runs and a pig receiver.

The pig receiver attaches directly to the Mountain Valley Pipeline. The station will be

surrounded by a chain-link fence. The purpose of the gas filter separators are to prevent any

residual dirt or dust from the pipeline from entering the meters for accurate measurement. The

ultrasonic gas meters will measure the volume of gas flowing through the site for billing and

mass balances on the pipeline. The purpose of the flow control valves are for Gas Control

Operations use to control shipper volume nominations on the pipeline. The purpose of the

overpressure protection control valve is a safety apparatus to prevent maximum pressure

exceedance of the pipeline. The purpose of the pig receiver is to have the ability to remove

pipeline inspection tools from the pipeline. The purpose of the chain link fence is to establish a

site security boundary.










16


Request:


8. Provide a schedule when on-site inspections of proposed rectifier sites could be

conducted. After the inspections, revise table 1.3-3 to denote if the cathodic protection

would be a groundbed type-surface or deepwell.

Response:

Table 1.3-3 has been modified in Attachment RR1-8 to show the updated rectifier locations and

the groundbed type.










17


Request:


9. Section 1.3.3 stated that: “Mountain Valley Pipeline is currently conducting surveys to

identify sensitive resources in the vicinity of the access roads.” Provide a schedule for

the road inspections, and the filing of information about sensitive resources that may be

affected by project use of specific access roads. In addition, provide measures that would

be implemented to reduce impacts on those specific resources.

Response:

Access roads have been surveyed to the extent that survey permission has been granted. All

potential impacts relating to access roads that were surveyed were contained in Mountain Valley

Pipeline’s application. As stated in Section 1.3.3, impacts will be avoided or minimized by

shifting access roads where feasible. However, if impacts are unavoidable, Mountain Valley

Pipeline will utilize the FERC Plan and Procedures as well as the Project-specific Erosion and

Sediment Control Plan to minimize impacts to resources from access road construction.

Once access to the remaining parcels is obtained, Mountain Valley Pipeline will perform the

required surveys and analyze any potential impacts to these remaining areas. Results of these

surveys will be provided to the Commission and to the relevant agencies. Mountain Valley

Pipeline continues to have discussions with landowners to obtain survey access; however, a

specific date for access is unknown at this time.










18


Request:


10. Contractor yard acreages in table 1.3-4 sum to 147.0 acres, while tables 1.3-1 and 8.1-2

indicate that 228.3 acres would be impacted during construction of the contractor yards.

Resolve the apparent discrepancy. In addition, forested land is included with several of

the proposed contractor yards. Indicate whether trees would be cut to prepare the

contractor yards. If trees would be cut, provide site-specific justification for the clearing.

Response:

Table 1.3-4 has the correct acreage for contractor yards. Mountain Valley expects to file updated Tables

1.3-1 and 8.1-2 by January 22, 2016.

The locations of the pipe/laydown yards are analyzed and selected for access to public roads and the

pipeline. Mountain Valley Pipeline has analyzed and reduced work areas in forested areas to the greatest

extent possible. However, at the locations where there are trees, Mountain Valley Pipeline will need to be

cleared to provide adequate access area for clean storage, temporary trailer locations, and access to stored

pipe. Site specific justification for pipeyards in which tree clearing is required is provided in Attachment

RR1-10.










19


Request:


11. Page 1-23 stated that waterbodies, roads, and railroads would have 3 feet of cover.

However, page 1-27 stated that waterbody crossings would have 4 feet of cover (except

in consolidated rock) and page 1-32 stated that railroads would have 10 feet of cover.

Clarify the apparent discrepancies.

Response:

Mountain Valley Pipeline will comply with the requirements of the applicable permits for

waterbodies, roads, and railroads.

Mountain Valley Pipeline will install the pipeline with a minimum of 4 feet of cover for

navigable waterbodies and a minimum of 3 feet of cover for non-navigable waterbodies

measured from the waterbody bottom to the top of the pipe, except in consolidated rock where a

minimum of 2 feet of cover will be required.

Mountain Valley Pipeline will install the uncased railroad crossings with a minimum of 10 feet

of cover measured from the base of the rail to the top of the pipe.

Mountain Valley Pipeline will install the cased railroad crossings with a minimum of 5’ 6” of

cover measured from the base of the rail to the top of the pipe. The railroad crossing types will

be determined by each railroad company’s permit.










20


Request:


12. Page 1-19 stated that construction will not occur on frozen ground, but page 1-37 stated

that construction will occur on frozen ground. Resolve the apparent discrepancy.

Response:

Page 1-37 states “it can be expected that construction activities will occur in frozen ground

conditions before and after winter months in various sections of the route, meaning construction

may occur during times of snowfall.” Conversely, page 1-19 states “Mountain Valley Pipeline

does not expect that construction activities will occur in frozen ground conditions.” The

statement on page 1-19 should be revised to state that “it can be expected that some construction

activities will occur in frozen ground conditions.”










21


Request:


13. Section 1.4.1.1 stated that: “in actively cultivated agricultural areas, the trench depth will

be greater in order to achieve the greater depth of cover requirements.” Provide the

specific depth of cover (in feet) for agricultural areas, by MP.

Response:

Section 1.4.1.1 states that “Under typical conditions, the trench will be adequate to accommodate

the 42-inch-diameter pipeline with 36 inches of cover and 48 inches of cover in actively

cultivated agricultural lands… In actively cultivated agricultural areas and at certain crossings

(e.g., road, waterbody), the trench depth will be greater in order to achieve the greater depth of

cover requirements.”

The statement that the trench depth will be greater in actively cultivated agricultural areas refers

to the 48 inches of cover for these areas as opposed to the typical 36 inches of cover for typical

upland construction. The trench depth will therefore be an additional 12 inches in actively

cultivated agricultural areas. The described cover design, therefore, does not require milepost

specific data as they will all be the same number.










22


Request:


14. Describe any potential impacts on environmental resources, such as revegetation

concerns or altered drainage patterns, associated with the use of limestone dust as backfill

material. Justify the statement in section 1.4.1.1 that: “Mountain Valley Pipeline does

not plan to have certifications of the fill that is brought in;” particularly in relation to the

potential spread of invasive plant species if the fill contains seeds.

Response:

Limestone dust will be used as a padding material on Mountain Valley Pipeline only when no

other suitable materials are available on the construction right-of-way. The application of

screening buckets on site will significantly increase the ability to reuse recovered soil from the

right-of-way even when in rocky terrain, and significantly decrease the need for off-site fill,

including limestone dust. Given the basic properties of limestone dust, no revegetation concerns

are anticipated. In addition, drainage patterns would not be affected. In situations when fill will

be brought to the construction right-of-way, Mountain Valley Pipeline expects to utilize local

sources.










23


Request:


15. Clarify what specific analyses would be performed on “baseline water samples…taken at

the source prior to water-up and prior to discharge” during hydrostatic testing. Indicate

what criteria from water analyses would result in the source not being used for

hydrostatic testing of the pipeline.

Response:

For the State of West Virginia sampling will consist of Oil and Grease, Total Suspended Solids

and pH. No actionable levels are listed for Oil and Grease or Total Suspended Solids and pH

must be between 6.0 and 9.0. In addition, if a chlorinated water source is utilized then Total

Residual Chlorine will be included in the tests. Where Total Residual Chlorine or Chloroform

are tested, the actionable levels are 11 ug/l and 5.7 ug/l respectively.

For the State of Virginia sampling will consist of Total Petroleum Hydrocarbons, Total Organic

Carbon, Total Suspended Solids, pH and Total Residual Chlorine. No actionable levels are listed

for Total Organic Carbon or Total Suspended Solids. Total Petroleum Hydrocarbons must be

below 15 mg/l, Total Residual Chlorine must be below 11ug/l and pH must be between 6.0 and

9.0.

For both states, if discharge occurs to a waterbody then testing for chloroform will be included.










24


Request:


16. Section 1.4.1.2 stated that spoil piles would be separated by temporary water bars which

would be diverted into straw bales or No. 3 aggregate. Indicate methods that would be

used to remove No. 3 aggregate during cleanup.

Response:

A small backhoe/excavator would be used to clean out the debris at the aggregate collection

areas and disposed of as outlined in FERC staff’s Upland Erosion Control, Revegetation, and

Maintenance Plan (FERC’s Plan, May 2013 version).










25


Request:


17. Address comments filed by stakeholders that steep ridge tops often form property

boundaries, and that these boundaries could be affected by post-restoration changes in

topography (i.e., steep ridgelines could be notably rounded off).

Response:

Property markers, monuments and/or fencing will be referenced before construction and replaced

after reclamation. Mountain Valley will work with landowners to resolve situations where

construction may have affected property boundaries.

Respondent: Kevin Wagner

Position: Land Director








26


Request:


18. Provide either updated information or a schedule when details about all non-jurisdictional

facilities (such as electric and telecommunications services) would be filed with to the

FERC, after local utility companies communicate designs to Mountain Valley.

Response:

Mountain Valley Pipeline has updated information concerning non-jurisdictional facilities at

each MLV, Interconnect, and Compression Station. Mountain Valley has developed the designs

and plans for the non-jurisdictional facilities in consultation and coordination with the applicable

local utility companies. The site-specific details on planned service equipment and details are

provided below.

Mobley Interconnect:

There is an existing Mon Power 7.2 KV, single-phase line adjacent to the site. Service to the

Mountain Valley Pipeline site will be an underground service lateral from an existing pole

(Coordinates 39.562562 N & -80.542885 W) to Mountain Valley Pipeline’s service panelrack, a

distance of approximately 50 feet. There is an existing telecommunications line on this pole

which will be utilized for service to the site.

Main Line Valve 1 (MLV1):

There is an existing Mon Power 7.2 KV, single-phase line adjacent to the site. Service to the

Mountain Valley Pipeline site will be an underground service lateral from an existing pole

(Coordinates 39.562443 N & -80.543140 W) to Mountain Valley Pipeline’s service panelrack, a

distance of approximately 30 feet. The existing telecommunications line on this pole will be

utilized for service to the MLV1 site.

Bradshaw Compressor Station:

There is an existing 12.47 KV, three-phase line that originates at the Mon Power Jacksonburg

Substation (Coordinates 39.534598 N & -80.648506 W). It runs west on Rt. 20 past Fallen

Timber Run Road. The intersection of Fallen Timber Run Road and Rt. 20 (Coordinates

39.506288 N & -80.575744 W) is a distance of approximately 6.0 miles. At this intersection

there is also an existing Mon Power 7.2 KV, single-phase circuit that runs north on Fallen






27

Timber Run Road approximately 3.1 miles to a location adjacent to the Bradshaw Compressor

Station (Coordinates 39.535948 N & -80.537788 W).

Mountain Valley Pipeline has requested that Mon Power to extend the three-phase line north

from the intersection of Fallen Timber Run Road and Rt. 20 north on Fallen Timer Run Road to

Mountain Valley Pipeline’s sites using the same right-of-way as the single-phase line. This new

line will be a combination of new poles and reusing existing poles. Where applicable, the three-

phase will be installed over the existing single-phase line.

At the point adjacent to Mountain Valley Pipeline’s site a new pole line will be installed

approximately 1,350 feet up the hill to our site (Coordinates 39.533545 N & -80.533245 W).

Mountain Valley Pipeline will be required to obtain the new right-of-way and to clear the right-

of-way up the hill from Fallen Timber Run Road.

Mon Power may need to upgrade their Jacksonburg Substation and/or upgrade the conductors on

the three-phase line running along Rt. 20 in order to serve the Bradshaw Compressor Station.

The new and reused pole line from the intersection of Fallen Timber Run Road and Rt. 20 will

be used for telecommunications service to the Bradshaw Compressor Station.

MLV2:

Since this site (Coordinates 39.532079 N & -80.534178 W) is adjacent to the Bradshaw

Compressor Station and will be supplied both power and telecommunications from the Bradshaw

Compressor Station systems. There will be an unground feed from the electrical building to the

MLV2 site, a distance of approximately 400 feet.

Sherwood Interconnect:

There is an existing Mon Power 7.2 KV, single-phase line along Indian Run Road at the pipeline

crossing. The closest pole is at coordinates 39.313533 N & -80.539521 W. Mon power will

extend this line up the hill adjacent to the pipeline to the interconnect site (Coordinates

39.313399 N & -80.542854 W). Service to the Mountain Valley Pipeline site will be an

underground service lateral from the last Mon Power pole to Mountain Valley Pipeline’s service

panelrack, a distance of approximately 30 feet. Telecommunications will be constructed on this

same pole line and underground from the last pole to a Demark on the panelrack.

WB Interconnect and MLV9:

There is an existing Mon Power 7.2 KV, single-phase line near the site (Pole Coordinates

39.722017 N & -80.504881 W). This line presently supplies the house on the property. Power

to the valve and interconnect will be, initially, an extension of this line to the sites, a distance of






28

approximately 500 feet to MLV9 (Coordinates 38.722782 N & -80.503579 W) and an additional

1,000 feet to the interconnect (Coordinates 38.313399 N & -80.542854 W). Mon Power will set

a transformer pole at each site and will supply a 240/120 volt service lateral from the pole to

Mountain Valley Pipeline’s service panelrack at each site, a distance of approximately 30 feet.

The existing telecommunications line on this pole will be utilized for service to both sites and the

Harris Compressor Station.

After completion of the Harris Compressor Station, Mountain Valley Pipeline will provide an

underground 240/120 volt feeder from the Harris Compressor Station to both MLV9 and the

interconnect. This feeder will be in the ditch adjacent to the pipeline from the Harris

Compressor Station to the interconnect site. The purchased power will then be used as a backup

power source. Mountain Valley Pipeline will also provide telecommunications underground

from Harris Compressor Station to both the MLV9 and the WB Interconnect.

Stallworth Compressor Station:

There is an existing 12.47 KV, three-phase line that feeds from the AEP Charmco Substation

(Coordinates 38.005749 N & -80.748329 W) and runs approximately 12.1 miles south on Rt. 20

through Rainelle to the intersection of Rt. 20 with Rt. 29 (Coordinates 37.880596 N & -

80.808320 W). A three-phase tap from this line runs east on Rt. 29 for approximately 0.75 mile

to a pole located adjacent to Simms Mountain Cutoff Road (Coordinates 37.875339 N & -

80.797014 W). The three-phase stops at this pole and an existing 7.2 KV, single-phase tap

extends east on Rt. 29.

Mountain Valley Pipeline has requested that AEP evaluate extending the three-phase east on Rt.

29 from this pole to a location adjacent to the proposed Stallworth Compressor Station access

road (Coordinates 37.865619 N & -80.761657 W), a distance of approximately 2.2 miles. This

new, extended three-phase circuit would be a combination of overbuild on the existing single-

phase poles and new poles where necessary. New poles and conductors would extend from Rt.

29 along the Stallworth Compressor Station access road up to the site (Coordinates 37.867699 N

& -80.756672 W), a distance of approximately 0.50 mile.

Telecommunications is available on the existing pole line along Rt. 29. It will be extended on

this same pole line from Rt. 29 to the Stallworth Compressor Station.

Transco Interconnect and MLV36 End of Line (EOL) Receiver:

There is an existing 12.47 KV, three-phase line running along Transco Road. From the nearest

pole (Coordinates 36.834418 N & -79.338864 W) Mecklenberg Electric Coop will extend a 7.2

KV, single-phase tap south approximately 900 feet to a new pole at the MLV36 and EOL

Receiver site (Coordinates 36.832088 N & -79.340103 W). From this point Mecklenberg will






29

extend the line one additional pole, approximately 200 feet, to the interconnect site (Coordinates

36.830838 N & -79.341127 W).

Telecommunications is available on the existing pole line along Transco Road. It will be

extended on this same pole line from Transco Road to the interconnect and MLV36 sites.

MLV3 and MLV4:

There is an existing Mon Power pole at coordinates 39.834418 N & -80.338864 W. This pole is

approximately 2 feet from MLV4 (Coordinates 39.397949 N & -80.477592 W). Mon Power will

extend this line from their pole to MLV4 for power to the site. The electrical/automation

equipment for both MLV3 and MLV4 will be located at the MLV4 site. The communication

conductors from the RTU at MLV4 will be run to MLV3 in a conduit in the boring under the

railroad and Route 29 with the pipeline, a distance of approximately 400 feet.

Telecommunications is available on the existing Mon Power pole and will be extended to the

MLV4 site.

MLV5:


approximately 210 feet from MLV5 (Coordinates 39.201056 N & -80.553300 W). Mon Power

will extend this line from their pole to MLV5 for power to the site. There is an existing

telecommunications line on this pole which will be utilized for service to the site.

MLV6:



will extend this line from their pole to MLV6 for power to the site. There is an existing

telecommunications line on this pole which will be utilized for service to the site.

MLV7:

There will not be a non-jurisdictional build-out for power or telecom facilities for MVL 7. They

will have on-site generated power by either solar panels, thermal electric generators, or fuel cells

as discussed in Resource Report 1 Section 1.2.2.5 on page 1-11. Telecommunications will be

radio and/or cellular with VSAT backup.

MLV8:






30

There is an existing Mon Power 7.2 KV pole at coordinates 38.862884 N & -80.525453 W. It

also has telecommunications. This pole is approximately 85 feet from MLV8 (Coordinates

38.863118 N & -80.525486 W). Mon Power will extend this line from their pole to MLV8 for

power to the site. The telecommunications will also be extended to the site.

MLV10:



will extend this line from their pole to MLV10 for power to the site.

MLV11:

There is an existing Mon Power pole at coordinates 38.480485 N & -80.553345 W that also has

telecommunications. This pole is approximately 350 feet from MLV11 (Coordinates 38.382344

N & -80.555625 W). Mon Power will extend this line from their pole to MLV11 for power to

the site. The telecommunications will also be extended to the site.

MLV12:

There will not be a non-jurisdictional build-out for power or telecom facilities for MLV 12.

They will have on-site generated power by either solar panels, thermal electric generators, or fuel

cells as discussed in Resource Report 1 Section 1.2.2.5 on page 1-11. Telecommunications will

be radio and/or cellular with VSAT backup.

MLV13:



will extend this line from their pole to MLV13 for power to the site. The Mon Power pole also

has telecommunications which will also extend to the site with the Mon Power line.

MLV14 and 15:

There will not be a non-jurisdictional build-out for power or telecom facilities for MLV 14 or 15.




MLV16:






31

There is an existing AEP pole at coordinates 38.019189 N & -80.749821 W. This pole is

approximately 1000 feet from MLV16 (Coordinates 38.020615 N & -80.752466 W). AEP will

extend this line from their pole to MLV16 for power to the site. The telecommunications on the

pole will also be extended to the site.

MLV17:



extend this line within the Mountain Valley Pipeline right-of-way from their pole to MLV17 for

power to the site. The telecommunications on the pole will also be extended to the site.

MLV18:



extend this line from their pole to MLV18 for power to the site. The telecommunications on the

pole will also be extended to the site.

MLV19:

MLV19 (Coordinates 37.868437 N & -80.756635 W) is located within the Stallworth

Compressor Station. Power to the valve site will be supplied from the station 240/120 volt

power system proposed for the compressor station. Telecommunications will also extend from

the compressor station to the valve site.

MLV20:

There is an existing Mon Power 7.2 KV, single-phase pole at coordinates 37.677094 N & -

80.729802 W. This pole is approximately 700 feet from MLV20 (Coordinates 37.676019 N & -

80.731774 W). Mon Power will extend this line from their pole to MLV20 for power to the site.

The telecommunications on the pole will also be extended to the site.

MLV21:

There is an existing Mon Power 12.47 KV, three-phase pole at coordinates 37.674832 N & -

80.730859 W. This pole is approximately 250 feet from MLV21 (Coordinates 37.674420 N & -

80.730859 W). Mon Power will extend a 7.2 KV, single-phase tap from this pole to MLV21 for


MLV22:






32

There is an existing AEP 7.2 KV, single-phase pole at coordinates 37.516326 N & -80.701909

W. This pole is approximately 200 feet from MLV22 (Coordinates 37.516713 N & -80.701884

W). AEP will extend this line from their pole to MLV22 for power to the site. The AEP pole

also has telecommunications which will also extend to the site with the AEP line.

MLV23:

There will not be a non-jurisdictional build-out for power or telecom facilities for MVL 23.




MLV24:

There is an existing AEP 12.47 KV, three-phase pole at coordinates 37.353202 N & -80.665418


W). AEP will extend a 7.2 KV, single-phase tap from this line from their pole to MLV24 for

power to the site. The AEP pole also has telecommunications which will also extend to the site

with the AEP line.

MLV25:



W). AEP will extend a 7.2 KV, single-phase tap from this line from their pole to MLV25 for


MLV26:


W. This pole is approximately 1400 feet from MLV26 (Coordinates 37.276626 N & -80.

373283 W). AEP will extend this line from their pole to MLV26 for power to the site. The AEP

pole also has telecommunications which will also extend to the site with the AEP line.

MLV27:


W. This pole is approximately 90 feet from MLV27 (Coordinates 37.236871 N & -80. 199540



MLV28:






33

There will not be a non-jurisdictional build-out for power or telecom facilities for MLV 28.




MLV29:



W). AEP will extend this line from their pole to MLV29 for power to the site. The

telecommunications on the pole will also be extended to the site.

MLV30:


W. This pole is across Grassy Hill Road from MLV30 and is approximately 175 feet from our

site (Coordinates 37.085419 N & -79.948162 W). AEP will extend this line from their pole to

MLV30 for power to the site. The telecommunications on the pole will also be extended across

the road to the site.

MLV31:


W. This pole is approximately 1400 feet from our site (Coordinates 37.044053 N & -79.881220



MLV32:





MLV33:










34

MLV34:

There is an existing Mecklenberg Electric Coop 7.2 KV, single-phase pole across Anderson Mill

Road at coordinates 36.889021 N & -79.433240 W. This pole is approximately 300 feet from

the site (Coordinates 37.888409 N & -79.432780 W). Mecklenberg will extend this line from

their pole to MLV34 for power to the site. The telecommunications on the pole will also be

extended to the site.

MLV35:

There is an existing Mecklenberg Electric Coop 7.2 KV, single-phase pole east on Mill Creek

Road at coordinates 36.856390 N & -79.390670W. This pole is approximately 450 feet from the

site (Coordinates 37.856237 N & -79.392336 W). Mecklenberg will extend this line from their

pole to MLV35 for power to the site. The telecommunications on the pole will also be extended

to the site.










35


Request:


19. Update table 1.7-1 to indicate the current status of all required federal, state, and local

government permit applications and approvals. Include the agency and individual

contacted, the date Mountain Valley submitted or would submit the application, and

indicate whether a permit was issued or its pending schedule. Be sure to address:

a. Right-of-Way Grant application submitted to the U.S. Department of Agriculture

Forest Service (FS) to cross a portion of the Jefferson National Forest;

b. Right-of-Way applications submitted to the U.S. Department of the Interior

(USDOI) National Park Service (NPS) to cross the Appalachian National Scenic

Trail and the Blue Ridge Parkway;

c. U.S. Army Corps of Engineers (COE) permit applications submitted to the

Huntington and Norfolk Districts (under section 404 of the Clean Water Act

[CWA] and section 10 of the Rivers and Harbors Act);

d. Water Quality Certificate applications submitted to the West Virginia Department

of Environmental Protection (WVDEP) and the Virginia Department of

Environmental Quality (VDEQ) under section 401 of the CWA;

e. National Pollutant Discharge Elimination System permits submitted to the

WVDEP and VDEQ under section 402 of the CWA;

f. Air quality permit applications under the Clean Air Act submitted to the WVDEP

and VDEQ;

g. Documentation of consultations with the USDOI Fish and Wildlife Service

(FWS) to determine project-related effects on federally listed threatened and

endangered species and their critical habitat under the Endangered Species Act;

h. Stream and wetland crossing permit applications submitted to the West Virginia

Department of Natural Resources (WVDNR) and Virginia Department of

Conservation and Recreation;






36

i. Right-of-Way applications to cross state lands submitted to the WVDNR,

Virginia Department of Forestry, and Virginia Department of Game and Inland

Fisheries (VDGIF);

j. Right-of-Way applications to encroach upon or cross state highways submitted to

the West Virginia Department of Transportation and the Virginia Department of

Transportation; and

k. Submerged lands permits from the Virginia Marine Resources Commission.

Response:

See the updated table 1.7-1 included as Attachments RR1-19. Documentation of consultations

for the time period between October 2015 and December 2015 with the USDOI Fish and

Wildlife Service (FWS) to determine Project-related effects on federally-listed threatened and

endangered species and their critical habitat under the Endangered Species Act are included as

Attachment RR1-19g. Consultations are listed chronologically and separated by agency (USFWS

WV followed by USFWS VA).










37


Request:


20. Quantify impacts, to the extent possible in tabular format, on specific resources from the

projects listed on 1.10-1. For each of the projects within the same watersheds as the

Mountain Valley pipeline route, list the amount of impact (e.g., acreage, water volumes,

sound decibels), and the duration of impact (time period, calendar year/months), for the

resources listed below:

a. erodible soils and prime farmland (by acres);

b. geological hazards, including karst terrain and coal mines;

c. waterbodies (number crossed), including impacts from sedimentation, turbidity,

and water uses;

d. wetland, including number and acres affected;

e. identification of federally-listed threatened and endangered species and acres of

habit affected;

f. historic properties potentially affected (number);

g. forest that would be cleared (acres); and

h. types and amount of pollutants emitted, and the airshed(s) that would be affected.

Response:

Mountain Valley expects to submit a response by January 22, 2016.










38


Request:


Appendix 1-A – Alignment Sheets

21. Update all alignment sheets to correct the following sampling of discrepancies. This is

not an exhaustive list:

Project Component Correction Required

Mobley

Interconnect

Labeled correctly but symbology is not hashed as an

aboveground facility.

Bradshaw

Compressor Station

Labeled correctly but symbology is not hashed as an

aboveground facility. Aerial extent doesn’t depict the entire

facility.

Access Roads

MVP-MLV-AR-04 Not depicted.

MVP-HA-031.1 Not depicted.

MVP-MLV-AR-05 At MP 34.9 not MP 34.51 as listed in Appendix 1F.

MVP-DO-048 Not depicted.

MVP-DO-049 Not depicted.

MVP-LE-057 Three MVP-LE-057’s are depicted, one is likely supposed to be

MVP-LE-057.1 and MVP-LE-057.3.

MVP-LE-057.1 Not depicted.



MVP-LE-076 Closer to MP 60.1 than MP 59.8.

MVP-MLV-AR-08 Closer to MP 65.6.

MVP-ANC-001 Not depicted.






39


MVP-WB-114.01 Not depicted.

MVP-WB-120.1 Closer to MP 89.4 than MP 89.1.


MVP-NI-136 (in

Appendix

1-F)

Labeled MVP-WB-136 on alignment sheets.

MVP-NI-146 Closer to MP 115.8.


MVP-NI-154.2 Not depicted.


MVP-MLV-AR-18 Not depicted but there are two MVP-MLV-AR-17 labels.

MVP-SU-207 Not depicted.

MVP-MN-258.05 Not depicted.

MVP-ANC-002 Not depicted.

MVP-MN-277 Mislabeled as MVP-MN-227.

MVP-MN-278.01 Not depicted.

MVP-FR-308.01 Not depicted.

Giles County File titled “Giles County Alignment Sheets_2” was not filed.

Provide the missing file.

Roadways Crossed

Various Ensure roadway names in table 8-A match roadway names on

alignment sheets. For example, CO RTE 44-Barnette Run Road

at MP 106.83 in table 8-A is labeled CO RTE 44-Coon Creek

Road in appendix 1-A.

Various Ensure roadway labels are include in appendix 1-A. For

example State Highway 20 at MP 23.06 is not labeled.

Additional Temporary Workspaces (ATWS)






40


MVP-ATWS-1365 Mislabeled as MVP-ATWS-1362.

MVP-ATWS-458 Full extent not shown on the alignment sheets.

MVP-ATWS-762 Full extent not shown on the alignment sheets.

MVP-ATWS-763 Not depicted.


MVP-ATWS-827 Unlabeled on map.

MVP-ATWS-781A Full extent not shown on the alignment sheets.





MVP-ATWS-433A Not depicted.

MVP-ATWS-109A Full extent not shown on the alignment sheets.






MVP-ATWS-182 Unlabeled on alignment sheet.

Waterbodies

Various None of the National Hydrography Dataset (NHD) waterbodies

are depicted on the alignment sheets. NHD waterbodies should

be included until replaced by field data.

S-L64 Not depicted.

S-R4 and SR-5 Not depicted.

S-L20 and SL-21 Depicted on the alignment sheets but not in table 2-A-2.






41


Various Monroe

County

Waterbodies not identified on the alignment sheet or in table 2-

A-2 but depicted on the aerial background.

P-Z1B, P-EE1 Ponds in Monroe County listed in table 2-A-2 but not depicted

on the alignment sheets.

S-Z9 Depicted on the Giles County alignment sheet but not in table 2-

A-2.

S-F16A and S-

F16B

Listed in table 2-A-2 but not depicted on the alignment sheet.

Alignment sheet depicts S-F16.

S-F9B Labeled on the alignment sheet as F-9.1.

S-F9A Labeled on the alignment sheet as F-9.

S-B2 Labeled on the alignment sheet as S-B2A.

Wetlands

Various None of the National Wetlands Inventory (NWI) wetlands are

depicted on the alignment sheets. NWI wetlands should be

included until replaced by field data.

Various Combined wetland categories [e.g., palustrine emergent

(PEM)/palustrine scrub-shrub (PSS] should be split out on the

alignment sheets.

W-K32 Two separate wetlands labeled W-K32 (MP 45.9).

W-K27 Label missing from map portion of the alignment sheet.

W-A20 This wetland is PEM and PFO. Alignment sheets don’t

distinguish area of PEM from PFO.

W-EE3 Listed as impacted in table 2-B-1 however it is outside the

survey corridor on the alignment sheet.






42

Response:











43


Request:


Ancillary Sites Detail Sheets

22. Revise the ancillary sites maps to:

a. correct the label for the Flatwood Contractor Yard which is currently labeled

Mountain Valley Pipeline-LY-001 and it should be labeled Mountain Valley

Pipeline-RD-001; and

b. provide a map of contractor yard Mountain Valley Pipeline-LY-004.

Response:











44


Request:


Appendix 1-C – Plot Plans

23. Revise appendix 1-C to include:

a. a plot plan for the Stallworth Compressor Station (CS);

b. the location of the communication towers for each of the three CSs; and

c. locations of all VSAT equipment.

Response:

See Attachment RR1-7, which was included in the response to Resource Report 1, Request 7.










45


Request:


Appendix 1-D – Additional Temporary Workspace (ATWS) Table

24. As previously requested in our comments dated August 11, 2015, revise appendix 1-D to

include dimensions (length and width in feet, or denote as “odd-shaped”) for each

ATWS.

Response:











46


Request:


Appendix 1-E – Collocation Table

25. As previously requested in our comments dated August 11, 2015, revise appendix 1-E to

include units for all columns (feet or miles). Revise the table to remove “varies” and

“unknown” and replace with a specific off-set and/or overlap between the pipeline and

the edge of the right-of-way. Describe what is meant by the listing of the offset at

MP 264.25 as “- 13.”

Response:











47


Request:


Appendix 1-F – Access Roads

26. Provide the missing data listed as “TBD” in appendix 1-F or a timeline regarding when

the data will be provided. Do not hide the data in the length column which is noted as

“this column to be hidden in the final version.” Provide all MPs. Where possible, route

new access roads away from waterbodies, wetlands, and forest and indicate whether

Mountain Valley proposes to use permanent fill for access roads within waterbodies or

wetlands.

Response:

Mountain Valley has not been granted survey permission to survey all access roads. Once survey

permission is granted and surveys are complete, Mountain Valley Pipeline will be able to

produce all information labeled as “TBD” in Appendix 1-F of the application. Discussions are

ongoing with landowners; however, at this time Mountain Valley Pipeline is unable to predict

when survey access to these properties will be granted.

Mountain Valley considers the presence of waterbodies, wetlands, and forest when routing

access roads.

Any installation of culverts or other fill material for access roads within waterbodies or wetlands

will be subject to approval by appropriate federal and state agencies.










48


Request:


Appendix 1H – Fire Prevention and Suppression Plan

27. Section 4.1 stated the project would cross the George Washington National Forest in

Virginia. However, RR 8 correctly indicated that the project would cross the Jefferson

National Forest. Resolve the apparent discrepancy.

Response:

An updated Fire Prevention and Suppression Plan has been included as Attachment RR1-4. See

the response to Resource Report 1, Request 4.










49


Request:


Appendix 1H – Fire Prevention and Suppression Plan

28. Section 4.1 stated that fire prevention and suppression would be addressed in a “Plan of

Development or Construction, Operations, and Maintenance Plan.” This plan is not

mentioned elsewhere in RR 1. File a copy of this plan with the FERC, or provide an

anticipated submittal date.

Response:

The “Plan of Development or Construction, Operations, and Maintenance Plan” refers to a

requirement for the right-of-way application with the United States Forest Service. Mountain

Valley Pipeline is in the process of developing the Plan of Development which will be included

as a part of the SF-299 application for a right-of-way to cross U.S. Forest Service lands.










50


Request:


Appendix 1-J – Vertical and Lateral Slope Tables

29. Appendix 1-J (vertical/lateral slopes between 15-30% grade) states the beginning MP is

190.82 and the ending MP is 1,327.22. Resolve the apparent error.

Response:

The ending milepost should be 190.85.










51


Request:


Appendix 1-K – Winter Construction Plan

30. As previously requested in our comments dated August 11, 2015, explain why mulching

would cover “at least seventy-five percent of the ground surface” and not 100 percent.

Response:

Section 3.0 of the Winter Construction Plan has been revised to state that “100 percent of the

ground surface” and is provided as Attachment RR1-30.










52


Request:


Appendix 1-K – Winter Construction Plan

31. As previously requested in our comments dated August 11, 2015, clarify whether

sediment barriers would be installed with the goal of “minimal reportable control

failures” or with a goal of no control failures.

Response:

Section 3.0 of the Winter Construction Plan has been revised to state “zero control failures” and

is provided as Attachment RR1-30.










53


Request:


Appendix 1-L – Agency Correspondence

32. As previously requested in our comments dated August 11, 2015, include the “enclosed

map” referenced in Mr. Lipford’s September 8, 2014 letter from the Nature Conservancy.

Response:

See Attachment RR1-32.










54


Request:


Appendix 1-M – Landowner List

33. Provide a public version of appendix 1-M with a unique tract or parcel number for each

affected landowner and redacted landowner names so that each landowner can be

matched specifically with landowner codes provided on the alignment sheets. Also

provide a privileged and confidential version of appendix 1-M that includes landowner

names, addresses, and associated tract or parcel number that can be matched specifically

with landowner codes provided on the alignment sheets.

Response:

Mountain Valley has revised the landowner list to include tract/parcel numbers. As discussed

with Commission Staff, Mountain Valley is filing the revised landowner list as privileged and

confidential. See the attached landowner list (Attachment RR1-33), which is privileged

information and is labeled “Contains Privileged Information – Do Not Release.”










55


Resource Report 2 – Water Use and Quality

Water Resources

1. As previously requested in our comments dated August 11, 2015, describe any confining

layers that may be present between surficial and regional aquifers, including depth to the

confining layer(s) and thickness of the confining layer(s).

Response:

An extensive discussion related to the character of aquifers in the states in the area of the Project,

as well as documentation of agency statements regarding the need for additional data on aquifers

was provided in Section 2.1.1. As stated, there are no available public sources of detailed

information regarding specific mapping of surficial aquifers in the area, including confining

layers. Aquifers in the area of the Project are typically limited in both vertical and horizontal

extent; and are not “regional” aquifers that cover large areas. Although aquifers occur in

geologic formations, these formations are not generally characterized as “regional” aquifers in

the area of the Project.










56


Request:


Water Resources

2. Specifically define the number and location of the “water basins” and/or watersheds

crossed by the proposed pipeline route. Revise table 2.2-1 to provide beginning and

ending MPs for each watershed. Indicate the gross square acre size for each watershed.

Response:











57


Request:


Water Resources

3. Section 2.1.1.2 stated that the pipeline route would cross the Pittsburgh and Sewell mine

pools. Provide a discussion of the water use and water quality of the Pittsburgh and

Sewell mine pools. In addition, provide the measures that Mountain Valley would

implement to avoid or minimize impacts from crossing mine pools.

Response:

The Mine Pool Atlas includes the following information regarding the Sewell and Pittsburgh

mine pools:

The Sewell and Beckley seams have the greatest potential for containing totally or partially

flooded mine voids…. The large mines in the Sewell, especially the ones below drainage, offer

high potential for supplying water resources. The down dip areas of some of the large mines

located near or above drainage also have potential for supplying water resources. Of the 599

mines in this seam, 415 are located in areas where structure contour and cropline data are

available. Three hundred sixty-eight of these mines are above drainage, 31 near drainage, and

16 below drainage. One near drainage mine and 16 below drainage mines are potentially totally

flooded; and 240 above drainage mines and 28 near drainage mines are potentially partially

flooded. Twelve potentially totally flooded below drainage mines exceed 500 acres in area and

average bed thicknesses 37.00 to 57.00 inches. Thirteen potentially partially flooded near

drainage mines exceed 500 acres in area, and average bed thicknesses for these mines range

from 27.00 to 57.00 inches. Large areas of several above drainage mines exceeding 500 acres in

area may be flooded… Potentially partially and totally flooded underground mines in the Sewell

coal provide an estimated 70,722.33 MMGal of potential storage; and 71.73 percent of

estimated storage is in potentially partially flooded mines. This potential storage accounts for

5.11 percent of total potential storage in underground mines of major seams (Figure 7a). This

coal represents 5.54 percent and 4.96 percent storage in potentially totally and partially flooded

mines, respectively, of major seams.

Twenty-seven public water supplies, which are located in Boone, Kanawha, Logan, Mingo,

Fayette, Greenbrier, McDowell, Raleigh, and Wyoming counties, were identified as being

associated with underground mines in these nine coal beds: Stockton; Winifrede; Fire Clay; No.

2 Gas; Sewell; Beckley; Fire Creek; Pocahontas No. 4; and Pocahontas No. 6. Ten of these

public water supplies are springs formed where old works crop out and 17 are wells drilled into






58

old mines. Twenty-two are located above drainage and four are located near drainage, mostly in

potential partially flooded mines; and one is located below drainage.

The Upper Pennsylvanian Monongahela Group (Figures 6a, b) includes nine named coal beds of

which four, the Waynesburg, Sewickley, Redstone and Pittsburgh, have been mined by

underground methods. Coal beds that have the potential to contain large volumes of groundwater

in mine voids are the Pittsburgh and Sewickley coals... The total potential storage in the

Pittsburgh seam surpasses that of other major seams such as the Number 2 Gas, Pocahontas No.

3, Eagle, and Sewell. The main reasons are the wide lateral extent of this seam and its greater

average thickness… Potentially partially and totally flooded underground mines in the Pittsburgh

coal provide an estimated 423,453.52 MMGal of potential storage; and the potentially partially

flooded underground Pittsburgh mines contain 51.87 percent of this potential storage. Potential

storage in underground Pittsburgh mines accounts for 30.60 percent of total potential storage in

underground mines of major seams. The percentage of potential storage in potentially totally and

partially flooded underground Pittsburgh mines represents 56.52 and 21.47 percent, respectively,

of the total combined potential storage of mines in major coal beds.

http://www.dep.wv.gov/WWE/wateruse/Pages/MinePoolAtlas.aspx

Impact to mine pools during construction is unlikely due to the large difference between the

depth of the pipeline and the depth at which mine pools are typically formed. Mountain Valley

Pipeline will remain pro-active in communication with mine operators, both past and present,

while working over former deep mines which have potential to be saturated.










59


Request:


Water Resources

4. Section 2.1.1.5 stated that Mountain Valley is continuing to evaluate specific karst areas,

and the project’s potential impacts on groundwater. Provide a schedule for filing this

information with the FERC.

Response:

Mountain Valley Pipeline continues its efforts to gain permission from property owners to access

properties along the proposed alignment in karst terrain in order to conduct a karst hazards

survey. Mountain Valley Pipeline will attempt to complete additional karst surveys in early

February 2016. Mountain Valley expects to provide any additional data acquired during that time











60


Request:


Water Resources

5. Clarify whether or not the pipeline would overlie any recharge zones for any of the sole

source aquifers discussed in section 2.1.2.

Response:

As stated in Section 2.1.2, no sole source aquifers were identified in the area of the Project and

the nearest sole source aquifer is over 100 miles from the Project. Therefore, the Project would

not cross any recharge zones for sole source aquifers.










61


Request:


Water Resources

6. Define the methods used to determine the hydraulic (groundwater flow) position of the

public water-supply facilities listed on table 2.1-4. In addition, revise table 2.1-4 to

provide distance (in feet) between the water-supply facilities and the pipeline.

Response:

The locations of public water sources (wells, springs) listed in Table 2.1-4 were identified

relative to the proposed alignment using topographic mapping data. However, the water source

locations are at this time approximate, and based on unverified open-source data. Mountain

Valley continues its efforts to contact all public water suppliers and to meet with concerned

public water suppliers in efforts to verify the actual groundwater withdrawal, surface water

intakes, and spring intake locations relative to the alignment. This is part of Mountain Valley’s

efforts to work with public water sources to identify concerns, discuss contingencies to maintain

uninterrupted water service during construction, and to conduct pre-construction baseline testing.

The approximate distances listed in Table 2.1-4 between the water sources and the proposed

alignment are based on visual estimates from topographic maps. Mountain Valley expects to

provide an updated table 2.1-4, which provides distance in feet, by January 22, 2016.










62


Request:


Water Resources

7. Clarify whether Source Water Assessment Areas in West Virginia, mentioned in

section 2.1.3.4, were identified by the West Virginia Bureau for Public Health.

Response:

Source Water Assessment Areas in West Virginia were identified from the West Virginia

Department of Health and Human Resources.










63


Request:


Water Resources

8. Section 2.1.3.4 stated that: “the only source water protection area identified as potentially

within 0.1 mile of the Project area is in the Rainelle Water Department located in

Greenbrier County….” However, section 2.2.2.4 stated that: “There are two source

water protection areas that are crossed by the Project and one that is less than one mile

away.” Reconcile the apparent discrepancy. Also clarify if the Rainelle Water

Department source water protection area is upgradient or downgradient from the pipeline.

Response:

Note that Section 2.1.3.4 is specific to groundwater sources and Section 2.2.2.4 is specific to

surface water source supplies. Section 2.1.3.4 identifies two public groundwater supplies as

potentially being within 0.1 mile of the Project. Table 2.1-4 indicates that the Rainelle

groundwater sources are indicated to be downgradient of the pipeline route.










64


Request:


Water Resources

9. Clarify whether the Robin Court Subdivision groundwater supply well, about 0.1 mile

from the pipeline, is within a Wellhead Protection Area or Source Water Protection Area.

Response:

The Robin Court Subdivision groundwater supply well is not located within a Wellhead

Protection Area or Source Water Protection Area. The public groundwater supply is discussed in

the text due to its close proximity to the Project.










65


Request:


Water Resources

10. Revise the Draper Aden Associates Water Resource Identification and Testing Plan, and

the Project Blasting Plan to include short-term yield (specific capacity) tests for private

wells both pre- and post-construction.

Response:

Based on hydrogeological experience in the Appalachian Basin, Mountain Valley Pipeline does

not consider aquifer yield testing to be an effective means of gathering data for protecting the

water wells. Well yield testing (e.g., specific capacity) is subject to tremendous amounts of

variation based on well construction, seasonal changes, aquifer properties, and testing

procedures. As a result, reliable information on water supply yields or aquifer flow

characteristics would not be produced, and comparison to these data in the future would not

elucidate if the well was affected by construction or if the lack of test reproducibility caused

notable differences.

Alignment adjustments have provided buffer between identified wells along the alignment and

the Project area. Additionally, because the trench excavation will be approximately ten feet in

depth, groundwater will not likely be encountered through most of the alignment. Therefore, the

potential for impact to a water supply from ground disturbance associated with Mountain Valley

Pipeline construction is considered remote, but would be best indicated by changes in water

quality in a more demonstrable manner than water yield.

Mountain Valley has initiated a robust pre-construction water supply sampling program that

relies on detailed information gathered from the water supply owner and water sample collection

at three and six months prior to construction activities. Wells in the near vicinity of construction

will be observed for signs of impact during construction. Where necessary, due to construction

observations or concerns of the property owners, post construction sampling may be conducted

in conjunction with a thorough review of the concerns, specific site conditions, and

hydrogeologic setting.










66


Request:


Water Resources

11. Section 2.1.4.1 and appendix 2-E (attachment 5 table 5.3) indicate that the water quality

analysis of wells and springs would include field indicator parameters, total and fecal

coliform bacteria, and major water quality analytes (major ion concentrations), along

with other target analytes that may be pertinent based on the setting. Provide the

rationale for water-quality analysis of major ions.

Response:

See the revised Table 5.3 for a more detailed discussion on rationale for the proposed water

quality parameter analyses in Attachment RR2-11.










67


Request:


Water Resources

12. Clarify the distance from the pipeline where Mountain Valley identified water supplies

(section 2.1.4.1 stated 150 feet, while section 2.1.3.3 indicated 500 feet).

Response:

The reference to 150 feet in Section 2.1.4.1 is a typographical error. Water supplies in karst

terrain that are located within at least 500 feet of the Project area were identified, and are

proposed for sampling as described in the Water Resources Identification and Testing Plan,

Appendix 2-E of Resource Report 2.










68


Request:


Water Resources

13. As previously requested in our comments dated August 11, 2015, add a data column in

table 2.1-5 to list the contaminants of concern, and media impacted (groundwater and

soils). Outline measures Mountain Valley would implement to avoid, minimize, or

mitigate for the unanticipated discovery of contaminated sites.

Response:

Based on available database searches, specific contamination concerns and media impacted were

not specifically available in these public forums. Section 2.1.3.5 provides discussion of the sites

identified including any sites noted of potential concern in regards to the Project. Sections 2.1.3.5

and 2.1.4.3 provide a general description of measures that would be followed in the case that

unanticipated contamination is found. An SPCC Plan would be created and implemented for the

Project as discussed in Section 2.2.5.










69


Request:


Water Resources

14. For karst areas traversed by the pipeline route, provide the results of:

a. published potentiometric surface or water table contour maps showing the direction

of groundwater flow from construction work areas to potential groundwater receptors

(public and private wells, springs, discharge to surface water), and recharge areas;

and

b. published dye tracer tests which identifies the groundwater flow path through the

karst system to area receptors (public and private wells, springs, discharge to surface

water), and recharge areas.

Response:

a. There are no readily available published peer-reviewed studies documenting groundwater

potentiometric surface, groundwater flow direction or related recharge areas in the vicinity of

the proposed route that lies within karst terrain. Geologic and hydrologic investigations have

been conducted by the United States Geological Survey in West Virginia and Virginia, but

not to a level of detail applicable to a narrow linear and shallow area of disturbance required

for pipeline construction.

b. Likewise, there are no peer-reviewed published dye trace studies in the karst area of the

proposed route. It is Mountain Valley’s understanding that the Virginia Department of

Conservation and Recreation is compiling dye trace study results and presumably will make

these data available to the public at some time in the future, but no specific plan or date for

publishing the results is in the public domain.

Mountain Valley is conducting a comprehensive karst hazards assessment in the karst areas

underlying the proposed route. The Karst Hazards Assessment document (see Resource

Report 6) was prepared by a Karst Specialist team that possesses over 70 years of combined

experience directly with karst terrain in southern West Virginia and southwest Virginia.

Mountain Valley will also deploy Karst Specialist teams prior to, and during construction to

assist Mountain Valley in avoiding karst features, monitoring karst terrain during

construction, and mitigating features if necessary. These levels of effort will provide






70

effective Project-specific assessment and management of karst resources compared to

indirect and non-peer reviewed evaluations that are not readily available.










71


Request:


Water Resources

15. Provide the results of a fracture trace/lineament analysis utilizing remote sensing

platforms (aerial photographs, and LiDAR imagery) and correlate, if possible, surficial

karst features found in the karst survey area with the lineament features intersecting with

the pipeline alignment, and evaluate the potential for intersecting shallow, interconnected

karst voids and cave systems along the alignment.

Response:

The application of fracture trace/lineament analysis over a broad region comprising more than 30

miles of karst terrain is not an effective or feasible analysis technique for karst hazards. The

Karst Specialist Team that will be utilized during construction possesses detailed understanding

of karst hazards along the proposed alignment, which will be confirmed through field

documentation on properties where access has been granted as discussed in Resource Report 6.

This is a superior karst hazards assessment process, relative to remote sensing applications, and

is described in more detail in Resource Report 6.










72


Request:


Water Resources

16. If pipeline trenching through karst terrain encounters sediment filled, pinnacled epi-karst

features, and minor route adjustments are not feasible, discuss how industry standard

erosion sediment controls would be deployed to sufficiently prevent raveling of

soils/sediment to the groundwater system, especially during precipitation events over the

exposed trench line.

Response:

This will be included in the Project-specific erosion and sediment control plan, with specific

references to erosion and sediment control measures to be implemented in karst terrain.

Mountain Valley expects to submit the plan by February 26, 2016.










73


Request:


Water Resources

17. As previously requested in our comments dated August 11, 2015, identify any

waterbodies that may be affected by construction of the proposed compressor stations and

meter stations, and use of pipe or contractor yards, and new or existing access roads that

may be improved. Provide a discussion of measures that would be implemented to avoid,

reduce, or mitigate impacts on waterbodies during construction of aboveground facilities

or ancillary use areas.

Response:

Mountain Valley expects to submit an updated Table 2-A-2 by February 26, 2016. The updated

table will include a complete list of impacts to waterbodies from the Project temporary and

permanent facilities. Section 2.2.5 provides a discussion of measures that would be implemented

to avoid, reduce, or mitigate impacts on waterbodies during construction and operation of the

Project.










74


Request:


Water Resources

18. Clarify if the Little Kanawha River (MP 75.0) and the Pigg River (MP 286.3) are major

(more than 100-feet-wide) or intermediate waterbody crossings. Revise section 2.2.1.3

and table 2.2-5, accordingly.

Response:











75


Request:


Water Resources

19. Section 2.2.2 of RR 2 stated that: “Mountain Valley Pipeline will prepare site-specific

crossing plans for the three waterbodies that are greater than 100 feet.” However, table

2-A-2 lists five waterbodies greater than 100 feet which would be crossed by the pipeline

route. Resolve the apparent discrepancies.

Response:

Mountain Valley will prepare crossing plans for all waterbodies with crossing greater than 100

feet. Mountain Valley expects to submit an updated Table 2-A-2 by February 26, 2016.










76


Request:


Water Resources

20. Provide definitions for the flow types “artificial path,” “dry ditch,” and “NR” in

table 2.2-3.

Response:

An artificial path is a channelized portion of a natural stream or river. A dry ditch is a roadside

drainage with no water present. Not Recorded (NR) is for waterbody types that were not

recorded in the field.










77


Request:


Water Resources

21. Mountain Valley is currently proposing open-cut wet ditch crossings for five

waterbodies. Two of these waterbodies are major waterbody crossings and two are

intermediate. One waterbody is listed on the Nationwide Rivers Inventory, and three are

listed on the Virginia Significant Rivers list. Evaluate the use of alternative crossing

methods, such as dry ditch and/or trenchless technologies, instead of wet open-cut

crossings of those five waterbodies.

Response:

Mountain Valley Pipeline contracted RK&K, an engineering firm that specializes in underground

crossing design. RK&K analyzed all five of the rivers mentioned for the feasibility of crossing

with three pipe installation methods. The methods evaluated were conventional bore, horizontal

directional drill (HDD) and open cut. Site geology, pipeline alignment, topography, access to

both sides of the river, and ATWS availability for equipment support was analyzed at each river

crossing. Any limiting factors that would affect the installation methods were also taken into

account. From the available data, the installation methods were determined to be feasible or not.

The feasible installation methods were ranked and the crossing method selected. Since the five

rivers are major and intermediate water bodies, open cut dry ditch installation method was not

considered. However, the rivers will be re-evaluated considering the open cut dry ditch

installation method, and the crossing method updated based upon further analysis. The crossing

method re-evaluation will be completed on available tracts. Mountain Valley expects to submit

any changes to FERC by February 26, 2016.










78


Request:


Water Resources

22. Several crossing lengths provided in table 2.2-5 contradict information provided in table

2-A-2. For example, the crossing length of Meadow Creek (MP 140.1) is listed as

265 feet in table 2.2-5 and 26 feet in table 2-A-2 and the crossing length of Little Tenmile

Creek is listed as 70 feet in table 2.2-5 and 69 feet in table 2-A-2. In addition, table 2.2-5

reports several waterbody widths that exceed crossing lengths. For example Price Run is

listed as a waterbody width of 35 feet and a crossing length of 41 feet. Reconcile the

discrepancies.

Response:

The crossing length for Meadow Creek in table 2.2-5 is a typographical error and should be 26

feet. The crossing length for Little Tenmile Creek is shown correctly as 69 feet in table 2-A-2.

The waterbody widths were assigned in the field and are the widest portion of the channel in the

general survey area (not specifically at the crossing area).










79


Request:


Water Resources

23. Section 2.2.1.4 provides a summary of horizontal directional drill (HDD) feasibility for

several waterbody crossings. Expand this discussion to include the feasibility of:

a. using an HDD at all major waterbodies, including the Left Fork Holly River and the

Gauley River;

Response:

Mountain Valley Pipeline will assess the feasibility of crossing the Left Fork Holly River

and Gauley River using the horizontal directional drill (HDD) method. Mountain Valley

expects to submit an analysis by February 26, 2016.

b. completing the HDD in sections rather than one continuous pullback or push

operation; and

Response:

Mountain Valley Pipeline will provide an HDD feasibility analysis for all major

waterbodies. Mountain Valley expects to submit an analysis by February 26, 2016.

c. minor route alignment modifications for a more favorable HDD crossing.

Response:

Mountain Valley Pipeline will provide an HDD feasibility analysis for all major

waterbodies. Mountain Valley expects to submit an analysis by February 26, 2016.





Senior Environmental Coordinator






80


Request:


Water Resources

24. Section 2.2.5 stated that: “there are 5 locations where the pipeline route parallels a

waterbody within 15 feet as listed in table 2-A-4.” Provide table 2-A-4. Because the

FERC’s Procedures would not allow construction within 50 feet of a waterbody, provide

site-specific justifications for these five locations and a request to modify the FERC’s

Procedures in those cases. Also, identify measures that could be implemented during

construction to reduce impacts on those five waterbodies.

Response:

Table 2-A-4 is included below. The table includes five locations where the pipeline route

parallels a waterbody within 15 feet. Mountain Valley is requesting a modification to the FERC

Wetland and Waterbody Construction and Mitigation Procedures, Section V, sub-section

3c. Site-specific justifications for each parallel location are included in the table. Mountain

Valley will implement flume pipes and site-specific erosion and sedimentation control measures

to keep water flowing and protected from construction activities. All impacts will be temporary

in nature and conditions will be restored following construction activities.










81

Table 2-A-4

Pipeline Locations Paralleling Waterbodies Within 15 Feet

State/ County

Waterbody ID

Waterbody Name

Milepost Distance to Route (ft)

Acres Within 15

feet of Pipeline

Flow Regime

Water Depth

Source Waterbody

Width Site Specific Justification

West Virginia

Webster S-B43 UNT/Amos Run 97.9 12.22 0.0013 Ephemeral 0.0 TTWB 1

Alignment follows contours up steep slope and avoids existing ponds. Each drain contains subsidence issues, therefore following the spur ridge was the most desirable route.

Nicholas S-N9 Ext Braid1

Skelt Run 122.2 8.77 0.0010 NR 0.0 TTWB 2.5

Pipeline is routed to avoid homes and follow contours. There is a large rock high wall to the east which prevents us from adjustment. Additionally, there is a school to the east, efforts were made to provide as much distance as possible between the route and the school

Virginia

Roanoke County

S-Y9 UNT/Mill Creek 243.3 10.73 0.0017 Intermittent 0.5 TTWB 3

Pipeline is desktop routed to avoid steep slopes to the north and south. Route surveying will be completed when access is granted.

Franklin County

NHD-137 Teels Creek 256.2 5.82 0.0188 Perennial 0.0 NHD 12

Pipeline is desktop routed to the side of an existing field. Route surveying will be completed when access is granted.

Pittsylvania S-H11 UNT/Rocky

Creek 283.7 3.19 0.0025 Ephemeral 0.0 TTWB 3

Routed to follow contour and cross road. ROW has been minimized to reduce impacts.






82


Request:


Water Resources

25. Confirm that Spring Hollow Reservoir is 1.2 miles downstream of where the pipeline

would cross the Roanoke River.

Response:

The Spring Hollow Reservoir is more specifically 1.13 miles downstream of where the pipeline

will cross the Roanoke River.










83


Request:


Water Resources

26. As previously requested in our comments dated August 11, 2015, provide documentation

of consultations with applicable local authorities that own or manage public surface water

intake facilities that may be impacted by the proposed project. Provide a discussion of

impacts construction may have upon water intake equipment and filters, and offer

measures to avoid, reduce, or mitigate those impacts.

Response:

See updated Table 5.2 (from Appendix 2-E, Water Resources Identification and Testing Plan)

attached as Attachment RR2-26 for documentation of consultations with applicable local

authorities that own or manage public surface water intake facilities that may be impacted by the

Project.

The potential for impacts to public groundwater supply wells from Mountain Valley Pipeline

construction is considered negligible given the distance separating the alignment from the few

supply wells identified in the vicinity of the Project area, and the fact that the construction trench

is likely to be no more than 10 feet deep but groundwater wells are typically hundreds of feet

deep.

The primary risk to surface water impacts is mobilization of sediment during construction that is

not captured by erosion, sediment, or stormwater control measures, which migrates to the surface

water intake. Anticipated negative effects would include reduced water clarity, high suspended

solids content and possible screen clogging. Mountain Valley Pipeline has contacted all public

water suppliers within the HUC10 water shed that the Mountain Valley Pipeline crosses, and

offered to meet with the suppliers and develop contingency plans for those that were concerned.

Mountain Valley Pipeline will implement enhanced sediment control features in the area of

water intakes during construction and revegetation. Mountain Valley Pipeline will also consider

several options to ensure uninterrupted water flow to the public supply customers, including

establishing additional surface storage, or an interconnect with another water provider, or an

alternative water supply that would be put into service during construction in the vicinity of a

water supply. If sediment impacts the supply, the contingency water supply would be utilized

until sediment migration is arrested and water quality improves to the meet the facility’s permit.

Mountain Valley Pipeline would commit to cleaning water supply intake filters if it is






84

demonstrated that construction activities mobilized sediments to the extent that the filters were

impacted.










85



Water Resources

27. Revise the crossing methods in table 2.2-9 to match those provided in table 2-A-2.

Response:

Mountain Valley expects to update the revised crossing table and provide it to FERC with the

stream crossing reevaluation report by February 26, 2016.










86


Request:


Water Resources

28. As previously requested in our comments dated August 11, 2015, provide specific details

regarding whether municipal water would be used for hydrostatic testing. Section 2.2.3

indicated that municipal water may be used for hydrostatic testing; however, municipal

water sources are not listed in table 2.2-9.

Response:

The hydrostatic test for Mountain Valley Pipeline will utilize the streams listed in Table 2.2-10.

See also the response to Resource Report 2, Request 35. In the event that a stream is not capable

of supplying the requisite volume of water at the time of the test, Mountain Valley Pipeline will

purchase water from a municipal source to make up the deficit. Mountain Valley Pipeline has

contacted all municipal water suppliers located along the route with general information about

the project and plans to discuss purchasing surplus water with them.











87


Request:


Water Resources

29. Section 2.2.3 stated that Mountain Valley may install groundwater wells to acquire water

for hydrostatic testing. Provide:

a. clarification if Mountain Valley would conduct pre and post-construction water

quality testing of other groundwater wells and springs within 150 feet of the

hydrostatic test wells

b. any measures Mountain Valley would implement to protect other nearby wells during

the drilling of the hydrostatic test water wells; and

c. a list of all state and local permits that would be necessary for the hydrostatic testing

water wells, and a schedule for permit applications. Include the regulations either in

table 1.7-1 or in a stand-alone table.

Response:

Mountain Valley Pipeline would only install groundwater wells for hydrostatic testing where and

when surface and municipal sources are limited, and only where the hydrogeologic conditions

are amenable to obtaining both the quantity and quality of water needed to make groundwater

withdrawal a viable alternative to other more remote sources.

No locations have been identified at this time for groundwater well installation. However, if it

appears that groundwater would be needed to augment hydrostatic testing, all state and local

permitting, testing, and monitoring requirements would be followed regarding well site location,

well installation, and casing requirement to ensure that no adverse impacts occur to springs,

surface water, or groundwater resources.



Phone Number: 724-873-3640Date: January 15, 2016







88


Request:


Water Resources

30. As previously requested in our comments dated August 11, 2015, describe plans for

compliance with the FERC’s Procedures, including sediment and erosion control, in the

event that a previously dry waterbody begins flowing during construction.

Response:

Section 2.2.1.4 (Waterbody Crossing methods) indicates that FERC Procedures and the Project

specific erosion and sedimentation control plan would be followed for all waterbody types,

including dry waterbodies that begin to flow.










89


Request:


Water Resources

31. Table 2.2-9 indicates that the Greenbrier, Roanoke, and Blackwater Rivers, are impaired

waterbodies; these locations are also proposed sources of hydrostatic test water (as

reported in table 2.2-10). Discuss the potential impacts on watersheds where hydrostatic

test water from impaired waterbodies would be discharged. Provide the opinion of

regulatory agencies on the use of water from impaired waterbodies for hydrostatic

testing. Clarify if Mountain Valley would commit to discharging hydrostatic test water

from impaired sources back into the same waterbody as sourced.

Response:

Mountain Valley Pipeline will discharge all hydrostatic test water in well-vegetated upland areas

at the end of the test section per consultations with applicable agencies. See also the updated

table 2.2-10 submitted in response to Resource Report 2, Request 35.










90


Request:


Water Resources

32. Section 3.1.4 stated that: “Geotechnical analysis will be conducted for some of the stream

crossings that will be performed via trenchless method.” Explain why geotechnical

analyses would not be performed at all streams to be crossed using trenchless methods.

Identify all waterbodies that would be crossed using trenchless methods (name,

county/state, MP, width), and adjust all tables in RR 2 accordingly.

Response:

The statement in Section 3.1.4 is inaccurate. If trenchless methods are used, geotechnical

analysis will be conducted for each crossing. However, at this time, all stream crossings are

anticipated to be open cut (trench) crossings.

Geotechnical analysis is used to reduce the unknown variables at stream crossings with higher

risk trenchless methods such as conventional bores over 300 feet in length or horizontal

directional drills (HDDs). For conventional bores less than 300 feet, the unknown variables

defined by geotechnical analysis have much less impact on the success of the completion of the

drill, therefore, geotechnical analysis is seldom used for the shorter conventional bores.

Mountain Valley Pipeline does not plan to cross any streams using trenchless

methods. However, re-evaluation is occurring on five rivers as requested by FERC. If the

method of crossing changes to a trenchless method on any of the five rivers, the requested

geotechnical information will be provided.










91


Request:


Water Resources

33. Discuss flash flooding hazards along the pipeline route. Identify the type of rain event,

and estimate the amount of precipitation that could result in flash flood conditions.

Outline measures that Mountain Valley would implement to handle a flash flood during

construction.

Response:

Section 2.2.1.2 addressed facilities located within in the 100-year flood zones. Flash floods

could occur in these zones with heavy rainfall. Mountain Valley will remove any equipment or

loose material from these areas prior to any significant rain event. Also, erosion and

sedimentation control measures will be secured to the greatest extent possible. Site-specific

measures, if necessary, to prevent damage to facilities during flooding and flash flooding will be

addressed in the floodplain permit applications required for development in flood zones.










92


Request:


Water Resources

34. Discuss the potential for stream scour during flash flood events. Outline the measures

Mountain Valley would implement to prevent or mitigate stream scour.

Response:

As stated in Section 2.2.5 (Impacts to Waterbodies from crossings and Mitigation Measures), the

pipeline will be installed at a depth below the streambed which is below scour levels. Stream

scour due to pipeline construction is not anticipated.










93


Request:


Water Resources

35. As previously requested in our comments dated August 11, 2015, revise table 2.2-10 to

include:

a. bold quantities as indicated in the table notes;

b. anticipated withdrawal rate of hydrostatic test water and its relation to the source

water’s anticipated discharge volume (e.g., the percent of water that would be

withdrawn from a waterbody);

c. anticipated month that water would be withdrawn; and

d. any invasive aquatic or plant species known to be within the surface water source.

Response:

a-c. See revised Table 2.2-10 included as Attachment RR2-35. Note that Mountain

Valley has modified the note to say “highlighted quantities” and has highlighted

the applicable quantities in yellow.

d. Invasive species that could be transferred during hydrostatic testing are addressed

in Resource Report 3, Section 3.1.4.5. The prevention and control of non-native

plant invasive species is further discussed in the Exotic and Invasive Species

Control Plan, provided in Appendix 3-C of Resource Report 3.










94


Request:


Water Resources

Appendix 2.A – Waterbody Crossing Tables

36. As previously requested in our comments dated August 11, 2015, revise table 2-A-2 to:

a. clarify why RR 1 stated that some waterbodies adjacent to roads or railroads would be

crossed via conventional bore; however this crossing method is not listed in

table 2-A-2;

b. define “ancillary sites temporary;”

c. clarify that “open cut dry ditch” refers to dam-and-pump or flume crossings and

“open cut wet ditch” refers to an open-cut crossing as described in RR 1;

d. denote impaired waterbodies (table 2.2-9);

e. identify waterbodies impacted by the compressor stations;

f. clarify why the Greenbrier River was listed as a “minor” waterbody, but the crossing

length would be 410 feet;

g. clarify why a waterbody would have a construction impact but no defined crossing

length;

h. fill in all missing information including waterbody classification, fisheries, and timing

restrictions; and

i. define the abbreviations and/or acronyms used to describe the fishery types.

Response:

Mountain Valley expects to submit a response by February 26, 2016.










95


Request:


Water Resources

Appendix 2.E – Water Resources Identification and Testing Plan

Revise appendix 2-E to include pre- and post-construction water-quality analysis of

volatile and semi-volatile organic compounds, and total petroleum hydrocarbons that

could be detected within area wells and springs from a potential spill or leak of fuels, oils

and other hazardous materials, along the construction right-of-way, particularly within

areas traversed by karst terrain.

Response:

Mountain Valley will conduct two (2) pre-construction water quality testing events at water

supplies (wells, springs, streams) where owner permission is granted to access the supply. See

Appendix 2-E of Resource Report 2 for the water quality testing plan discussion. Unless a

complaint is registered from the water supply owner that purports Mountain Valley construction

caused negative impact to the water supply quality, Mountain Valley does not see the necessity

in conducting post-construction water quality sampling in addition to the pre-construction

sampling. If a post-construction complaint regarding water quality is lodged by the water supply

owner, Mountain Valley will resample the supply(ies) within two weeks after receiving the

complaint in writing and compare the post-construction and pre-construction monitoring results

to identify if a notable and negative difference in water quality is observed. If it is determined

that Mountain Valley construction negatively impacted the water supply, Mountain Valley will

take all reasonable and responsible actions to restore, supplement and/or replace the water supply

to the satisfaction of the owner, at no expense to the owner. Mountain Valley will include

volatile, semi-volatile and total petroleum hydrocarbon target analytes for water quality sampling

at wells, springs or surface water bodies if we observe during pre-construction sampling an

indication that organic compounds may have been released by other parties in the vicinity of the

water supply, or in the event that a release is documented during Mountain Valley construction.

Testing of anthropogenic compounds at water resources that show no evidence of contamination

is not considered as an effective method to monitor and protect water quality.






96










97


Request:


Wetlands

37. Revise the analysis presented in section 2.3 and associated tables to only refer to a single

wetland type (i.e., palustrine emergent [PEM], palustrine scrub/shrub [PSS], palustrine

forested [PFO]). Avoid using combined PEM/PFO, PEM/PSS, PSS/PEM, PSS/PFO,

PFO/PSS categories.

Response:











98


Request:


Wetlands

38. Revise the analysis presented in section 2.3.1 to provide discussion of existing wetland

resources and how they would be impacted, including:

a. acreages of wetlands affected by both construction and operation – total acreage of

impacted wetlands, by state, and total by wetland type (i.e., PEM, PSS, PFO);

b. acreage of PFO and PSS wetlands that would be maintained in both the 10-foot-wide

corridor and 30-foot-wide corridor where woody vegetation would be selectively

removed; and

c. construction and operation acreages of impacted wetlands by facility type (i.e.,

aboveground facilities, access roads, pipe storage and contractor yards, ATWS, and

access roads). Clarify “ancillary sites” as referred to in table 2.3-1.

Response:











99


Request:


Wetlands

39. Clarify the discrepancy between table 3.2-1 and table 2-B-1. Table 3.2-1 lists

construction impacts on wetlands as 1.64 acres and operational impacts on wetlands as

0.56 acre; however, table 2-B-1 lists construction impacts on wetlands as 23.86 acres and

operational impacts as 9.29 acres.

Response:











100


Request:


Wetlands

40. Provide a summary table of wetland impacts. The table should include columns for each

state/county, wetland types crossed, and construction and operational acres for each

wetland type.

Response:

The summary table of wetland impacts is Table 2.3-1 included with Resource Report 2.










101


Request:


Wetlands

41. Clarify that riverine unconsolidated bottom (R5UB) discussed in section 2.3.2 and table

2.3.1 would not be crossed by the project. Palustrine unconsolidated bottom (PUB) and

R5UB should be discussed in the water resources section rather than the wetlands section.

Revise text and tables in RR 2 as appropriate.

Response:

Palustrine unconsolidated bottom resources would be crossed as identified in Table 2.3-1. Due to

the extensive reformatting and conforming changes associated with the requested text relocation,

Mountain Valley has not provided a revised version of Resource Report 2.










102


Request:


Wetlands

42. Clarify the meaning of “Not Reported” wetland acreages in table 2.3-1.

Response:











103


Request:


Wetlands

43. As previously requested in our comments dated August 11, 2015, provide a detailed

discussion of actual or conceptual compensatory mitigation plans for wetland impacts for

each state based on consultation with the COE and state agencies.

Response:

A compensatory mitigation plan is being prepared and will be submitted with the United States

Army Corps of Engineers Nationwide 12 Preconstruction Notification Package and West

Virginia DEP 401 Water Quality Certification. Mountain Valley expects to submit the plan by

February 26, 2016. All unavoidable permanent or conversion wetland impacts will be mitigated

through the purchase of wetland and stream credits from approved mitigation banks in West

Virginia and Virginia. In West Virginia the in lieu of fee program may also be utilized as

necessary. Calculation of compensatory mitigation credits for West Virginia will be determined

using the West Virginia Stream and Wetland Valuation Metric (SWVM) Version 2.1, September

2015. For Virginia, calculation of compensatory mitigation credits will be determined using the

Corps mitigation calculation worksheet.










104


Request:


Wetlands

44. Provide more details concerning measures that Mountain Valley would implement to

avoid and/or minimize secondary and indirect impacts on adjacent wetland areas (i.e.,

prevention of sediment discharge into adjacent wetlands and waterbodies - erosion and

sediment control measures, dewatering), or mitigation thereof if effects cannot be

avoided or minimized.

Response:

Mountain Valley Pipeline will follow the FERC Procedures and the Project-specific Erosion and

Sediment Control Plan, which Mountain Valley expects to submit by February 26, 2016.










105


Request:


Wetlands

45. Clarify discrepancies in wetland impact totals between table 2.3-1 (Construction –

24.07 acres, Operation – 9.42 acres, Total – 33.49) and appendix table 2-B-1

(Construction – 23.86 acres, Operation – 9.29 acres, Total – 33.15 acres).

Response:











106


Request:


Wetlands

Appendix 2-B – Wetland Crossing Tables

46. As previously requested in our comments dated August 11, 2015, revise table 2-B-1 to:

a. provide a crossing method for each wetland;

b. include details on footnote “e;”

c. include wetlands crossed by all Project components such as ATWS, access roads, and

aboveground facilities; and

d. revise footnote “c” to include all wetland types listed in the table.

Response:

a. Wetland Table 2-B-1 is updated for crossing method and is included in Attachment RR2-

46a.

b. Footnote “e” indicates: Construction Impact acreage is inclusive of all Operational

Impacts acreage.

c. Wetlands crossed by all Project components such as ATWS, access roads, and

aboveground facilities were included in RR2 and Appendices.

d. The footnote has been revised. See Table 2-B-1 in Attachment RR2-46a.










107


Request:


Wetlands

Appendix 2-E – Water Resources Identification and Testing Plan

47. Revise table 5.1 in appendix 2-E to include all project components.

Response:











108


Request:

Resource Report 3 – Fisheries, Vegetation and Wildlife

1. File all pending biological and botanical survey reports and related analyses, or provide a

schedule for their submission, including, but not limited to:

a. portal surveys for bats;

b. surveys for raptor nests;

c. surveys for rare, threatened, and endangered species and their habitats;

d. biological evaluation for the Jefferson National Forest; and

e. applicant-prepared draft biological assessment developed in coordination with the

FWS for the Roanoke logperch and northern long-eared bat (and other federally listed

species as appropriate).

Response:

a. Mountain Valley expects to file the portal surveys by January 22, 2016.

b. Mountain Valley expects to file the raptor survey report by January 22, 2016.

c. Mountain Valley expects to file the requested surveys by January 22, 2016.

d. Mountain Valley expects to file the Biological Evaluation for the Jefferson National

Forest to FERC by February 26, 2016.

e. The applicant-prepared Biological Assessment is currently in preparation. The

document will cover the Roanoke logperch, northern long eared bat, Indiana bat, and

several species of mussels. Mountain Valley expects to file the document with FERC











109


Request:


2. Clarify (in section 3.1.2.2) whether all native mussels are protected in the state of

Virginia.

Response:

According to the USFWS and VDGIF DRAFT Freshwater Mussel Guidelines for Virginia (dated

September 4, 2013), “VDGIF is responsible for the conservation and management of all

freshwater mussel species throughout Virginia” (see Attachment RR3-2). However, there is no

statutory protection for species without a legal status designation. Mussel species with a legal

status designation from VDGIF (http://www.dgif.virginia.gov/wildlife/virginiatescspecies.pdf)

and USFWS

(hhttp://www.fws.gov/northeast/virginiafield/pdf/endspecies/State_List/VaSpeciesList.pdf) can

be found in the lists included as Attachment RR3-2.










110


Request:


3. Confirm that fish and mussel removals and relocations would occur in both West

Virginia and Virginia for waterbody crossings de-watered during construction. Clarify

that Mountain Valley would only use qualified professional for the removals as

recommended by the Virginia Chapter of the American Fisheries Society for stream

crossings in Virginia, and outline removal and relocation methods. Describe any efforts

to relocate mussels, both within and downstream of the work zone, from waterbody

crossings that would not be de-watered during construction (i.e., those waterbodies to be

crossed via open-cut wet ditch methods).

Response:

Mussel and fish removals will be performed under supervision of qualified, professional

biologists holding necessary State and/or federal permits. Mussel removal and relocations will

occur at all streams proposed to be impacted in West Virginia and Virginia where native mussels

are located during mussel surveys. Fish removals will occur at all streams in Virginia. Fish

removals will not occur in streams of West Virginia. Fish and mussel removal and relocation

efforts will occur during suitable weather and water conditions, approved field seasons, and

coordinated to avoid instream work during time-of-year restrictions as provided by Virginia

Department of Game and Inland Fisheries (VDGIF) and West Virginia Division of Natural

Resources (WVDNR). In the event federally listed species are encountered during removal

efforts, USFWS and respective state agencies will be notified within 24 hours.

Mussel Relocations

Mussel relocation efforts vary according to the mussel survey protocols for each State, following

the West Virginia Mussel Survey Protocol (WVMSP) and the USFWS and VDGIF DRAFT

Freshwater Mussel Survey Guidelines for Virginia (dated September 4, 2013). In West Virginia,

implementation of standard mussel relocation protocols are anticipated for all Project crossings,

regardless of if wet or dry crossings are proposed. Methods for completing these efforts are

contained in the Study Plans submitted to and approved by the USFWS in West Virginia and

Virginia, WVDNR and VDGIF. Those documents are included as Attachment RR3-3a. This

attachment contains privileged information and is labeled “Contains Privileged Information –

Do Not Release.”

Fish Removals

Depletion fish surveys will occur at all perennial streams in Virginia and are completed within

instream disturbance areas including but not limited to coffer dam, dewatered areas, and/or






111

pipeline construction footprint) immediately prior to instream construction activities and/or

dewatering events. General methods for this effort are identified in the Study Plan submitted to

and approved by the USFWS in Virginia, and VDGIF. That document is included as Attachment

RR3-3b. This attachment contains privileged information and is labeled “Contains Privileged

Information – Do Not Release.” Based on additional coordination with the agencies since that

submission, the follow additional details have been identified: Temporary block nets (i.e. seines)

are installed perpendicular to flow upstream and downstream of the construction activities and

will remain in place for the duration of construction activities to prohibit movement of fishes into

and out of the isolated area. Once block nets are installed, variable fish collection techniques

including seining and electrofishing are employed within the isolated area. Techniques may be

dependent on the site-specific conditions encountered. Depletion fish survey efforts will

continue within the isolated area until no fishes are collected on the final pass. All collected

fishes will be moved downstream of the Project footprint.










112


Request:


4. Clarify whether blasting would be conducted when crossing the Gauley and Greenbrier

Rivers. The project-specific blasting plan should include measures to reduce impacts on

aquatic species when blasting would be used to cross waterbodies.

Response:

In the event blasting is necessary at these crossings, all blasting will be completed in accordance

with the preliminary Mountain Valley Pipeline Blasting Plan (Appendix 6B of Resource

Report 6) as well as the approved site specific blasting plans that will be submitted prior to

construction.

The following text is included in the preliminary blasting plan and addresses waterbody crossing

blasting procedures:

Blasting should not be conducted within or near a stream channel

without prior consultation and approval from the appropriate

federal, state, and local authorities having jurisdiction to

determine what protective measures must be taken to minimize

damage to the environment and aquatic life of the stream. At a

minimum, a five work day notice must be provided to the

appropriate federal, state, and/or local authorities. In addition to

the blasting permits a separate permit and approvals are required

for blasting within the waters of the states of West Virginia and

Virginia.

To facilitate planning for blasting activities for waterbody

crossings, rock drilled or test excavations may be used in

waterbodies to test the ditch-line during mainline blasting

operations to evaluate the presence of rock in the trench-line. The

excavation of the test pit or rock drilling is not included in the time

window requirements for completing the crossing. For testing and

any subsequent blasting operations, streamflow will be maintained

through the site. When blasting is required, the FERC timeframes

for completing in-stream construction begin when the removal of

blast rock from the waterbody is started. If, after removing the

blast rock, additional blasting is required, a new timing window






113

will be determined in consultation with the Environmental

Inspector. If blasting impedes the flow of the waterbody, the

Contractor can use a backhoe to restore the stream flow without

triggering the timing window. The complete waterbody crossing

procedures are included in Mountain Valley Pipeline’s E&SCP.

Additionally, in the event blasting is necessary at the Greenbrier and Gauley river crossings,

efforts will be made to minimize the impacts to aquatic resources that are protected by the State

of West Virginia; namely freshwater mussels. A formal mussel survey was completed at the

proposed Greenbrier River crossing where live freshwater mussels were located. Therefore

mussel relocation efforts will occur immediately prior to construction at this crossing, in

accordance with the methods outlined in the approved Study Plan, to avoid adverse effects to

mussels.

A formal mussel survey was not performed at the proposed Gauley River crossing because a

whitewater rapid posed unsafe diving conditions and inherent human risk. Searches for live and

deadshell mussels were completed in shallow, calm, littoral waters and yielded no live or

deadshell mussels. In addition, deadshell mussels were not recovered during bank searches.

This, combined with available information on substrate habitat, indicates that it is not likely that

mussels are present at the proposed Gauley River crossing therefore freshwater mussels are not

expected to be adversely affected.










114


Request:


5. Revise table 3.1-1 to include a column noting the state and fishery type in which the

listed aquatic species would be expected to occur.

Response:

Table 3.1-1 has been revised and is included in Attachment RR3-5. Two new columns have

been added to the Table to indicate the state and fishery type in which the fish or mussel species

is expected to occur.










115


Request:


6. As previously requested in our comments dated August 11, 2015, provide a revised

table 3.1-2 to include access roads (provide the access road identifier and closest MP for

each access road) and add a data column for stream width at the crossing location.

Response:

Revised Table 3.1-2 is included in Attachment RR3-6.










116


Request:


Vegetation

7. Reconcile all discrepancies regarding the amount of impacts on vegetation types (in

acres) within RR 3 and between RR 3, RR 2, and RR 8.

Response:











117


Request:


Vegetation

8. In table 3.2-3, provide the locations (by MP) of invasive plant species observed during

field surveys.

Response:

Observations of invasive plant species were collected from field crews following the summer of

2015. An updated Table 3.2-3 is attached as Attachment RR3-8 and includes locations of

observations to the extent they are available.










118


Request:


Vegetation

9. Discuss (in section 3.2.10) the ability of Mountain Valley to control invasive plant

species on the permanent right-of-way during operation without the use of herbicides.

Response:

As proposed in Resource Report 3 Appendix D, Mountain Valley Pipeline intends to revegetate

the right-of-way with native low-growing and stable plant communities that will resist invasion

by tall-growing tree species and invasive plant species. Post-construction right-of-way

maintenance will use mechanical and/or manual treatments as defined in the FERC Plan.










119


Request:


Vegetation

10. Provide actual “proposed avoidance or minimization” measures in table 3.2-2 for the sites

crossed (Jefferson National Forest, National Committee for the New River, and the Mill

Creek Springs Natural Area Preserve) developed in communication with site

owner/manager. Add a column to table 3.2-2 regarding whether the site owner/manager

agreed with Mountain Valley’s proposed avoidance or minimization measures. Resolve

the status of the purple fringeless orchid in table 3.2-2, currently reported as “current

status unknown.”

Response:

Table 3.2-2 has been updated as requested (see Attachment RR3-10). Coordination with

Jefferson National Forest, National Committee for the New River, and Mill Creek Springs

Natural Area Preserve are ongoing. Once feedback regarding or acceptance of the proposed

measures is received, an update will be provided to FERC. The remaining conservation units are

listed as N/A as the proposed Project route/facilities no longer cross those areas. With respect to

the purple fringeless orchid, surveys will be conducted during the flowering window in summer

2016.










120


Request:


Vegetation

11. As previously requested in our comments dated August 11, 2015, provide a table with the

following data for each forested interior tract for both construction and operation:

county/state; enter and exit MPs; length crossed (feet); area (acres) affected directly by

tree removal; and indirect effects (acres) on buffer zone areas of remaining forest

immediately adjacent to the pipeline right-of-way. In addition, develop a mitigation plan

(or state-specific plans) for both long-term and permanent upland forest impacts prepared

in coordination with the FWS, WVDNR, and VDGIF, with emphasis on mitigation for

interior forest impacts. This plan may be combined if appropriate with the pending

MBHCP and with efforts to minimize impacts to tree-roosting bat species.

Response:

Attachment RR3-11 provides the following data for each forest interior tract crossed by the

Project:

• Forest Tract ID

• Enter/Exit Milepost

• Length Crossed (feet)

• Pre-Construction Estimate of Edge (feet)

• Pre-Construction Estimate of Area (acres)

• State

• Construction Impacts by County

• Operation Impacts by County

• Post-Construction Percent Change in Edge

• Post-Construction Percent Change in Area

• Forest Fragments Created (Post-Construction)

A “forest interior tract” was bounded by a minimum size of 25 acres based on available

literature. The data presented in this table will be incorporated into the Migratory Bird Habitat

Conservation Plan that is currently in preparation. This plan will cover impacts, avoidance and

minimization and mitigation measures for birds and will be submitted to the USFWS, USFS,

WVDNR, and VDGIF for review and comment.






121

Forest impacts and avoidance and minimization measures for bats will be addressed in the

Biological Assessment, which will be provided to USFWS.










122


Request:


Wildlife

12. Revise table 3.3-1 to include a column noting the county/state and habitat type (e.g.,

deciduous forest, evergreen forest, scrub-shrub land, forested wetland, etc.) in which the

listed wildlife species would be expected to occur.

Response:

Revised Table 3.3-1 is included as Attachment RR3-12.










123


Request:


Wildlife

13. Regarding section 3.3, as requested in our comments dated August 11, 2015, describe any

known game corridors, herding or feeding areas, or game farms along or adjacent to the

pipeline route. Outline measures Mountain Valley would implement to avoid, minimize,

or mitigate impacts on harvested game species during construction and operation of the

project.

Response:











124


Request:


Wildlife

14. The “sensitive wildlife habitat composed of karst and karst-like features” described in

section 3.3-2 is not included in table 3.3-2 (Sensitive or Significant Wildlife Habitats).

Either include it (and any other sensitive wildlife habitats omitted) in the table or justify

why it was not included. Either in table 3.3-2 or in a separate table, provide the direction

and distance of the proposed work area from Tawney’s Cave. Add a column to

table 3.3-2 regarding mitigation measures developed in coordination with site

owner/manager or provide documentation from the site owner/manager agreeing that no

further measures are needed.

Response:

Table 3.3-2 included in the filed resource reports lists “karst” in the column titled “Habitat Types

Affected.” Table 3.3-2 has been updated as requested and is included in Attachment RR3-14










125


Request:


Wildlife

15. Regarding analysis in section 3.3.4, specify whether Mountain Valley would follow FWS

guidelines for installation of telecommunication towers at the proposed compressor

stations (see section 1.2.2.4 for reference).

Response:

The 2013 U.S. Fish and Wildlife Service (USFWS) Revised Voluntary Guidelines for

Communication Tower Design, Siting, Construction, Operation, Retrofitting, and

Decommissioning provides recommendations on the installation and operation of

communication towers to avoid impacts to birds. The Project’s proposed tower installations

adhere to the USFWS voluntary guidelines.

The Project’s proposed tower installations include each of the three compressor stations having

an identical 60 foot tall communications tower with a concrete foundation made up of three

vertical posts connected by reinforcing bars for the entire height. There are no lighting or other

devices supported by these towers, therefore, they are not a source of light or sound. Each tower

will be located within the compressor station limits of disturbance and will not require additional

earth disturbance permits. The towers will also not require operating licenses. These towers will

be operated in compliance with Federal Communications Commission, Part 15 requirements. For

more information on the proposed installations, refer to the response to Resource Report 1,

FERC Data Request 3. In addition, towers, such as the structures proposed, that are unlit,

unguyed, and less than 200 feet above ground level.










126


Request:


Wildlife

16. File a plan for the management of trash and food debris along the pipeline right-of-way

during construction.

Response:

The Trash Management Plan will be site-specific and will be the responsibility of the

construction contractor to develop. This will be submitted with the Implementation Plan.










127


Request:


Wildlife

17. Regarding section 3.3.4, discuss:

a. whether Mountain Valley would conduct 24-hour operations during construction

using artificial lighting (separate from HDD operations and aboveground

facilities) that may impact nocturnal species;

b. the effects artificial lighting at the aboveground facilities (e.g., security lighting at

compressor stations) during operation may have on local nocturnal species and

migratory bird species (reference recent literature in the discussion);

c. the effects that noise during construction and operation may have on local species

(reference recent literature in the discussion); and

d. measures that would be implemented by Mountain Valley to avoid, reduce, or

mitigate for potential impacts due to artificial lighting and/or noise at the project

facilities.

Response:











128


Request:


Endangered, Threatened, and Special Concern Species

18. Regarding section 3.4, specify the taxonomic groups and/or species for which survey

study plans been developed in coordination with federal and state agencies.

Response:











129


Request:



19. Discuss the impacts of forest clearing in temporary work areas outside the permanent

right-of-way upon “tree bats” such as the Indiana bat and northern long-eared bat.

Response:

Impacts to listed bat species associated with forest clearing activities will be addressed in the

Biological Assessment. Mountain Valley expects to submit the Biological Assessment by

February 26, 2016.










130


Request:



20. Clarify the statement in section 3.4.5 that: “… the Project corridor has been determined

unoccupied by state and federally listed species,” given that Mountain Valley is assuming

the presence of the federally endangered Roanoke logperch and mist surveys captured the

federally threatened northern long-eared bat.

Response:

The complete paragraph containing the above referenced statement is as follows: “Field surveys

for state and federally protected species are ongoing, and the quantity and severity of impacts to

these species cannot be determined until all data are collected. To date, no federally listed or

state protected species of freshwater mussels, birds, reptiles, or plants have been documented in

the Project study corridor during field surveys. Although the Project corridor has been

determined unoccupied by these state and federally listed species, there may be a temporary or

permanent loss or degradation of potentially suitable habitat. Temporary and permanent losses

of vegetation by type are discussed in Section 3.2.11. Similarly, while determined unoccupied by

field surveys, potentially suitable freshwater mussel habitat could be temporarily impacted by in-

stream construction. Details on these impacts and mitigation are discussed in Section 3.1.4”.

To clarify, the word “these” should have been inserted into the paragraph as illustrated above in

bold, so as to only refer to the lack of state and federally listed species of mussels, birds, reptiles,

and plants observed in the study corridor during field studies. Mountain Valley Pipeline is

assuming presence of Roanoke logperch in three streams (Roanoke River, North Fork Roanoke

River, and Pigg River) and field surveys confirmed the presence of northern long-eared bats in

the Project area.










131


Request:


Environmental Consequences on Jefferson National Forest Lands

21. Regarding sections 3.5.1, 3.5.3, 3.5.4, and 3.5.5 (and/or associated tables), specify how

Mountain Valley would avoid or minimize impacts on FS-specified old growth forest,

and FS-designated special biological areas (such as the Slussers Chapel Conservation

Site).

Response:

Mountain Valley will address this topic in the Biological Evaluation for the Jefferson National

Forest. Mountain Valley expects to submit the Biological Evaluation to FERC by February 26,

2016.










132


Request:


Environmental Consequences on Jefferson National Forest Lands

22. Regarding section 3.5.1:

a. provide a plan and schedule for FS-requested vegetation surveys and site index

measurements for the portion of the pipeline route crossing the Jefferson National

Forest. Indicate when forest survey reports would be submitted to the FERC and FS,

and file the FS review of all survey reports; and

b. indicate if Mountain Valley would incorporate the FS recommendation regarding the

replanting of shrubs along the edge of the right-of-way to reduce the sharp edge

effect. Provide a planting plan for the Jefferson National Forest crossing, developed

in communication with the FS.

Response:

a. Mountain Valley will address this topic in the Biological Evaluation for the

Jefferson National Forest. Mountain Valley expects to submit the Biological

Evaluation to FERC by February 26, 2016.

b. Mountain Valley Pipeline proposes to plant native shrubs and fast growing native

vegetation with varying mature characteristics within the temporary impact area

(also often referred to as the “Border Zone”) to reduce the sharp edge effect.

Mountain Valley will address the planting plan in the Biological Evaluation for the Jefferson

National Forest. Mountain Valley expects to submit the Biological Evaluation to FERC by

February 26, 2016.










133


Request:

Resource Report 4 – Cultural Resources

1. Resolve the discrepancies between section 4.1.2.1 and table 4.1-5. For example,

section 4.1.2.1 stated that 55 prehistoric sites are located within 0.5 mile of the project,

but table 4.1-5 lists 57 sites.

Response:

The Virginia Department of Historic Resources (VDHR) archaeological site files are part of the

state database system known as Virginia Cultural Resources Information System (V-CRIS).

Mountain Valley Pipeline conducted a site file search of the VDHR files in October 2014 and

again in September 2015. As shown in Table 4.1-5 below, V-CRIS contains records for

138 archaeological sites that have been previously recorded within one mile of the Project. Of

these, 97 archaeological sites are located within 0.5 mile of the Project. Eighty prehistoric sites

are located within one mile of the Project and 57 of these are within 0.5 mile of the Project. Four

sites that are located within one mile of the Project contain both historic and prehistoric

components. Of these, two are located within 0.5 mile of the Project. Forty-nine historic sites

are recorded within one mile of the Project. Of these, 41 are located within 0.5 mile of the

Project. Five sites of unknown time association are located within one mile of the Project of

which three are located within 0.5 mile of the Project.

Table 4.1-5

Previously Recorded Archaeological Resources in Virginia Within One Mile and 0.5 Mile of the Project

County

Prehistoric Sites

Prehistoric and Historic

Historic Sites

Unknown Time Period

Total Archaeology

Sites

1.0 Mile

0.5 Mile

1.0 Mile

0.5 Mile

1.0 Mile

0.5 Mile

1.0 Mile

0.5 Mile

1.0 Mile

0.5 Mile

Giles 8 7 0 0 14 13 2 0 24 20

Craig 0 0 0 0 0 0 0 0 0 0

Montgomery 20 13 3 1 14 10 1 1 38 25

Roanoke 12 0 0 0 2 0 0 0 14 0

Floyd 0 0 0 0 0 0 0 0 0 0

Franklin 31 28 1 1 7 7 2 2 41 38

Pittsylvania 9 9 0 0 12 11 0 0 21 20

Total Sites 80 57 4 2 49 41 5 3 138 103

Source: V-CRIS






134










135


Request:


2. Resolve the mathematical errors in the totals of several tables provided in RR 4. For

example, total archaeology sites within a 0.5 mile sums to 18 rather than the reported 19

and the total aboveground sites within 1 mile in table 4.1-8 sums to 325 not the reported

329. Update RR 4 text and appendices as necessary, when new survey report data

becomes available.

Response:

Resource Report 4 - Table 4.1-1 (revised)

Previously Recorded Archaeological Resources in West Virginia Within One Mile and 0.5 Mile of the Project

County

Prehistoric Sites

Prehistoric and Historic

Historic Sites

Unknown Time Period

Total Archaeology

Sites

1.0 Mile

0.5 Mile

1.0 Mile

0.5 Mile

1.0 Mile

0.5 Mile

1.0 Mile

0.5 Mile

1.0 Mile

0.5 Mile

Wetzel 0 0 0 0 5 3 0 0 5 3

Harrison 4 0 2 0 4 0 0 0 10 0

Doddridge 0 0 0 0 0 0 0 0 0 0

Lewis 0 0 0 0 1 1 0 0 1 1

Braxton 0 0 0 0 1 1 1 0 2 1

Webster 3 0 0 0 0 0 0 0 3 0

Nicholas 3 1 0 0 0 0 1 0 4 1

Greenbrier 1 1 0 0 0 0 0 0 1 1

Fayette 0 0 0 0 0 0 0 0 0 0

Summers 15 4 2 0 9 1 16 0 42 5

Monroe 40 4 4 2 4 0 7 1 55 7

Total Sites 66 10 8 2 24 6 25 1 123 19

A search of V-CRIS revealed 329 aboveground cultural resources recorded within one mile of

the Project of which 210 are located within 0.50 mile of the Project. Revised Table 4.1-8 below

lists the numbers of these resources by county. Numbers of the aboveground resources are

located within historic districts.






136

Resource Report 4 - Table 4.1-8 (revised)

Previously Recorded Aboveground Resources in Virginia Within One Mile of the Project

County Number of Aboveground Resources a/

1 Mile 0.5 Mile

Giles 78 65

Craig 1 0

Montgomery 50 36

Roanoke 61 32

Floyd 4 0

Franklin 91 40

Pittsylvania 44 37

Total Sites 329 210

a/ Includes Historic Districts and individual resources that comprise the Historic Districts










137


Request:


3. Document communications between Mountain Valley and/or its consultants and all local

governments including Certified Local Governments, counties, cities, and towns crossed

by the proposed pipeline route, and local historical societies or organizations, as

requested by the West Virginia and Virginia State Historic Preservation Offices (SHPO).

In particular, document that Mountain Valley communicated with the Greater Newport

Rural Historic District Committee, including the dates of communication and the

identification of individuals involved in those communications.

Response:

The outreach efforts of Mountain Valley to afford consulting parties and the public the

opportunity to comment on historic resources is summarized below. Generally, these efforts fall

within two categories, correspondence and public meetings.

Mountain Valley reviews all letters and comments filed with FERC through the e-library system.

Some letters have expressed specific concerns about cultural resources. In some instances,

public concerns regarding historic resources are forwarded to Mountain Valley via the

appropriate SHPO office staff. These letters examined and answered. Please see Resource

Report 4-J filed October 23, 2015 for letters forwarded from SHPO.

Mountain Valley hosted 16 community outreach open houses. One open house was held in each

county through which the Project traverses. Each meeting was advertised in multiple local

newspapers and the notices appeared at least twice for each open house. At each open house,

Mountain Valley set up information stations including Safety, Construction, Wildlife Habitat

Council, Environmental & Permitting, General Information about the Mountain Valley Pipeline,

and a Welcome/sign-in table. There also was always a table for FERC staff to answer questions

about the FERC process. At each open house, a cultural resources professional was present to

respond to any questions or comments about cultural issues.

Now that the route has been finalized, local governments, Certified Local Governments and local

historical societies and organizations in West Virginia will be contacted via letter as requested by

the West Virginia Division of Cultural and History (WVDCH).

Mountain Valley plans to reach out to the Greater Newport Rural Historic District Committee

regarding the recently-completed surveys.






138










139


Request:


4. Provide a table that lists the following sites identified by the public in relation to the

proposed pipeline (distance in feet from the centerline):

a. Josiah Whitney Cemetery on Pitt Farm, Red Oak Community, Webster County,

West Virginia;

b. McElwain Cemetery, Webster County, West Virginia;

c. archaeological sites along Hungards Creek on Bouldin Farm, Summers County,

West Virginia;

d. Bartholomew family Cemetery, Monroe County, West Virginia;

e. Johnson family Cemetery, Monroe County, West Virginia;

f. Historic Ross Cemetery, Craig County, Virginia;

g. Cumberland Gap Trail, Craig County, Virginia;

h. Audie Murphy Memorial on Brush Mountain, Montgomery County, Virginia;

i. Historic Griffith John Cabin in Montgomery County, Virginia;

j. Historic Wilderness Road in Montgomery County, Virginia;

k. Civil War Cemetery in Montgomery County, Virginia;

l. 1874 Johnsville Old German Baptist Meetinghouse in Montgomery County,

Virginia;

m. Kinzie house built in 1915, Newport, Giles County, Virginia;

n. archaeological sites on Kinzie Farm, Newport, Giles County, Virginia;

o. 1916 Red Covered Bridge, Newport, Giles County, Virginia;

p. archaeological sites along the Roanoke River, Roanoke County, Virginia;

q. pre-contact archaeological sites along Teels Creek, Roanoke County, Virginia;

r. Bowman Farm in Franklin County, Virginia; and

s. Slave Cemetery on Bryant Farm, Pittsylvania County, Virginia.






140

Response:

Table 4 below lists the sites noted in this request and provides their distances in feet from the

centerline.

Resource Report 4 Response 4 – Table 4

Distance to Centerline of Sites Listed in RR4 Request 4

Cultural Site County, State Comments and Distance (feet) from centerline

a. Josiah Whitney Cemetery Webster, WV Insufficient information provided – location unknown

b. McElwain Cemetery Webster, WV Two McElwain cemeteries on maps: George McElwain Cemetery: 3,095 feet Tunis McElwain Cemetery: 1,030 feet

c. Archaeological sites along Hungards Creek

Summers, WV 0 feet Project crosses a relocated archaeological site

d. Bartholomew family cemetery

Monroe, WV Insufficient information provided – location unknown

e. Johnson family cemetery Monroe, WV Johnson Crossroads Cemetery - 16,400 feet

f. Historic Ross Cemetery Craig, VA 39,365 feet

g. Cumberland Gap Trail Craig, VA Virginia Route 42 is known in Craig Co. as Cumberland Gap Road. Its closest approach to the Mountain Valley Pipeline centerline is 2,980 feet

h. Audie Murphy Memorial Montgomery, VA 37,800 feet

i. Historic Griffith John Cabin Montgomery, VA Insufficient information provided – location unknown

j. Historic Wilderness Road Montgomery, VA The “Wilderness Road” was a colonial-era trail or multiple parallel trails that followed the Great Valley in Virginia in a southwesterly direction. In Montgomery County, much of the known route of this road lies beneath Interstate Route 81 (I-81). I-81 crosses the Mountain Valley Pipeline Project at milepost 232.65

k. Civil War cemetery Montgomery, VA Insufficient information provided – location unknown

l. Johnsville Old German Baptist Meetinghouse

Montgomery, VA 21,850 feet

m. Kinzie house Giles, VA Two Kinzie houses noted on maps 1. William Kinzie--2,500 feet 2. L.W. Kinzie---1,045 feet

n. Archaeological sites on Kinzie farm

Giles, VA Insufficient information provided – location unknown

o. 1916 Red Covered Bridge Giles, VA 2,245 feet

p. Archaeological sites along the Roanoke River

Roanoke, VA Mountain Valley Pipeline centerline crosses the Roanoke River at milepost 238.85 in untested red tracts

q. Pre-contact archaeological sites along Teels Creek

Roanoke, VA Insufficient information provided – location unknown

r. Bowman Farm Franklin, VA 934 feet

s. Slave Cemetery Pittsylvania, VA Insufficient information provided – location unknown

Should any of the unknown sites listed above be located by Mountain Valley during field

surveys, the information will be exhibited in a survey report that will be submitted to the

respective SHPO.






141










142


Request:


5. In a filing on November 5, 2015, Stephen Legge of Newport, Virginia stated that the

Chester Grove School, which is listed on the National Register of Historic Places

(NRHP), on his property may be affected by the project. Provide the distance (in feet)

from the Chester Grove School to the pipeline centerline, and indicate if the school

building was recorded by Mountain Valley’s architectural survey (including the site

number and description from the report). If the school building is within the direct area

of potential effect (APE) (within 200 feet of the pipeline) provide a site-specific plan for

avoidance or mitigation. If the building is outside of the direct APE but within the

indirect APE (0.25 mile from the pipeline), discuss site-specific measures that would

minimize audible, visual, or other impacts from the project that may alter the character of

the property. If the Chester Grove School was not recorded by Mountain Valley’s

architectural survey, explain why.

Response:

A Chester Grove School has not been found within the NRHP list or in VDHR site files. A

property called The Chestnut Grove School however has been noted in VDHR files. The files

describe it is a weatherboard-sheathed schoolhouse with a stone foundation. It is typical of

schools in the district built circa 1910. It is a contributing building of the Greater Newport Rural

Historic District (VDHR #035-0412-0278). The building was not observed during field survey

and therefore was not recorded by Mountain Valley Pipeline. It is possible that the structure is no

longer extant. The approximate distance from the pipeline centerline to that site as recorded on

the 1932 map is 1,245 feet.










143


Request:


6. In a filing on November 10, 2015, Spenser Slough stated that the project may impact a

folk log structure dating to 1830, and five other structures dating to 1845, 1875, 1902,

and 1914 in Montgomery County, Virginia. Indicate the distance (in feet) each structure

is from the pipeline centerline. Relate these buildings to Mountain Valley’s architectural

survey (including site numbers, descriptions, and evaluations). If these buildings were

not recorded during Mountain Valley’s survey, explain why.

Response:

Mr. Slough’s letter of November 10, 2015 does not provide specific site location information for

the resource about which he expressed concern. As such, the referenced buildings were not

recorded during Mountain Valley’s survey.










144


Request:


7. In a filing on November 11, 2015, Ray Moeller of Summersville, West Virginia raised

concerns about potential project-related impacts on the 1852 Beaver Grist Mill near

Craigsville, in Nicholas County, which is apparently listed on the NRHP. Provide the

distance (in feet) from the mill to the pipeline, and indicate if the building was recorded

by Mountain Valley’s architectural survey (including site number and description). If the

Beaver Grist Mill is within the direct APE provide a site-specific plan for avoidance or

mitigation. If the building is outside of the direct APE but within the indirect APE,

discuss site-specific measures that would minimize audible, visual, or other impacts from

the project that may alter the character of the property. If the Beaver Grist Mill was not

accounted for in Mountain Valley’s survey report, explain why.

Response:

Beaver Mill (Field Survey No. 0108) (National Register Listing #01000776) is a historic grist

mill located on CR5/Old Beaver Road near Craigsville, Nicholas County, in the indirect APE,

approximately 0.30 mile from the Project centerline. Additional information including mapping

depicting the Mill’s location in relationship to the centerline and photographs can be found in

Cultural Resources Survey, Volume III, Nicholas, Greenbrier, and Fayette Counties, West

Virginia. This resource is represented in Figure 6.1.1-3, Table 6.1.1-1, and Photos 7.2.2-3 to

7.2.2-4; the updated West Virginia Historic Property form for Beaver Mill can be found in

Appendix D of that report filed with FERC December 23, 2015.

Constructed in 1852, the mill is a two-story, clapboard sided, timber frame structure with an end

gable roof. It sits on a stone pier foundation, and measures 25 feet wide by 30 feet long. The mill

ceased operation in 1932. The mill remains in relatively the same condition today as when it was

NRHP-listed in 2001 for its historical significance under Criterion C.

As noted in the NRHP nomination form and confirmed during Mountain Valley Pipeline’s

architectural survey, the structure is showing signs of deterioration, noticeably in the sills along

the mill’s stone foundation. Mountain Valley Pipeline’s architectural survey resulted in a

recommendation that the mill maintains the level integrity which warranted its listing on the

NRHP according to Criterion C. It embodies the distinct characteristics typical of a water-

powered gristmill, including its construction technique, plan and surviving equipment. There

have been few changes to the building. The period of significance beginning in 1852, its year of

construction, to 1932, when the post office and general store burned down and the mill ceased

operation, is still applicable.






145

Because of the distance and the current state of the building, Mountain Valley does not anticipate

any audible, visual, or other impacts from the Project that may alter the character of the property.










146


Request:


8. In a filing on November 16, 2015, Rebecca Dameron of Bent Mountain stated that her

145-year-old house is 0.5 mile away from the pipeline. Indicate the actual distance (in

feet) from the house to the pipeline, and assess the project’s potential impact on the site.

Response:

Rebecca Dameron’s house is located 1,900 feet east of the Mountain Valley Pipeline centerline.

The house is shielded from the proposed pipeline by a hill that rises approximately 120 feet

above the terrain on which the house is set. Permanent impacts on the cultural and historical

character of the house have been assessed as negligible.










147


Request:


9. In a November 17, 2015 filing, the Greater Newport Rural Historic District Committee

stated that Mountain Valley’s architectural survey missed numerous contributing

properties within the Historic District. Provide a list of all contributing properties within

the Historic District within 0.25 mile of the pipeline centerline. Relate these buildings to

Mountain Valley’s architectural survey (site numbers and descriptions), and indicate how

far (in feet) the pipeline would be from each of the structures. If any of the contributing

structures would be within the direct APE, provide measures for avoidance or mitigation.

If any of the buildings are outside of the direct APE but within the indirect APE, discuss

site-specific measures that would minimize audible, visual, or other impacts from the

project that may alter the character of those properties. If contributing buildings in the

Historic District within 0.25 mile of the pipeline were not relocated by Mountain Valley’s

survey, explain why.

Response:

Architectural surveys for Mountain Valley Pipeline are ongoing. The Phase I architectural survey

for Roanoke County survey is estimated for completion in early January 2016. Contributing

buildings in the Historic District within 0.25 mile of the pipeline were not located by the

Mountain Valley Phase I architectural survey because the survey scope developed in consultation

with VDHR did not require the recordation of individual resources within National Register

Districts. NRHP districts within the project APE were to be evaluated by windshield survey to

determine if there had been significant changes that would render all or portions of the district

ineligible. The architectural survey team recommends that the boundary for the Newport

Historic District is appropriate and it should remain unchanged.

In order to provide the data (a list of all contributing properties within the Greater Newport

Historic District within 0.25 mile of the pipeline centerline) requested by FERC, a desktop query

of VDHR’s VCRIS (Virginia Cultural Resources Information System) was conducted. Resource

Report 4 Response 9 - Table 9-a lists contributing resources within 0.25 miles of the pipeline

centerline, the VDHR No., the resource name, street address, distance to the pipeline centerline

in feet, if the resource is within the direct effects APE, and measures that will be taken to avoid

or mitigate direct, visual audible or other effects.






148

Resource Report 4 Response 9 -Table 9a

Greater Newport Rural Historic District Contributing Structures within 0.25-miles of Pipeline Centerline

VDHR ID Resource

Name Street Address

Distance from Pipeline

Centerline (ft)

Within Direct APE

Measures for Mitigation

035-0412-0246

House 382 Mountain Lake Rd, Newport, VA 24128

1254 No None. The Project should not be visible due to intervening vegetation.

035-0412-0242

Service Station

136 Smith Brothers Rd, Newport, VA 24128


035-0412-0241

House (Greek Rev)

112 Smith Brothers Rd, Newport, VA 24128


035-0412-0244

House 100 Covered Bridge Ln, Newport, VA 24128

209 Yes To be discussed with VDHR. The Project may be visible from the resource

035-0412-0010

Pole Barn (on Aldie Jones Farm)

402 Steele Acres Road, Newport, VA 24128

0 Yes To be discussed with VDHR. The pole barn has been documented and record filed with VDHR

035-0412-0466

Road Trace (on Aldie Jones Farm)

402 Steele Acres Road, Newport, VA 24128

0 Yes The Project centerline will cross the road trace; Phase II Survey will be performed, report filed with VDHR, and potential effects will be assessed.

035-0005 Red Covered Bridge

Covered Bridge Lane, Newport, VA 24128

108 Yes Special construction techniques will be used to minimize effects of construction on the bridge

035-5001 Bridge 6052 Rt 700 Over Sinking Creek, Newport VA 24128

140 Yes No affect anticipated. Ca. 1949 bridge not evaluated for NRHP eligibility. Bridge will not be removed and vehicular access to bridge will not be impeded.

Resource Report 4 Response 9 - Table 9-b lists contributing resources to the Greater Newport

Historic District located at a distance greater than 0.25 miles of the pipeline centerline. The table

also indicates measures to minimize impacts from the Project.






149

Resource Report 4 Response 9 – Table 9b

Greater Newport Rural Historic District Contributing Resources in Indirect APE Greater than 0.25 Mile from Centerline

VDHR No. Street Address Site-specific measure to minimize impacts from the

project

035-0412-0041 892 Blue Grass Trail, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures







035-0412-0249 463 Mountain Lake Rd, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures

035-0412-0466 428 Steele Acres Rd, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures

035-0412-0402 347 Clover Hollow Rd, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures

035-0412-0053 175 7 Oaks Rd, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures

035-0412-0404 118 Dunford Ln, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures

035-0412-0241 112 Smith Brothers Rd, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures

035-5073 1576 Blue Grass Trail, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures






150

Resource Report 4 Response 9 – Table 9b

Greater Newport Rural Historic District Contributing Resources in Indirect APE Greater than 0.25 Mile from Centerline

VDHR No. Street Address Site-specific measure to minimize impacts from the

project

035-0063 1576 Blue Grass Trail, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures

035-0412-0052 291 Seven Oaks Road, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures

035-0412-0010 402 Steele Acres Road, Newport, VA 24128 Implement Mountain Valley Pipeline’s Plan and Procedures outlined in Mountain Valley Pipeline Resource Report 1, Section 1.4 Construction Procedures










151


Request:


10. In a filing on November 25, 2015, Tina Badger stated that she knows the location of

unmarked graves near the pipeline route in the vicinity of McDonald’s Mill in

Montgomery County, Virginia. Prove the distance (in feet) from the unmarked cemetery

to the pipeline. Indicate if the graves were recorded by Mountain Valley during its

cultural resources survey, and correlate the site to the report (providing the site number,

description, and assessment of NRHP eligibility). If not recorded, explain why.

Response:

Ms. Badger’s property is situated 10,245 feet from the Mountain Valley Pipeline centerline. The

information provided regarding unmarked graves is inadequate to establish resource location in

relation to the Mountain Valley Pipeline centerline.










152


Request:


11. In a filing on November 30, 2015, Perry Martin stated that the Mt. Olive United

Methodist Church in Newport, Virginia was built in 1852, and may be near the pipeline

route. Provide the distance (in feet) from the church to the pipeline. Indicate if the

church was recorded during Mountain Valley’s cultural resources survey, and correlate

the church to the report (providing site number, description, and evaluation). If not

recorded, explain why.

Response:

Mount Olive United Methodist Church (historically known as Newport Methodist Church) is at

322 Bluegrass Trail, Newport Virginia. The church (VDHR resource no. 035-0059) is a

contributing resource in the Newport Historic District. The National Register nomination

describes the church as follows:

One-story, three-bay weatherboarded frame church with steep-pitched gable roof, pressed metal

shingles, Gothic stained glass windows, central three-stage bell tower, decorative wooden trim

including turned blocks, sawn brackets and consoles, wide pilasters; rear chancel bay. Interior

features decorative wooden trim also: trusswork, cornice brackets, wainscot, paneling, and rose

window-like tracery; original (circa 1906) altar furniture, lectern, altar rail, and pews. Post-1973

fellowship hall addition on northeast side of sanctuary, matches original in materials, details, and

proportions. Land for the church was donated in 1852 by David Price Brown, who may also have

constructed the first church building in 1853; local tradition holds also that the church was

remodeled in 1906 by local carpenter-cabinetmaker Robert Wysong (turned block detailing is

apparently a hallmark of his work). A prominent local landmark, the Newport Methodist Church

remains one of the most elaborate and well-preserved examples of Gothic Revival architecture in

the area.

The church is approximately 1,222 feet south of the pipeline centerline. The church was not

recorded during the Phase I historic architecture survey. The survey scope agreed upon by

VDHR did not require the recordation of resources within National Register Districts. NRHP

districts within the project APE were to be evaluated by windshield survey to determine if there

had been significant changes that would render all or portions of the district ineligible. The

architectural survey team recommends that the boundary for the Newport Historic District is

appropriate and it should remain unchanged.






153










154


Request:


12. In a filing on December 23, 2015, James Scott indicated that there is an historic

graveyard on his land in Roanoke County, Virginia that may be affected by the pipeline.

Provide the distance (in feet) from the pipeline to this cemetery. Indicate if this cemetery

was recorded during Mountain Valley’s survey and correlate it to the report (site number,

description, and assessment of NRHP eligibility). If not recorded, explain why.

Response:

Mr. Scott denied access to his property to Mountain Valley Pipeline survey teams. Once access

is obtained, the Mountain Valley Pipeline team will attempt to observe and record the cemetery.










155


Request:


13. Address the comment from Preservation Virginia, filed December 2, 2015, that stated

that the Mountain Valley’s architectural survey missed important historic sites and

cemeteries along the pipeline route in Virginia.

Response:

In a letter filed December 2, 2015 by Sonja A. Ingram, Danville, VA, representing Preservation

Virginia filed the following comment with FERC. After reviewing the Architectural Survey, we

have concerns about potentially important historic sites and cemeteries that appear to be within

the pipeline ROW. We have not had access to the Archaeological report; however, after it is

reviewed we may have concerns about archaeological sites as well.

Architectural surveys are ongoing. As the surveys are completed they will be filed and available

for review by the public. To date, Phase I architectural surveys have been filed with VDHR for

Pittsylvania and Franklin Counties. VDHR has concurred with the recommendation that there

are no National Register of Historic Places-listed or -eligible properties within the project APE in

Pittsylvania County. VDHR responded to the Franklin County architectural resources report on

January 6, 2016. VDHR concurred with Mountain Valley’s recommendations.










156


Request:


14. Provide summary tables of all cultural resources investigations and sites recorded. The

survey table should indicate the miles of proposed pipeline route in each county

inventoried for cultural resources (dates of all surveys and reports submitted to the

FERC). Identify all proposed aboveground facilities, and new or to-be-improved access

roads, staging areas, and contractor-pipe yards in each county that were covered by

cultural resources surveys, including acres inventoried at each of those areas (dates of all

surveys and reports submitted to the FERC). Provide the number of shovel probes

excavated in each county, indicating how many were positive and negative.

Response:

Attachment RR4-14a provides a summary of archaeological sites recorded by county and

indicates, the date of the report submittal to FERC.

Attachment RR4-14b identifies all proposed aboveground facilities, and new or to-be-improved

access roads, staging areas, and contractor-pipe yards in each county that were covered by

cultural resources surveys, including acres inventoried

Attachment RR4-14c provides the number of shovel probes excavated in each county, indicating

how many were positive and negative and miles surveyed versus total miles in each county.

These attachments include privileged information and are each labeled “Contains Privileged

Information – Do Not Release.”










157


Request:


15. Revise appendices 4-F and 4-I of RR 4 to include all archaeological and architectural

sites recorded in the APE in West Virginia and Virginia, and add columns for MP, and

distance to pipeline centerline (in feet). Also indicate which previously recorded sites in

the APE in both West Virginia and Virginia, including those listed in appendices 4-B1,

4-C1, and 4-G, were relocated and assessed by Mountain Valley and/or its consultants

(site number, county/state, milepost, NRHP evaluation, and report). If any previously

recorded sites in the APE were not relocated, explain why.

Response:

Attachment RR4-15a includes a revised comprehensive table that incorporates all requested

revisions. The attachment includes privileged information and is labeled “Contains Privileged

Information – Do Not Release.”










158


Request:


16. If any segment of pipeline, or proposed aboveground facilities, access roads, staging

areas, or pipe storage and contractor yards in any county has not yet been surveyed for

cultural resources, provide a schedule for future field work and submission of reports

with the FERC and the appropriate SHPO, and filing of the SHPO’s comments on those

reports.

Response:

Phase I archaeological and architectural Surveys are still in progress. To date approximately 90

percent of the accessible properties have been surveyed and reported. The date of completion of

the Phase I surveys depends on when permission to survey the remaining parcels is obtained. It

is anticipated that the fieldwork for all Phase I and Phase II surveys of all Project elements will

be completed in the late spring or early summer of 2016, with reports submitted to SHPOs and

FERC in July 2016. SHPO comments are anticipated in August or September of 2016.










159


Request:


17. Document that Mountain Valley incorporated the West Virginia Department of Culture

and History (WVDCH) comments of April 17, 2015 about the West Virginia Discovery

Plan into a revised plan (this can be done in highlights or in Word Track Changes). File

the revised plan with the FERC, together with the WVDCH’s acceptance of that revised

plan.

Response:

The revised Unanticipated Discovery Plan with the edits requested by WVDCH was filed

October 23, 2015 in Resource Report 4, Appendix 4-M. See Section 4.3(9)b of the

Unanticipated Discovery Plan. The WVDCH approved the plan in comments dated

May 8, 2015. Please see Resource Report 4, Appendix 4J, Page 2, Paragraph 5 of letter dated

May 8, 2015.










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Request:


18. File a copy of Mountain Valley’s March 20, 2015 email to the WVDCH about its

definition of the direct APE, and the WVDCH’s acceptance of that definition.

Response:

The March 20, 2015 email is included below in its original font. A hardcopy with supporting

figures entitled Amendment II to the Cultural Resources Workplan for West Virginia was

submitted March 20, 2015. WVDCH approval can be found in Resource Report Appendix 4-J

filed October 23, 2015. Please see letter from WVDCH dated May 08, 2015, Page 1,

Paragraph 3.

On Mar 20, 2015, at 1:46 PM, Marine, James

<[email protected]<mailto:[email protected]>> wrote:

Dear Ms. Brennan and Ms. Pierce:

Tetra Tech, Inc. (Tetra Tech) is pleased to provide clarification and supplemental

information in response to your comments regarding the proposed Area of Potential

Effects (APE) for architectural and historic resources (the “indirect APE”) for the

Mountain Valley Pipeline (Mountain Valley Pipeline) Project (Project). We appreciate

your time discussing survey methods and considerations in defining the indirect APE in

conversations on January 5, March 6, and March 19, 2015. Tetra Tech is requesting your

review of our proposed indirect APE and survey strategy prior to our formal submission

of a revised work plan and the initiation of field-based architectural and historic resources

survey as discussed in our most recent conversation.

As described in the initial consultation materials submitted to your office in October

2014, Mountain Valley Pipeline, LLC proposes to construct approximately 188.5 miles of

natural gas pipeline in West Virginia, extending from the existing Equitrans transmission

system in Wetzel County to Transcontinental Gas Pipeline Company’s Zone 5

compressor station 165 in Pittsylvania County, Virginia. This FERC regulated Project

will include the construction of three (3) new compressor stations in West Virginia. At

the time of the initial submission, the compressor station site locations had not been

selected and, therefore, were not included in the Project mapping.






161

Tetra Tech recognizes that determining an indirect APE for the linear pipeline corridor is

challenging as there is no precise and practical method for creating an accurate viewshed

model for a pipeline corridor in deeply dissected, heavily wooded terrain like that found

in West Virginia. Tetra Tech proposes that the initial indirect APE for the 188.5-mile-

long pipeline corridor, exclusive of the compressor station locations, be defined as 0.25-

mile (1,320 ft.) on either side of the Project centerline. The width of the indirect APE can

be revised in consultation with WVDCH based on the results of the initial phase of

inventory work. To assist in the revision of the initial APE, Tetra Tech will document, in

tabular format, the 381 previously recorded architectural resources located within one-

mile of the Project. However, new photographs and updated Historic Property Inventory

(HPI) Forms will not be provided for these resources, unless specifically requested by

your office (J. Brennan, phone conversation, January 5, 2015 with Sydne Marshall-Tetra

Tech, and Richard Estabrook-NextEra Energy).

Subsequent to the October 2014 submittal, compressor station sites were selected. Bare

earth viewshed maps showing areas in the Project vicinity that would have a view of each

compressor station have been created using engineering specifications (58 feet maximum

height) and a USGS digital elevation model with a ten-foot contour interval. Based on

the viewshed mapping, the remote setting, and the historic context developed for the

Project, Tetra Tech proposes that the initial indirect APE for the compressor station

locations be defined as a 0.5-mile (2,640 ft.) radius around each compressor station.

Tetra Tech acknowledges that resources located outside of the initial indirect APE may

have a view of the cleared pipeline corridor, in particular, those with “ridge views” of the

corridor, or views of the pipeline corridor as it descends a ridge (J. Brennan, 5 January

2015). However, Tetra Tech does not anticipate this scenario to occur beyond the

proposed 0.50-mile initial indirect (0.25-mile on either side) APE based on the density of

vegetation and the deeply dissected terrain.

Based on background research and the historic context developed for the Project,

resource types most likely to be affected by alterations to the existing landscape include,

but are not limited to: agricultural properties, agricultural and rural historic landscapes,

military landscapes, state and federally-managed forests and lands, and recreational areas.

Such resources would be evaluated using HPI Forms if identified by Tetra Tech during

field and background investigations, or brought to the attention of WVDCH or Tetra

Tech before the end of the FERC public comment period. FERC, as the lead federal

agency for the NEPA process, is required to solicit public comments on the Project. The

FERC, through its eComment feature accepts comments throughout the life of the

Project. In addition, a public scoping period (typically 30 days) will allow the public to

provide comments on the scope of the NEPA document. Mountain Valley Pipeline is

required to formally respond within 14 days to all comments received during the scoping

period. In addition, once a Draft Environmental Impact Statement (DEIS) is issued,






162

FERC will have another comment period (typically 45 days) where they will solicit

public comments on their analysis.

Tetra Tech’s Architectural Historian, Ms. Hannah Dye, would record architectural or

historic resources style-dated as 50 years old (circa 1967) or older within the indirect

APE, by windshield survey. Each resource would be photographed and the location

keyed to a map. Tetra Tech would then provide the photographs (two to a page) along

with a map to your office for review within two weeks of completion of field surveys.

Any other recorded information would be summarized in a matrix in Excel spreadsheet

format. The need for more detailed recordation (including the completion of HPI forms)

would be determined by your office following your office’s review of the submitted

materials.

The suggested indirect APE will be illustrated on figures that would be attached to the

Work Plan Amendment.

We request your review of the proposed initial indirect APE and survey strategy. We

look forward to your response and appreciate your continued assistance.

<image001.jpg>

James T. Marine , RPA | Cultural Resources Manager Pittsburgh PA: Direct:: 484-680-

9997 | Personal Fax: 412.921.4040

[email protected]<mailto:[email protected]>

Tetra Tech | Natural & Cultural Resources

661 Andersen Drive, Foster Plaza 7, Pittsburgh, PA 15220-2745

PLEASE NOTE: This message, including any attachments, may include privileged, confidential

and/or inside information. Any distribution or use of this communication by anyone other than

the intended recipient is strictly prohibited and may be unlawful. If you are not the intended

recipient, please notify the sender by replying to this message and then delete it from your

system.










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Request:


19. Document that the following cultural resources survey reports were reviewed by the

Virginia Department of Historic Resources (VDHR), and file the VDHR’s comments on

the reports:

a. Mountain Valley Pipeline Project, Phase IB Archaeological Survey Report,

Franklin County, Virginia;

b. Phase I Reconnaissance Architectural Survey for the Mountain Valley Pipeline,

Franklin County, Virginia;

c. Mountain Valley Pipeline Project, Phase 1B Archaeological Survey Report, Giles

County, Virginia; and

d. Mountain Valley Pipeline Project, Phase II Work Plan, Pittsylvania, Franklin,

Roanoke, Montgomery, and Giles Counties, Virginia.

Response:

The following table summarizes when reports were submitted to and reviewed by the Virginia

Department of Historic Resources (VDHR). The VDHR’s comments on the reports are included

in the updated correspondence filed with this submittal to FERC.


Reports Submitted and Reviewed by VDHR

Report Date Submitted to

VDHR Date of VDHR Comments

Mountain Valley Pipeline Project, Phase IB Archaeological Survey Report, Franklin County, Virginia

Transmittal letter September 11, 2015

Comment letter December 30, 2015

Phase I Reconnaissance Architectural Survey for the Mountain Valley Pipeline, Franklin County, Virginia

Transmittal letter October 8, 2015

Comment letter January 6, 2016

Mountain Valley Pipeline Project, Phase 1B Archaeological Survey Report, Giles County, Virginia

Transmittal letter December 1, 2015

Comment letter December 31, 2015

Mountain Valley Pipeline Project, Phase II Work Plan, Pittsylvania, Franklin, Roanoke, Montgomery, and Giles Counties, Virginia

Transmittal letter November 20, 2015

Record of Telephone Conversation December 4, 2015






164










165


Request:


20. Provide a schedule for filing cultural resources survey reports, and the SHPOs’ comments

on those reports that cover the following counties: Nicholas, Greenbrier, Fayette,

Summers, and Monroe in West Virginia; and Craig, Montgomery, Roanoke, and Floyd in

Virginia. Also, provide a report documenting an architectural survey of Giles County,

Virginia, and file the SHPO’s comments on that report.

Response:


Schedule for Filing Resource Survey Reports and SHPO Comments

State Counties Report Submission

Date Anticipated Comment Date FERC Filing Date

VA Craig, Montgomery,

Roanoke, Floyd Phase IB Archaeology 2/1/2016 3/1/2016

VA Giles Architectural 2/1/2016 3/1/2016

WV Nicholas, Greenbrier,

Fayette VOL III Combined Archaeological and

Architectural 12/23/2015 1/23/2016

WV Summers and Monroe VOL IV Combined Archaeological and

Architectural 2/1/2016 3/1/2016

*Floyd County is within the indirect APE.










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Request:


21. Revise the survey report for Wetzel, Harrison, Doddridge, and Lewis Counties, West

Virginia (Espino et al. July 2015), to address the comments of the WVDCH in its

October 6, 2015 letter. Revise tables 6.1.1-1, 6.2.1-1 6.3.1-1, and 6.4.1-1 to include the

distance (in feet) from each historic architectural site to the pipeline centerline, and an

assessment of project effects (such as visual and audible impacts which may alter the

character of any historic properties). Clarify what is meant by “previously surveyed” and

“new field survey” on figures 6.1.1-1+, 6.2.1-1+, 6.3.1-1+, 6.3.1-1+, 6.4.1-1+. If

“previously surveyed” means previously recorded, provide a list of all previously

recorded architectural sites in the indirect APE, including county/state, site number/name,

type, MP, distance (in feet) to the pipeline centerline, recorder/company/date, NRHP

evaluation, assessment of project effect, recommendations for future investigations, and

SHPO opinion and date. Indicate which previously recorded architectural sites were

relocated and assessed by Mountain Valley. Explain why any previously recorded site

was not relocated.

Response:

In comments dated October 6, 2015 the WVDCH requested that additional work be conducted at

46WZ134 at the location of a possible gravestone to determine if it marks a burial. Mountain

Valley Pipeline conducted supplementary work and after removing the undergrowth determined

that historic burial was present as marked by a paired head and footstone. The results of this

supplementary work will be presented in an addendum to the Volume I Cultural Resources

Report. It is anticipated that the addendum report will be submitted by February 26, 2016.

WVDCH concurred with all other recommendation concerning archaeological resources and

approved the Phase II workplans for sites recommended for Phase II significance evaluations.

Please see letter form WVDCH dated October 6, 2015, in Resource Report 4. Appendix J, filed

October 23, 2015.

Attachment RR4-21 contains the following revised tables: Volume I - Table 6.1.1-1, Table

6.2.1-1, and Table 6.4.1-1 (note that there is no Table 6.3.1-1 in Volume I); and Volume II –

Table 6.1.1-1 and Table 6.2.1-1. The attachment includes privileged information and is labeled

“Contains Privileged Information – Do Not Release.” The revised tables include a list of all

previously recorded architectural sites in the indirect APE, county/state, site number/name, type,

MP, distance (in feet) to the pipeline centerline, recorder/company/date, NRHP evaluation,

assessment of project effect, recommendations, and SHPO opinion and date.






167

The West Virginia reports use the terms ‘previously surveyed’ and ‘previously recorded’

interchangeably. The terms refer to sites that are recorded within WVDCH site files and have

been reported to WVDCH as a result of previous surveys in the state. Any sites previously

surveyed or previously recorded that are indicated by WVDCH mapping to be located within the

indirect or direct effects APEs were all re-located by Mountain Valley’s historic architecture

team. In a number of instances, the mapped site locations proved to be inaccurate. When

recognized, the map locations were corrected and are included in the report figures. The

corrected location data were also provided to WVDCH.

The tables noted earlier indicate which resources were previously recorded and thus relocated by

placement of an ‘x’ in the column titled ‘previously recorded’. All previously recorded

resources within the direct and indirect effects APEs were re-located by Mountain Valley’s

historic architecture team.










168


Request:


22. Revise the archaeological survey report for Braxton and Webster Counties, West Virginia

(Espino et al. October 2015) to address the comments of the WVDCH conveyed in a

November 16, 2015. Revise tables 6.1.1-1 and 6.2.1-1 to indicate the distance from each

historic site to the pipeline centerline. Indicate which previously recorded architectural

sites were relocated and assessed by Mountain Valley. Explain why any previously

recorded site was not relocated. Reassess project effects on the Weston and Gauley

Turnpike Bridge, and present a plan to avoid, reduce, or mitigate adverse effects on this

site. Attach copies of official state site forms for all sites in the APE.

Response:

WVDCH Comments Archaeological Resources

The WVDCH concurred with all comments concerning archaeological resources and approved

the Phase II workplans for sites recommended for Phase II significance evaluations (see

Attachment RR4-22). Copies of Archaeological Site Forms were included in the WV Cultural

Resources Volume II Report filed with FERC October 12, 2015. Please see Appendix E of the

Volume II Report.

Architectural Resources

Please note that the revisions to Tables 6.1.1-1 and 6.1.2-1 noted in Request 22 have been

incorporated into Attachment RR4-21. Copies of Architectural Site forms were included in the

WV Cultural Resources Volume II Report filed with FERC October 12, 2015. Please see

Appendix D of the Volume II Report.

Weston and Gauley Bridge Turnpike (NR#98001430)

The NRHP-listed Weston and Gauley Bridge Turnpike (NR#98001430) is a historic turnpike,

portions of which are located in the vicinity of Burnsville and Walkersville, Braxton County. The

resource was resurveyed and reevaluated during Mountain Valley Pipeline’s architectural survey

and was assigned temporary field number 0057. Additional information including mapping

depicting its location in relationship to the centerline and photographs can be found in Cultural

Resources Survey, Volume II, Braxton and Webster Counties, West Virginia, Appendix 4-O.

More specifically, the resource is represented in Table 6.1.1-1, Figure 6.1.1-1, and Photos 7.2.2-5






169

and 7.2.2-6; the updated West Virginia Historic Property Form for the resource (including

photographs) can be found in Appendix D of that report.

The Weston and Gauley Bridge Turnpike is an unpaved, 10-mile long section of trail,

approximately 60 feet in width. The route was built starting in 1847 to provide access to Sutton

for transport of product to grist mills and sawmills, and provided access to the Bulltown

sawmills. During the American Civil War, the turnpike was used in 1861 by Union troops to

move to take control of western Virginia. It was also critical in the movement of troops during

the Battle of Bulltown on October 13, 1863. Today, the turnpike is a contributing, resource to the

Bulltown Historic Area and it was listed on the NRHP (Criterion A), in 1995.

Mountain Valley Pipeline’s architectural survey revealed that the condition of the turnpike

remains in fundamentally the same condition as when it was NRHP listed. The Weston and

Gauley Bridge Turnpike was an important link in establishing an early road system in West

Virginia. Other roads were built to connect to the turnpike and provide a system of transportation

in the region. Because the new road, U. S. 19, followed the valleys instead of the ridges where

the old turnpike was located; several sections remain in essentially in original condition,

including the section that is NRHP-listed. The turnpike continues to reflect the movement in

West Virginia to establish land routes for transportation. Mountain Valley Pipeline’s

architectural survey resulted in a recommendation that the resource maintains a level of historic

integrity which warranted it NRHP-listing under Criterion A; the NRHP-listed section of

turnpike continues to reflect events that have made a significant contribution to the broad

patterns of our history. The turnpike’s period of significance 1849-1917, as recommended per

the NRHP nomination, remains applicable.

However, Mountain Valley Pipeline’s architectural survey revealed that the NRHP boundary, as

represented in the NRHP nomination, does not correlate with the construction features of the

turnpike, as mapped and surveyed in the field and did not align with cartographic and

photographic sources.

Due to its location within the direct APE and inconsistencies in how the resource’s limits were

represented in: 1) the WVSHPO GIS NRHP boundary shapefile, 2) Google Earth aerial imagery,

and 3) USGS quadrangle maps; the NRHP-listed Weston and Gauley Bridge Turnpike (0057)

(NR#98001430) was resurveyed by Mountain Valley Pipeline using deferentially corrected Leica

survey-grade GPS receivers (WV Vol. 2 Report, Figure 6.1.1-1). In instances where tree cover

obstructed the satellite coverage it was necessary to use a Leica total station to perform

conventional terrestrial survey methods that tied into the established primary control. Civil

features and existing conditions were mapped to survey grade accuracy and delivered to

Mountain Valley Pipeline engineering staff to assist with the avoidance of the resource during

route selection and workspace design. GIS files derived from this survey data were provided to

WVDCH so that they may be integrated into the WVSHPO GIS. As currently designed, the

Mountain Valley Pipeline route will traverse this location by boring beneath the ground surface,






170

avoiding any direct impacts to the turnpike’s limits. Additionally, Mountain Valley will leave a

buffer of approximately 100 feet on both sides of the trail where trees will not be cleared and the

ground not disturbed. .See Attachment RR4-22a for a typical construction detail depicting

Mountain Valley Pipeline’s plan to conventionally bore beneath, and in turn avoid, the Weston

and Gauley Bridge Turnpike.










171


Request:


23. File either an avoidance plan or a treatment plan for the archaeological sites at Pence

Spring, Summers County, West Virginia. Elsewhere in West Virginia, file site-specific

avoidance plans for historic archaeological site 46HS99 in Harrison County; and St.

Bernard’s Church and cemetery (46LE42/80), and sites 46LE81 and 82 in Lewis County.

Also, file avoidance plans or site-specific evaluation-testing plans for sites 46HS100,

101, 104, 109, and 111 in Harrison County; and 46LE77 in Lewis County. Document

that the avoidance, evaluation-testing, or treatment plans were submitted to the WVDCH,

and file the WVDCH’s comments on the plans.

Response:

Site-specific evaluation plans were submitted for sites 46HS100, 101, 104, 109, and 111 in

Harrison County; and 46LE77 in Lewis County were submitted to the WVDCH as Appendix I of

Volume I Cultural Resources Survey Report. WVDCH concurrence of the Phase II workplans

can be found in Resource Report 4 Appendix 4-J, filed October 23, 2015. Please see letter from

WVDCH dated October 6, 2015, Page 6, Paragraph 5.

Attachment RR4-23 depicts the Limits of Disturbance of the Pipeline in relation to sites 46HS99,

St. Bernard’s Church and cemetery (46LE42) in Lewis County and Sites 46LE80 and 81 in

Lewis County. These sites are located within the 300’ direct APE but are outside the Projects

Limits of Disturbance. Attachment RR4-23 includes privileged information and is labeled

“Contains Privileged Information – Do Not Release.”










172


Request:


24. Explain why previously recorded architectural site HS-0495-006 in Harrison County,

West Virginia listed on appendix 4-C-1 of RR 4 within the direct APE was not relocated

by Tetra Tech’s survey.

Response:

The circa-1900 Fielder House / Proffitt House (HS-0495-006), located on CR 4-5/Big Elk Road,

in Harrison County, West Virginia was resurveyed during Mountain Valley Pipeline’s

architectural survey. An updated West Virginia Historic Property Inventory form was completed;

the resource was assigned temporary field survey number 0177. Additional information

including mapping depicting its location in relationship to the centerline and photographs can be

found in Cultural Resources Survey, Volume I, Wetzel, Harrison, Doddridge, and Lewis

Counties, West Virginia, Appendix 4-N. More specifically, the resource is represented in

Table 6.2.1-1, Figure 6.2.1-1; the updated West Virginia Historic Property form for the resource

(including photographs) can be found in Appendix D of that report.

During the course of architectural field survey, as previously recorded resources are relocated

and resurveyed, discrepancies are often discovered between the locational data provided by the

SHPO and the locational data captured by architectural survey field staff. In these cases, these

discrepancies are reconciled in order to provide the most accurate and up-to-date locational data,

as confirmed by field survey, to the SHPOs. In the case of (HS-0495-006), the locational data

provided by the SHPO indicated that the resource was located across the road from the residence

and west of CR 4-5/Big Elk Road, when in fact, field survey confirmed its location as being on

the east side of the road. As such, this is the reason for the slight variation between the resource’s

location as per the SHPO data and the Mountain Valley Pipeline architectural survey location

data for (Field Survey No. 0177) (HS-0495-006), previously recorded as the Fielder House /

Proffitt House. A description and evaluation of significance for the resource, as provided in the

updated West Virginia Historic Property Inventory Form is as follows:

Description

The buildings and structures on this parcel were previously recorded in 2002. Since that time, the

two-story residence has been altered with the replacement of 4/4 windows with 6/6 windows

with false muntins at the projecting bay.

Outbuildings:






173

6A. The garage has no visible alterations since the previous recordation

6B. This garage is not visible from the public right-of-way and it is unknown whether it remains

on the parcel

6C. This building is not visible from the public right-of-way and it is unknown whether it

remains on the parcel

6D. The cellar house has no visible alterations since the previous recordation

Statement of Significance

The previous recordation of the buildings did not evaluate the resource for NRHP eligibility.

This resource is not associated with noteworthy events and does not reflect significant themes in

history. Therefore, it is recommended not NRHP-eligible under Criterion A. The role of this

small subsistence farmstead is not clearly defined by the collection of extant buildings and

features of this property. No information linking this house to any significant person could be

located in various histories of Harrison County. As such, it does not meet NRHP Criterion B for

eligibility. The main dwelling is constructed in the frame vernacular style of architecture, a form

commonly found throughout Harrison County and therefore the resource is recommended not

NRHP-eligible under Criterion C.










174


Request:


25. For Virginia, revise the archaeological survey reports for Giles County (Reeve et al.

November 2015), Franklin County (Reeve et al. September 2015), and Pittsylvania

County (Reeve et al. September 2015) to include copies of individual official state site

forms. Address the comments raised by VDHR in its October 27, 2015 letter.

Response:

Copies of the individual official state archaeological site forms are included as Attachment RR4-

25a. Mountain Valley Pipeline addressed the comments raised by VDHR in its letter of October

27, 2015, and sent the package containing the comment responses to VDHR on January 8, 2016.

The package is contained within Attachment RR4-25b.

Attachments RR4-25a and RR4-25b include privileged information and are labeled “Contains

Privileged Information – Do Not Release.”










175


Request:


26. File site-specific avoidance plans for archaeological sites 44GS231, 232, 233, 235, 236,

44FR355, and 44PY421 and 427 in Virginia. Document that the avoidance plans were

submitted to the VDHR, and file their comments on the plans with the FERC.

Response:

In the locations of archaeological sites 44GS231, 44GS232, 44GS233, 44GS235, 44GS236,

44FR355, 44PY421 and 44PY427, Mountain Valley Pipeline has defined the Project’s limit of

disturbance. Site-specific avoidance plans consist of the figures contained within Attachment

RR4-26 which display the respective sites in relation to the defined limit of disturbance in each

location. Attachment RR4-26 includes privileged information and is labeled “Contains

Privileged Information – Do Not Release.” Mountain Valley Pipeline is committed to

avoidance of these sites as demonstrated in these figures. The site-specific avoidance locations

will be marked as sensitive areas on construction plans and where these sensitive areas (i.e. site

locations) are located closer than 50 feet of the limit of disturbance, a high-visibility temporary

barrier that may be seen by equipment operators will be placed so that there will not be

accidental breaches of site avoidance during construction.










176


Request:


27. File site-specific plans for future investigations at historic architectural sites 003-5304,

003-5325, 003-5327, and 003-5387 in Virginia to assess their NRHP eligibility.

Document that the plans were submitted to the VDHR, and file their comments on the

plans with the FERC.

Response:

The three-digit prefix 003 is assigned to architectural resources in Alleghany County, Virginia.

Alleghany County is outside the Area of Potential Effects for the Project.










177


Request:


28. Provide an assessment of project effects for the Appalachian National Scenic Trail, the

proposed Bent Mountain Historic District, and the five previously recorded NRHP-listed

historic districts that would be crossed by the proposed pipeline route (Pence Spring

Hotel Historic District in Summers County, West Virginia; Newport Historic District and

Greater Newport Rural Historic District in Giles County, Virginia; the North Fork Valley

Rural Historic District, in Montgomery County, Virginia; and the Blue Ridge Parkway

Historic District in Floyd County, Virginia). Include a plan to avoid, reduce, or mitigate

adverse effects on the trail and the historic districts, that takes into account potential

audible, visual, and other project impacts that may alter the character or integrity of the

districts.

Response:

Mountain Valley will employ construction techniques that avoid or minimize potential effects to

the Appalachian National Scenic Trail and NRHP -listed and -eligible historic districts. As

currently designed, the Mountain Valley route will traverse this location by boring beneath the

ground surface, avoiding any direct impacts to the Trail’s limits. It is anticipated there could be

some temporary audible and visual effects associated with the pipeline construction. If it is

determined that the Mountain Valley Project will result in adverse effects to NRHP -listed and/or

-eligible properties, then avoidance plans will be developed. If avoidance of some historic

properties is not possible then treatment plans will be developed in consultation with the West

Virginia Division of Culture and History, and the Virginia Department of Historic Resources and

Interested Parties.










178


Request:


29. Provide a copy of the FS cultural resources survey of the pipeline route through Jefferson

National Forest, documentation that the report was reviewed by the VDHR, and file the

VDHR’s comments on the report; or submit a schedule for when those tasks would be

completed.

Response:

In December 2015, the United States Forest Service informed Mountain Valley that due to a

recent decline of internal resources, it would prefer that Mountain Valley perform the

archaeological survey of the Project located on Forest Service land. In response, Mountain

Valley developed an Archaeological Resources Protection Act (ARPA) Permit Application.

Mountain Valley Pipeline submitted the ARPA application to the Forest Service for review and

approval on January 8, 2015. Once the ARPA Permit is issued to Mountain Valley, a survey of

the Project area through the Jefferson National Forest will be conducted. When completed, a

report will be written and provided to the Forest Service for review. If the Forest Service

concurs with the survey, Mountain Valley Pipeline will also provide the report to VDHR for

review and comment. Alternatively, the Forest Service may itself submit the report to VDHR as

part the consultation under Section 106 of the National Historic Preservation Act, 1966, as

amended. Mountain Valley anticipates that, following award of the ARPA Permit and weather

permitting, the cultural resources survey of the pipeline route through Jefferson National Forest

and subsequent preparation of a report will take place during the first quarter of 2016.










179


Request:


30. Provide a copy of the study of cultural attachment by Applied Cultural Ecology,

documentation that the study was submitted to the FS, and file the FS’ comments on the

report; or submit a schedule for when those tasks would be completed.

Response:

The cultural attachment study report by Applied Cultural Ecology is in preparation. Mountain

Valley Pipeline anticipates submission of the report to the Forest Service and FERC by February

1, 2016. To the extent the Forest Service does not file its comments on the FERC docket,

Mountain Valley Pipeline will file with the FERC comments from Forest Service once they are

received.










180


Request:


31. File responses from Indian tribes to Mountain Valley’s letters dated December 2, 2014

and May 5, 2015, including from the Delaware Nation, Peoria Tribe, Stockbridge-

Munsee, and United Keetowah Band of Cherokee, as listed in Appendix 4-V of RR 4.

Resolve the discrepancies between section 11.2 of appendix 4-A and table 4.2-1 of RR 4.

The Summers County Historic Landmark Commission was included in RR4 but not in

appendix 4-A.

Response:

Mountain Valley Pipeline has received responses to letters dated December 2, 2014 and May 5,

2015 from the Delaware Nation, Peoria Tribe, Stockbridge-Munsee, United Keetowah Band of

Cherokee, and the Tuscarora Nation (received following the filing of our application to FERC).

These responses are attached as Attachment RR4-31.

Section 11.2 of Appendix 4-A and Table 4.2-1 of Resource Report 4 are in agreement. Section

11.2 of Resource Report 4 Appendix 4-A refers only to Virginia while Section 11.1 of Appendix

4-A discusses West Virginia where one bullet lists the Summers County (West Virginia Historic

Landmark Commission. Table 4.2-1 of Resource Report 4 combines the discussion of both

Virginia and West Virginia and lists together all parties that have requested consulting party

status.










181


Request:

Resource Report 5 – Socioeconomics

1. Provide a table of major tourist attractions in the project area by county/state. Indicate

the distance between the pipeline and those tourist attractions.

Response:

A list of major tourist attractions in the Project area is provided in the following table. Several

attractions are located in multiple counties; the distance in the table is the closest distance to the

Project. Additional information on potential impacts and mitigation measures associated with

these attractions is provided in Resource Reports 5 and 8.

Major Tourist Attractions in the Project Area

Attraction County a/ Approximate Distance from

the Project

West Virginia

North Bend Rail Trail Harrison County Crossed by the pipeline

Lantz Farm and Nature Preserve Wetzel County 5.0 miles

Lewis Wetzel WMA Wetzel County 6.0 miles

Smoke Camp WMA Lewis County 0.6 mile

Stonewall Jackson Lake WMA Lewis County 2.1 miles

Stonewall Resort (at Stonewall Jackson Lake State Park) Lewis County 4.3 miles

Staunton-Parkersburg Turnpike (Scenic Byway) Lewis County Crossed by the pipeline

Burnsville Lake WMA Braxton County TBD

Weston Gauley Bridge Turnpike Braxton County Crossed by the pipeline

Elk River WMA Braxton County 0.3 mile

Big Ditch WMA Webster County 0.4 mile

Meadow River WMA Greenbrier County Adjacent to laydown yard

Cranberry WMA Nicholas, Webster, and Greenbrier Counties

1.9 miles

Holly River State Park Webster County 5.0 miles

Summersville Lake Nicholas County 1.1 miles

Cranberry Tri-Rivers Rail-Trail Nicholas County 2.0 miles

Gauley River Nicholas County Crossed by the pipeline

Jefferson National Forest Monroe County Crossed by the pipeline

Appalachian Trail Monroe County Crossed by the pipeline

Virginia

Appalachian Trail Giles County Crossed by the pipeline

Jefferson National Forest Giles County Crossed by the pipeline






182

Major Tourist Attractions in the Project Area

Attraction County a/ Approximate Distance from

the Project

Peters Mountain Wilderness Giles County 75 feet

Cascade Falls Giles County 2.6 miles

Mountain Lake Park and Resort Giles County 2.4 miles

Whitt-Riverbend Park Giles County 1.9 miles

Greater Newport Rural Historic District Giles County Crossed by the pipeline

Roanoke River Montgomery County Crossed by the pipeline

Elliston Park Montgomery County 0.6 mile

Shenandoah Bike Trail and Park Montgomery County 2.4 miles

Bottom Creek Gorge Montgomery County 2.2 miles

Cahas Mountain Roanoke County 1.5 miles

Cahas Overlook Roanoke County 4.7 miles

Camp Roanoke Roanoke County 1.4 miles

Poor Mountain Overlook Roanoke County 1.5 miles

Blue Ridge Parkway Roanoke and Franklin Counties

Crossed by the pipeline

Slings Gap Overlook Franklin County 2.6 miles

Pigg River (State Scenic River) Franklin County Crossed by the pipeline

White Oak Mountain WMA Pittsylvania County 1.7 miles

a/ Several attractions are located in multiple counties and/or states. Only the counties within the Project area are listed in this table.










183


Request:


2. Provide a detailed discussion of the anticipated socioeconomic impacts resulting from the

proposed project on the tourism industry and associated local economies. Outline any

measures Mountain Valley would implement to minimize those impacts.

Response:

Potential impacts to the recreation and tourism industry are discussed in Section 5.3.2.3 of

Resource Report 5. While the potential exists for the Project to have localized effects on

recreation resources, construction and operation of the Project is not expected to substantially

affect the recreation and tourism industry in the affected counties. Construction activities would

be short-term and localized, with potential impacts reduced by proposed mitigation. Impacts to

specific recreation areas and activities are assessed in Resource Report 8, which also outlines the

measures that Mountain Valley Pipeline would implement to minimize those impacts.










184


Request:


3. Provide a table that lists all cities, towns, and communities within 10 miles of the pipeline

route. Additionally, update tables 5.2-1, 5.2-4, and 5.2-8 to include the associated

information for each of the communities.

Response:

The following table lists the communities within 10 miles of the pipeline route. These

communities were identified from TIGER/Census data (2015 Gazetteer). A total of 70

communities were identified within 10 miles.

Communities within 10 Miles

State/County Census Name Distance (miles)

Virginia

Franklin Boones Mill town 2.0

Franklin Ferrum CDP 9.1

Franklin Henry Fork CDP 4.8

Franklin North Shore CDP 6.7

Franklin Penhook CDP 1.7

Franklin Rocky Mount town 2.4

Franklin Union Hall CDP 2.6

Franklin Westlake Corner CDP 7.4

Giles Glen Lyn town 8.8

Giles Narrows town 6.9

Giles Pearisburg town 3.2

Giles Pembroke town 1.5

Giles Rich Creek town 7.2

Montgomery Belview CDP 9.0

Montgomery Blacksburg town 3.9

Montgomery Christiansburg town 9.4

Montgomery Elliston CDP 1.0

Montgomery Lafayette CDP 0.3

Montgomery Merrimac CDP 6.0

Montgomery Prices Fork CDP 6.2

Montgomery Shawsville CDP 4.3

Pittsylvania Blairs CDP 8.8

Pittsylvania Chatham town 2.7

Pittsylvania Gretna town 5.6

Pulaski Belspring CDP 9.0

Pulaski Parrott CDP 8.4

Roanoke Cave Spring CDP 7.7

Roanoke Glenvar CDP 4.8






185

Communities within 10 Miles

State/County Census Name Distance (miles)

Salem Salem city 8.5

West Virginia

Braxton Burnsville town 5.7

Braxton Flatwoods town 7.6

Fayette Meadow Bridge town 5.4

Gilmer Sand Fork town 8.7

Greenbrier Alderson town 5.4

Greenbrier Quinwood town 0.8

Greenbrier Rainelle town 1.2

Greenbrier Rupert town 2.5

Harrison Clarksburg city 8.3

Harrison Enterprise CDP 9.9

Harrison Gypsy CDP 9.4

Harrison Hepzibah CDP 8.5

Harrison Lumberport town 7.1

Harrison Salem city 1.9

Harrison Shinnston city 9.4

Harrison Spelter CDP 9.2

Harrison Wallace CDP 0.7

Harrison West Milford town 7.8

Harrison Wolf Summit CDP 2.8

Lewis Jane Lew town 9.2

Lewis Weston city 6.5

Marion Mannington city 9.3

Monroe Peterstown town 5.6

Monroe Union town 8.4

Nicholas Craigsville CDP 1.2

Nicholas Fenwick CDP 6.0

Nicholas Nettie CDP 1.0

Nicholas Richwood city 8.4

Nicholas Summersville city 8.0

Nicholas Tioga CDP 3.3

Summers Hinton city 7.4

Webster Addison (Webster Springs) town 7.6

Webster Camden-on-Gauley town 0.8

Webster Cowen town 1.2

Webster Parcoal CDP 9.3

Wetzel Hundred town 9.5

Wetzel Jacksonburg CDP 4.9

Wetzel Littleton CDP 9.9

Wetzel Pine Grove town 7.4

Wetzel Reader CDP 9.9

Wetzel Smithfield town 1.5






186










187


Request:


4. As previously requested in our comments dated August 11, 2015, provide a detailed

discussion on those counties where housing for the workforce is expected to be limited or

absent (i.e., Doddridge, Monroe, and Webster Counties). Include the communities where

workers are anticipated to be housed while working within these counties and the

distance to the worksite. Indicate the measures that would be implemented to mitigate

the impact of construction workers competing with visitors for hotel rooms, especially

during peak tourist seasons.

Response:











188


Request:


5. Clarify the following discrepancies regarding table 5.3-1:

a. table 5.1-2 listed the Stallworth Compressor Station in Fayette County, West Virginia

with a peak workforce of 100 (75 non-local). However, table 5.3-1 does not appear to

account for those 75 non-local workers in the spread 6 workforce numbers;

b. table 5.3-1 listed a peak non-local workforce of 611 workers for spread 7. However,

that spread contains only pipeline construction, which would have a peak non-local

workforce of 536. Clarify why there are an additional 75 workers within that spread;

and

c. a total of 559 peak non-local workers are listed for spread 11. However, the pipeline

would require 536 non-local workers, while the Transco Interconnect delivery meter

station would require an additional 30 non-local workers. This would result in a peak

non-local workforce of 566 workers.

Response:

a and b The apparent discrepancy between Table 5.1-2 and 5.3-1 occurs because table 5.3-1

does not correctly identify the counties that would be crossed by construction

spreads 6, 7, 9, and 10. Fayette County, for example, is incorrectly identified as part

of construction spread 6 when it should be represented in construction spread 7. The

correct counties are listed for these spreads in table 5.1-3 in Resource Report 5.

Following revisions to the route, the numbers were updated, but the lists of counties

were not. The counties for construction spreads 6, 7, 9, and 10 were also incorrectly

identified in table 5.3-2. Updated tables are presented below.

c. This comment is correct. The peak non-local workforce for spread 11 is 566, not

559. This correction applies to both tables 5.3-1 and 5.3-2 (see the updated tables

below).






189

Table 5.3-1 (updated)

Projected Non-Local Workers by Construction Spread

Spread State County 2013

Population a/

Average Employment Peak Employment

Number of Non-Local Workers

b/, c/

Percent of 2013

Population

Number of Non-Local

Workers b/, c/

Percent of 2013

Population

1 West Virginia Wetzel, Harrison 85,176 394 0.5 671 0.8

2 West Virginia Harrison, Doddridge, Lewis

93,768 317 0.3 536 0.6

3 West Virginia Lewis, Braxton 30,954 317 1.0 536 1.7

4 West Virginia Braxton, Webster 23,395 382 1.6 641 2.7

5 West Virginia Webster, Nicholas 34,858 317 0.9 536 1.5

6 West Virginia Nicholas, Greenbrier 61,609 317 0.5 536 0.9

7 West Virginia Greenbrier, Fayette, Summers, Monroe

108,289 368 0.3 611 0.6

8 West Virginia/ Virginia

Monroe, Giles 30,408 289 1.0 536 1.8

9 Virginia Giles, Craig, Montgomery

118,342 289 0.2 536 0.5

10 Virginia Montgomery, Roanoke, Franklin

246,066 289 0.1 536 0.2

11 Virginia Franklin, Pittsylvania 118,761 302 0.3 566 0.5

a/ Existing population data are estimates prepared by the U.S. Census Bureau 2014a. These estimates are presented by county in Table 5.2-1.

b/ Estimated numbers by construction spread include the estimated workforce required to build the compressor and meter stations (see Tables 5.1-2 and 5.1-3).

c/ Non-local workers are those who normally live outside daily commuting distance of the work sites. Non-local workers are assumed to comprise 75 percent of the total estimated workforce for each Project component.






190


Estimated Construction-Related Housing Demand by Construction Spread

Spread c/ State County

Estimated Housing Demand a/

Estimated Available Housing Resources b/

Average Employ-

ment (Workers/

Month)

Peak Employ-

ment (Workers/

Month)

Housing Units

Available for Rent d/

Hotel and Motel

Rooms

RV Spaces e/

1 West Virginia Wetzel, Harrison 394 671 732 1,663 na

2 West Virginia Harrison, Doddridge, Lewis

317 536 617 1,916 160

3 West Virginia Lewis, Braxton 317 536 230 801 703

4 West Virginia Braxton, Webster 382 641 194 383 631

5 West Virginia Webster, Nicholas 317 536 226 690 640

6 West Virginia Nicholas, Greenbrier 317 536 575 1,993 855

7 West Virginia Greenbrier, Fayette, Summers, Monroe

368 611 933 2,048 1,361

8 West Virginia/ Virginia

Monroe, Giles 289 536 236 181 48

9 Virginia Giles, Craig, Montgomery

289 536 775 2,326 16

10 Virginia Montgomery, Roanoke, Franklin

289 536 1,808 5,266 298

11 Virginia Franklin, Pittsylvania 302 566 928 1,225 213

a/ An estimated 75 percent of the total construction workforce is assumed to be non-local for the duration of the Project. b/ Housing data are presented by county in Table 5.2-8. Data are only presented for counties that would be directly crossed. c/ Estimated housing demands by construction spread include the estimated workforce required to build the compressor and meter stations. d/ Many of these available units include more than one bedroom and, if rented, could be occupied by more than one worker. A large number of in-migrating workers on similar projects typically rent a room in a house or live five in a rented house (BLM 2013). e/ Data are presented for counties that would be directly crossed only. Data were compiled from rvparking.com. Actual numbers may vary and information on the number of spaces was not available for some campgrounds/RV parks.










191


Request:


6. Estimate the average length of time (in months) a worker would be employed during

project construction.

Response:

The average length of time a worker would be employed is 10 months for the pipeline and

8 months for aboveground facilities.










192


Request:


7. Estimate the average number of employees per spread that may share accommodations,

and provide the source of that data.

Response:

After discussions with the potential pipeline contractors, the average number of employees per

spread that may share accommodations would be 25-30 people.










193


Request:


8. Estimate how many construction workers would bring their families to the project area,

and estimate the average family size, and the number of school age children. Include

these addition numbers in all population estimates.

Response:

Information gathered from construction contractors indicate many workers bring spouses, but

few bring children. The average number of families with kids on a typical spread is estimated to

be approximately 35 of various ages. The families tend to be small, one to two children and

often home schooled. As a result, the number of school age children expected to relocate is very

limited and will have very little effect on school enrollment in the Project area given a spread

encompasses 20 to 25 miles.










194


Request:


9. As previously requested in our March 13, 2015 comments, provide a detailed discussion

regarding impacts on local apiaries and honey bees due to removal of flowering

vegetation along the proposed pipeline route. Include measures Mountain Valley would

implement to reduce impacts on local apiaries and honey bees.

Response:

As discussed in Resource Report 3, the construction right-of-way width would be limited to 125

feet in uplands, and 75 feet in wetlands where possible, and the duration of construction in any

one area along the Mountain Valley Pipeline would generally not extend beyond one growing

season. Flowering vegetation comprises some fraction of the vegetation that would be disturbed

in any one area. Considering the limited width of the temporary construction disturbance, any

impact on flowering vegetation would be a small fraction of the area of flowering vegetation

available for honey bees or native pollinators in the broader area, and would not be expected to

have an impact on local apiaries. This small temporary impact on flowering vegetation will be

offset by Mountain Valley’s proposed use of permanent seed mixes that will include perennial

flowering plants specifically intended to improve long-term habitat for domestic and native

pollinators. It is expected that the long-term permanent benefit to honey bees and native

pollinators will be significantly greater than any temporary impact that may occur during

construction. See Resource Report 3 for detailed discussion of the proposed use of native

flowering plants as part of right-of-way restoration.










195


Request:


10. Indicate the training, funding, or additional facilities that Mountain Valley would provide

to local law enforcement, fire departments, and other first responders in order to handle a

pipeline accident.

Response:

Local law enforcement, fire departments and other first responders are trained and qualified in

their respective disciplines to respond to emergency situations. Specifically for fire departments,

the states of West Virginia (as defined in Title 87 Legislative Rule Fire Commission, Series 8

Volunteer Firefighter’s Training, Equipment and Operating Standards) and Virginia have defined

requirements for staffing, training and equipment that prepares and enables firefighters to

successfully manage public safety and fight secondary fires as a result of a pipeline emergency.

The Virginia Department of Fire Programs is a state agency, reporting to the Secretary of Public

Safety. The agency’s two primary functions are to distribute the Fire Programs Fund and to

provide training to Virginia’s firefighters. There are several other duties that the agency is

responsible for as a part of their role in state government and in carrying out the policies

established by the Virginia Fire Services Board.

To help ensure response efforts are efficient, Mountain Valley will establish and maintain

relationships with local fire departments and emergency responders to build familiarity with the

Project assets, emergency shutdown and isolation systems, and Mountain Valley monitoring and

isolation protocols. Additionally, Mountain Valley will coordinate and financially support

periodic response drills and table-top exercises, and incorporate education on the hazards of

natural gas. To further enhance pipeline emergency response knowledge, Mountain Valley will

provide additional resources (PHMSA - Emergency Response Guidebook, National Association

of State Fire Marshals - Pipeline Emergencies textbook) and incorporate key aspects into

discussions and drills. Mountain Valley is committed to supporting fire department budgets,

equipment and training needs with community involvement and support through local donations

and various organizations.

Respondent: Shawn Posey

Position: Senior Vice President – Engineering and Construction








196


Request:


11. Revise the “Traffic and Transportation Management Plan” attached as appendix 5-B to

provide:

a. list of all roads to be used for access, organized by federal, state, county, private;

b. counts of current traffic on the federal, state, and county roads that would be used

for access, during the time period 6:00am to 7:00pm, with peak traffic hours

recognized;

c. estimates of project-related construction traffic on each of the access roads, by

construction spread, with peak periods recognized;

d. indicate how Mountain Valley would document the pre-construction condition of

all access roads;

e. verify that Mountain Valley would repair all roads damaged by construction of

the project;

f. list of equipment types and number of vehicles to be used for construction of the

project by spread;

g. number of buses to be used by spread to transport workers from yards (identified)

to the pipeline right-of-way;

h. number of water trucks and volume of water per truck for each construction

spread;

i. type of tackifiers that may be used;

j. any road improvements that may be necessary to accommodate construction

traffic;

k. measures that would be implemented at rural neighborhoods to ensure landowners

would have maintained access to their houses; and

l. documentation that the revised Traffic Plan was provided to all state and local

highway departments, and file their comments on the plan.






197

Response:











198


Request:


12. Indicate whether Mountain Valley would be willing to track, investigate, and report to the

FERC quarterly for a period of two years following granting of in-service any

documented complaints from a directly affected or abutting homeowner whose insurance

policy was cancelled or materially increased in price as a result of the project. Further,

provide measures that Mountain Valley would implement to mitigation impacts

documented during the process above.

Response:

Mountain Valley is willing to track, investigate, and report to the FERC quarterly for a period of

two years following granting of in-service any documented complaints from a directly affected

homeowner whose insurance policy was cancelled or materially increased in price as a direct

result of the project.

Several commenters have indicated speculative concerns regarding insurance impacts; however,

these concerns are unfounded. The easement agreements pipeline companies negotiate with the

landowners can include indemnification language, which means the landowner or their agent

(i.e., the homeowners insurance companies) have no responsibility for damage or injury during

the construction or operation of the pipeline. In those instances, Mountain Valley would have

responsibility for such damages. Because the insurance industry determines coverage or

premiums based on risk evaluations, it is feasible to assume that homeowners insurance

companies would attribute minimal additional risk to the execution of pipeline

easements. Mountain Valley is willing to review any potential mitigation on a case-by-case

basis and will state any mitigation in the quarterly report mentioned above.


Position: Senior Vice President - Construction and Engineering








199


Request:

Resource Report 6 – Geologic Resources

1. As previously requested in our comments dated August 11, 2015, identify which caves in

proximity to the pipeline are used recreationally and which could provide habitat for bats.

Response:

Caves considered as recreational and in proximity to the proposed Mountain Valley Pipeline

Project include Pig Hole Cave, Tawney’s Cave, and Smokehole Cave. These caves are also

considered potential habitat for wintering bats. Canoe Cave is considered potential bat habitat

and would provide recreational value for local and regional cave enthusiasts if the landowner

decided to grant access. Canoe Cave has been closed to all visitation for over 30 years and was

added to the Virginia ‘closed cave list’ in September 1989.

All other caves in proximity to the Project are either obscure, rarely visited, or visitation is

strictly limited or expressly denied by the landowner.










200


Request:


2. As previously requested in our comments dated August 11, 2015, outline measures

Mountain Valley would implement to protect, avoid, and minimize construction impacts

on existing oil and gas wells located within close proximity to project work areas.

Response:

Mountain Valley Pipeline has identified and will continue to identify oil and gas wells within the

study corridor. Mountain Valley Pipeline has accounted for and avoided identified oil and gas

wells in its routing. Mountain Valley Pipeline will place orange safety fence around the

perimeter for identification purposes.










201


Request:


3. Provide source information for table 6.1-1 and table 6.1-2.

Response:

Elevation information was obtained from the U.S. Geological Society (USGS) 7.5-minute series

topographic quadrangle excerpts located in Resource Report 1. The link to this information is

here:

http://viewer.nationalmap.gov/basic/?basemap=b1&category=ned,nedsrc&title=3DEP%20View.

A complete table, by milepost, of the geology along the MVP alignment, as well as geologic

mapping, is available from West Virginia (West Virginia GIS Technical Center 2015a) and

Virginia (Virginia DMME 2015a) and is provided in Appendix 6-A.










202


Request:


4. As previously requested in our comments dated August 11, 2015, provide the following

with regards to surficial geology:

a. table listing surficial geology by MP; and

b. description of surficial geology crossed within each physiographic province.

Response:

Section 6.1.1 provides a discussion of the general surficial and topographic characteristics of

each physiographic province. Additional discussion was provided in the response to Resource

Report 6, Request 3. As discussed in Section 6.1.2, surface geology mapping is not available

from geological surveys. Surface geology is generally limited to river valleys and alluvial

deposits. However, these are not specifically mapped in the Project area. Therefore, a column for

surficial geology was not provided in Table 6.1-2 as such information is not available.










203


Request:


5. As previously requested in our comments dated August 11, 2015, revise table 6.3-1 to

provide the following information:

a. a column which identifies whether the mine is a surface or underground mine;

b. why so many mine statuses are identified as unknown and consult additional sources

to determine if the mines listed are active; and

c. notes within the table to identify statuses such as completely released, reclaimed, and

numerous outfalls.

Response:


Respondent: Joseph Park

Position: Landman








204


Request:


6. Section 6.3.2 states “there are 347 oil and gas wells in West Virginia within 0.25 mile of

the Project route…” However table 6.3-2 sums to only 337 wells. Resolve the apparent

discrepancy.

Response:

Table 6.3-2 provides the correct number of wells. The discrepancy was due to a typographical

error.










205


Request:


7. As previously requested in our comments dated August 11, 2015, provide the following

with regards to mining:

a. specific procedures that would be used with regards to communicating with mine

operators and what activities would require mine operators to notify Mountain

Valley;

b. discussion of the potential for landslides, slumping, subsidence resulting from

permitted, active, and future surface and subsurface mining activities along the

proposed pipeline route;

c. a discussion of the issues raised in WVDEP’s May 22, 2015 letter to the FERC;

d. a discussion of how current and future mine hazards would be identified;

e. measures that would be implemented if mine hazards are encountered during

pipeline installation; and

f. a discussion of construction and post-construction monitoring of the pipeline

route over mining areas.

Response:











206


Request:


8. Provide maps that depict the location of all surface and subsurface coal mines (permitted,

active, closed, reclaimed or currently in the reclamation process, and known abandoned)

within 0.25 mile of the pipeline alignment and aboveground facilities.

Response:



Position: Landman








207


Request:


9. Section 6.3.3 identified four underground coal mines that the pipeline alignment would

cross in West Virginia and stated that Mountain Valley would develop specific mitigation

measures in coordination with the mine operators. Provide an update of this coordination

and outline specific mitigation measures necessary to protect the pipeline from current

(ongoing) or future mining operations.

Response:

For longwall mines, Mountain Valley Pipeline will monitor and mitigate potential impacts as

described in the forthcoming mine subsidence plan. Mountain Valley Pipeline will negotiate

terms for pillar mining operations with the mine operator and mineral owners to leave the

necessary support coal in place to protect the Project. Mountain Valley expects to submit the

mine subsidence plan by January 22, 2016.


Position: Landman








208


Request:


10. Section 6.6.1.2 (p. 6-40) stated that: “it is possible that ground subsidence could occur as

a result of underground mining,” and that “measures are in place in West Virginia that are

designed to protect the integrity and service of pipelines in areas where mining takes

place.” Discuss the measures in place for West Virginia to protect pipelines that cross

subsurface coal mines.

Response:

Mountain Valley Pipeline will take the necessary precautions to monitor and mitigate the

pipeline prior to mining advancing underneath. For longwall mining operations, Mountain

Valley Pipeline will be monitor and mitigating the pipeline as further described in the mine

subsidence plan (see the response to Resource Report 6, Request 11(e)). Mountain Valley

Pipeline will negotiate terms for pillar mining with the mine operator and mineral owner to leave

the necessary support coal in place to protect the Project. Mountain Valley expects to submit the

mine subsidence plan by January 22, 2016.


Position: Landman








209


Request:


11. Regarding historic (abandoned, closed, and reclaimed) mines that would be crossed by

the pipeline route, provide:

a. West Virginia agency guidance on recommended surface to top of mine

minimums;

b. documentation of coordination with the appropriate West Virginia agency(ies)

regarding recommendations for the crossing of historic mines;

c. a discussion of historic underground longwall and room and pillar mines that

could present a subsidence hazard to the project.

d. a discussion of landslides, slumping, and subsidence due to the pipeline crossing

previously mined areas, poorly reclaimed mining areas, and historic unknown

underground mines;

e. a Mine Subsidence Plan;

f. protocol of how historic mine hazards would be identified; and

g. measures that Mountain Valley would implement to protect the pipeline when

crossing closed and/or reclaimed mines.

Response:



Position: Landman








210


Request:


12. Address the comments of Murray Energy and Alpha Companies filed on November 25,

2015 regarding coal mining in the project area.

Response:

Mountain Valley Pipeline has been in contact with both companies. Mountain Valley Pipeline is

diligently working on a resolution or mutual agreement regarding any issues or concerns that

Murray Energy and Alpha Companies may have pertaining to the Project. See also the response

to Resource Report 6, Request 9.


Position: Landman








211


Request:


13. Provide revised maps at a scale that can be used to relate the location of the Coles Hill

uranium deposit and other uranium deposits in proximity to the proposed pipeline route

and route alternatives.

Response:











212


Request:


14. The D.G. Honegger Consulting September 19, 2015 Report (p. 8 of 25) stated that for

Class 1 pipe, the threat for loss of pressure integrity for cross-country portions of the

route from liquefaction settlement can be ruled out if the depth of cover over the pipeline

is less than 10 feet, and that an increase in pipe wall thickness will significantly reduce

the stress. Provide:

a. a discussion of the class of pipe that would be utilized for each area identified in table

6.4-2, particularly where the pipeline alignment traverses through areas adjacent to

the Pembroke Fault Zone; and

b. the minimum depth of soil cover for each of these areas.

Response:

a. Updated Table 6.4-2 is attached (Attachment RR6-14) and includes the class of pipe and

minimum depth of cover.

The class of pipe selected for the identified in Table 6.4-2 areas is based on the design,

installation and class location criteria described in USDOT 49 CFR 192. The selection of

minimum depth of soil cover is determined by the requirements stated in USDOT 49

CFR 192, the project design requirements for installation of pipeline crossing agricultural

lands and the crossing requirements for installation of pipe in navigable waterbodies.

Please see the responses Resource Report 1, FERC Data Requests 11 and 13 regarding

details on depth of cover under waterbody crossings and agricultural areas.

The Mountain Valley Pipeline begins its overlap of the Pembroke Fault Zone at milepost

178, and exits the extent of the graphical image of the zone at milepost 222. In this

roughly 44 mile span, only 7.75 miles is designated to be class 1 pipe. The 7.75 miles of

class 1 pipe is wholly located between milepost 178 and 186 which is on the outer fringe

of the fault zone. To eliminate the risk of liquefaction, none of this class I pipe will be

over 10 feet depth of cover.

There may be some potential for ground settlement from liquefaction from roughly

milepost 165 to milepost 240. The potential for liquefaction requires consideration of

specific characteristics of soil deposits along the pipeline route. Liquefaction settlement

can be screened out as not posing a credible threat to cross-country portions of the






213

pipeline provided the depth of cover is less than 10 feet. Mountain Valley does not plan

to utilize depth of cover of more than 10 feet.

b. Updated Table 6.4-2 is attached (Attachment RR6-14) and includes the class of pipe and

minimum depth of cover.










214


Request:


15. Revise table 6.4-1 to include the distance between each earthquake event and the

proposed pipeline.

Response:

The updated Table 6.4-1 (below) includes a column listing the approximate distance between the

epicenter (i.e., location on the Earth's surface above the earthquake hypocenter or focus, the

subsurface location where an earthquake originates) and the nearest milepost for the proposed

Project area.


Earthquakes Epicenters (magnitude 4 and greater) within 100 miles of the Mountain Valley Pipeline Since 1976

State / Lat/Long (UTC)

Date and Time Magnitude

(RM)

Distance from Project

(Miles) Nearest MP

West Virginia

37.362°N 81.624°W

1976-06-19 05:54:13 4.7 51.3 195.0

Virginia

37.238°N 81.987°W

1988-04-14 23:37:31 4.1 72.0 199.0

37.200°N 81.920°W

2006-11-02 17:53:02 4.3 68.7 199.0

37.157°N 81.975°W

2006-11-23 10:42:57 4.3 72.3 199.0

37.136°N 82.068°W

1989-04-10 18:12:16 4.3 77.6 199.0

Source: USGS 2015c UTC = lat/long as based on universal time zone coordinated km = kilometer










215


Request:


16. Section 6.4.1.2 stated that the peak ground acceleration with exceedance in 50 years

range from 0.05 g to 0.16 g, while figure 6.4-1 indicated that peak ground accelerations

along the pipeline route range from 0.04 g to 0.14 g. Clarify this apparent discrepancy.

Response:

Section 6.4.1.2 should read peak ground acceleration ranges from 0.04 g to 0.14 g, which is

consistent with Figure 6.4-1.










216


Request:


17. Section 6.4.2.1 stated that: “The analyses provided documentation that Mountain Valley

Pipeline will have adequate response time to mitigate sinkhole formations in the even

they should occur.” Clarify what is meant by that statement. Indicate the time period

necessary to implement mitigation measures if a newly formed sinkhole is discovered

along the pipeline route during construction.

Response:

As described in the Karst Mitigation Plan, Appendix 6-D, Resource Report 6, Mountain Valley

will deploy the Karst Specialist Team prior to and during construction in karst areas to monitor

for karst feature activation resulting from land disturbance during construction. Karst specialists

will provide immediate recommendations to Mountain Valley construction on mitigation

procedures, and if necessary confer with the appropriate state agency. Mitigation efforts,

including enhanced inspection of a feature, as described in the Karst Mitigation Plan can begin

within 24 hours of observing the feature.










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Request:


18. Provide definitions for sinkhole, small sinkhole, medium sinkhole, shallow sinkhole, and

large sinkhole as listed in table 6.4-3.

Response:

As stated in the Mountain Valley Pipeline Karst Hazards Assessment (Appendix 6-D.2, Resource

Report 6) a sinkhole is characterized as a depression in the ground surface that has no natural

external surface drainage. Areas with sinkholes are known as karst terrain or karst topography.

This landform is primarily associated with limestone or dolomite bedrock. With no outlet all

water flowing into a sinkhole must drain through the side or bottom of the feature into the

subsurface hydrologic system. Sinkholes are referred to as closed depressions or closed contours

on topographic maps.

Mountain Valley Pipeline incorporated qualitative descriptors of sinkholes identified in the karst

hazards evaluation as a means to further characterize sinkhole development. Mountain Valley

Pipeline adopted the following generalized characterization descriptors:

• Small sinkholes were the most commonly observed, with most small sinkholes being less

than approximately 25 feet in diameter (estimated distance at ground surface), with some

shallow sinkholes up to 75 or more feet in diameter. Most of the “small” sinkholes are

not represented in available terrain surface mapping data, and were observed in the field.

• Medium sinkholes were approximately 100 feet in diameter, estimated at the ground

surface.

• Large sinkholes were more than 100 feet in diameter, estimated at the ground surface,

and generally more than 10 feet deep.

Where sinkholes were characterized as “shallow” in the karst hazards assessment, this referred to

observations of a few feet in depth, often comprising a rolling topography.










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Request:


19. Revise figure 6.4-2 to depict all caves discussed in section 6.4.2.2 and table 6.4-4. For

example, Bobcat Cave is discussed in the section and table but not depicted on the figure.

Response:

Revised Figure 6.4-2 and Table 6.4-4 are included in Attachment RR6-19.










219


Request:


20. Section 6.4.2.3 stated that: “construction across or in the near vicinity of Canoe Cave and

a nearby spring at MP 213.7 may lead to impacts to that natural resource, long-term

differential settlement, and pipeline instability.” Discuss if Canoe Cave and the nearby

spring can be avoided. If not, identify the measures Mountain Valley would implement

to protect those natural resources, and protect the pipeline from settlement or instability.

Also, document recent communications with Virginia state agencies regarding the

pipeline route and construction near Canoe Cave.

Response:

Mountain Valley Pipeline will review the Project alignment in the vicinity of Canoe Cave for

potential adjustments to avoid the cave and its local hydrologic system. Mountain Valley

Pipeline will identify options for alignment adjustments in this area and expects to provide this

information to FERC by February 26, 2016.

Mountain Valley Pipeline representatives contacted Mr. Wil Orndorff, Virginia Department of

Conservation and Recreation – Karst Protection coordinator, regarding Canoe Cave on

September 18, 2015. At that time, field-verified location data for the cave was not available.

Subsequently, Mountain Valley Pipeline provided Mr. Orndorff on October 29, 2015 with data

on the field-verified location of Canoe Cave and associated spring, as well as locations of all

karst features confirmed in the field as of that date, and locations of karst features identified

during desktop review but not yet field-verified.










220


Request:


21. The pipeline alignment traverses through a significant density of mapped sinkholes

between MP 221.1 and MP 222.3. Evaluate reroutes that may avoid these features. If a

route modification is not feasible, provide the results of subsurface geotechnical and

geophysical investigations that characterize near-surface interconnected karst

development in this area.

Response:

Resource Report 10 presents information on Mountain Valley Pipeline alignment re-routes that

avoid karst features where practical. In the case of the Mount Tabor sinkhole plain (milepost

221.1 to milepost 222.3) the geologic formations that host the sinkhole development has a

geologic strike of approximately North 60-degrees east, which is nearly perpendicular to the

Mountain Valley Pipeline route. Therefore, based on the current route alignment, the sinkhole

plain cannot be completely avoided. No published geologic or geotechnical studies have been

completed on the Mount Tabor sinkhole plain in the vicinity of the Project area. For purposes of

constructing the pipeline through karst areas and simultaneously limiting impacts and protecting

sensitive karst features, Mountain Valley Pipeline prepared a Karst Mitigation Plan (Appendix 6-

D, Resource Report 6) that will be followed to guide Mountain Valley Pipeline construction

practices in karst areas. The Karst Mitigation Plan details site inspection procedures to identify

specific karst features located within the limit of disturbance. The plan also outlines

communication procedures between the karst specialist team and Mountain Valley Pipeline

construction staff. The plan also discusses when consultation with the Virginia Department of

Conservation and Recreation Karst Protection agency is necessary. Finally, the plan discusses

pipeline monitoring and mitigation procedures. The karst specialist team will be on-site prior to

and during construction in the Mount Tabor sink hole plain. The karst mitigation plan

recommendations will be followed in the event a karst feature is encountered.










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Request:


22. Section 6.4.3 stated that mitigation measures for potential slope stability areas would be

included in the “final pipeline design.” File an outline of the mitigation measures for

unstable slopes, or provide a schedule for the completion of the “final pipeline design.”

Response:

Mountain Valley Pipeline has completed the field reviews of the 26 areas identified to exhibit

slope stability issues. The results and recommendations from said reviews, including mitigation

measures, are being compiled. Mountain Valley expects to submit it to FERC by February 26,

2016.










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Request:


23. Provide LiDAR imagery for each area of potential landslide concern identified in

table 6.4-6.

Response:

Lidar imagery of each area is included in Attachment RR6-23. Due to the large file sizes and file

format, Mountain Valley is providing this attachment directly to the Commission and the third-

party contractor on a separate CD.










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Request:


24. Provide a plan that outlines the specific procedures that would be followed in the event of

an unanticipated discovery of paleontological resources during pipeline construction.

The plan should indicate who would be responsible for identifying a paleontological

resource, who would be contacted, their contact information, and measures that would be

implemented to avoid or mitigate impacts on the resource.

Response:

See Attachment General 1-m.










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Request:


25. Section 6.6.1.3 states that: “to minimize the buoyance effect upon the pipeline due to

liquefaction in those areas, the pipeline will be designed with concrete coating, concrete

weights, or gravel-filled blankets, as applicable.” However, table 6.4-2 is titled “Flood

Zones That Require Pipeline Weights (Aggregate Filled Sacks).” Clarify what type of

material would be used to weigh down the pipeline.

Response:

The pipeline will utilize aggregate filled sacks to minimize the buoyance effect on the pipeline.










225


Request:


26. Section 6.6.1.5 states that Mountain Valley’s contractor would prepare a karst-specific

ESCP. Provide a copy of that plan, or a schedule for when it would be filed with the

FERC. Document that the plan was submitted to appropriate state resource agencies and

file their comments with the FERC. The karst-specific ESCP should include measures

that would be used to stabilize sinkholes, and address state agency recommendations.

Response:

Karst specific erosion and sedimentation control plans will be submitted to FERC as part of the

overall Project erosion and sedimentation control plan. Mountain Valley expects to submit to

FERC the final erosion and sedimentation control plans by February 26, 2016.










226


Request:


27. Provide an update of the status of completing the karst surveys/hazard assessment, and

water resource identification along the pipeline alignment through karst terrain and

provide:

a. documentation of communications with the Indian Creek Watershed Association

regarding their October 14 and November 13, 2015 comments to the FERC

identifying additional karst features and springs in close proximity to the pipeline

alignment;

b. a review of Classification and Geo-referencing Cave/Karst Resources across the

Appalachian Landscape Conservation Cooperative (by Dr. David Culver of American

University); and

c. an updated bibliography of all materials used in the desktop review to identify karst

features in the project area.

Response:

While Mountain Valley continues its efforts to gain permission from the owners to access

properties to complete field verification for karst features in order to supplement the desktop

review, a select few property owners continue to reject Mountain Valley’s requests to access

their property. A follow-up request for access is planned for submittal by Mountain Valley.

Under the standard protocol Mountain Valley would be able to access properties by the end of

January 2016. It is estimated that two (2) weeks will be required to review the properties, with

data analysis and reporting completed over the following two weeks. Mountain Valley will

complete the karst hazards assessment and expects to provide the information to FERC by

February 26, 2016. Mountain Valley will continue to clearly identify areas where field surveys

are unable to be conducted and therefore were evaluated only through the desktop review

process. The desktop review process includes utilizing public domain data sources, recently

flown lidar and aerial photography, and Mountain Valley’s Karst Specialist team’s more than 70

years of combined expertise on the karst hydrogeology of southern West Virginia and

southwestern Virginia.

27a Response

While Mountain Valley has not directly communicated with Indian Creek Watershed

Association, the following discussion addresses the technical comments presented by the Indian






227

Creek Watershed Association in letters presented to FERC, dated October 14, 2015 and

November 13, 2015.

The first letter, dated October 14, 2015, showed boxes with spring counts but gave no detailed

location or indication of actual potential impact. Most of the parcels noted are not in karst areas.

The clipped image below shows five (5) springs referenced in the letter on a parcel in the karst

area.

ICWA map graphic, 10/14/15

1. Karst features between Little Mountain and Peters Mountain……

-sinkholes, Rich Creek Cave, sinking stream

We are aware of these features but we have not been allowed access to this area by the property

owner to conduct field verification.

2. Karst features close to the Mountain Valley Pipeline crossing of Indian Creek near

Greenville….

-karst, caves, sinkholes, sinking streams

The Town of Greenville is located about 1.7 miles east of the alignment and upstream along

Indian Creek. The areas around Greenville are karst, the nearest mapped location being 0.2 miles

east, but again upstream and upgradient of the Project area.

Greenville Saltpeter Cave is located 0.5 miles north-east of the Town of Greenville and 1.8

miles upstream of the alignment.

Indian Draft Cave is located 0.84 miles east of milepost 179.5. It is a spring entrance on the

east side of Indian Draft and 2.4 miles upstream of the confluence with Indian Creek. The

drainage is a small watershed further to the east. The Indian Draft surface stream parallels the

alignment for approximately1 mile to the east from about milepost180 to milepost182.






228

Hans Creek Cave is also a spring and located about 1.36 miles west of the alignment and

downstream along Indian Creek. It is located on the opposite side of Hans Creek Valley from the

alignment and appears to drain an area to the west of Hans Creek.

Greenville Glenray Cave is located about 0.2 miles east and upstream of milepost181.9.

Mountain Valley Pipeline believe this is the new cave mentioned in ICWA’s November 13, 2015

letter. Field surveys have not been completed in this area and no further information is available

at this time.

“The Bull Hole”, a local name for a spring reported by ICWA in Slate Run near milepost181.8

is located on a property where Mountain Valley Pipeline has not been allowed access. It appears

the elevation difference of the “sinking stream” segment below this spring as described in

ICWA’s letter is about 15 to 20 feet above the level of Indian Creek and just upstream of the

road culvert. This desktop elevation approximation is based on the 2009 USGS 1/9th

LiDAR

derived National Elevation Dataset.

Due to the upstream/upgradient location and/or the distance from the Mountain Valley Pipeline

alignment, the caves and springs referenced were not included in our studies. There is negligible

risk that these features will be impacted by Mountain Valley Pipeline construction. “The Bull

Hole” spring along Slate Run and related waters has been added to the list for additional review

at such point access becomes available. Mountain Valley Pipeline is currently not aware of any

sinkholes in the vicinity of the alignment in this area.

3. Karst features along Ellison Ridge and in Hans Creek Valley……

-sinkholes, The Narrows of Hans, unknown cave, sinking stream

There is a narrow exposure of the Glenray and Reynolds limestones in the floor of Hans Creek

Valley. These are thin layers in the Bluefield shales. Depending on season, some or all of Hans

Creek sinks and rises in its bed at a location about 1.0 miles southwest of milepost185.0. The

subsurface flow is about 0.36 miles paralleling the county road. Additionally, several small

springs are purported to be in this area. However due to the distance and geologic setting the area

was not included in the studies completed for Mountain Valley Pipeline. There is negligible risk

that this feature will be impacted by Mountain Valley Pipeline construction.

The cave mentioned in the November 2015 letter appears to be what is known locally as

“Smokehole” and is on Ellison Ridge somewhere in the vicinity of milepost186.6. It is reported

to be a subsurface feature formed in sandstone that blows warm air, relative to surface air

temperature, in the winter and creates vapor. It is developed where the sandstone cap is

separating and sliding down the hillside. Mountain Valley Pipeline has not been granted access

to the property, but has been added to the list for additional review at such point access becomes

available.






229

Mountain Valley Pipeline is currently not aware of any sinkholes in the vicinity of the alignment

in the Ellison Ridge area which is comprised of the red and green shales and sandstones of the

Bluefield Formation. A review of the 2009 USGS 1/9th LiDAR derived, and 2003 USGS 1/9th

photogrammetrically derived, National Elevation Datasets do not indicate sinkholes. Ellison

Ridge is not karst.

27b Response:

The project led by Dr. David Culver of American University titled, ‘Classification and

Georeferencing Cave/Karst Resources across the Appalachian LCC’ (Culver, 2015a; Culver,

2015b) presents information on regional-scale biodiversity of cave fauna in the Appalachians. A

number of supporting GIS data layers were developed through Dr. Culver’s research such as

geology, hydrology, the physical landscape and the distribution of karst within the Appalachians.

The results are presented as ecoregions, counties, and 20 Km grid cells. These data are useful but

the scale and resolution are relatively coarse. Mountain Valley Pipeline’s efforts draw on work

such as Culver (2015a, 2015b), but more importantly Mountain Valley Pipeline’s researched

karst resources specific to the Project area (see Appendix 6-D of Resource Report 6).

27c Response:

Culver, D., 2015a. Classification and Georeferencing Cave/Karst Resources across the

Appalachian LCC. September 1, 2013 to August 1, 2015.

http://lccnetwork.org/project/classification-and-georeferencing-cavekarst-resources-across-

appalachian-lcc

Culver, D., 2015b. Classification and Mapping of Karst Resources, Appalachian Landscape

Conservation Cooperative, American University. 2015

http://applcc.org/research/cave-and-karst-classification-and-mapping/classification-and-

mapping-of-cave-and-karst-resources/classification-and-mapping-of-cave-and-karst-resources










230


Request:


28. Provide a schedule for the completion of the geotechnical landslide evaluation, and the

filing of a report of the evaluation with the FERC and appropriate state resource agencies.

Response:

Mountain Valley Pipeline has completed the field reviews of the 26 areas listed in Table 6.4-6.

The results and recommendations from said reviews, including mitigation measures, are being

compiled. Mountain Valley expects to submit it by February 26, 2016.










231


Request:


29. Section 6.6.1.2 stated that Mountain Valley would employ special construction

techniques where the slopes typically exceed 30 percent. These construction techniques

will require expanded workspace areas. Provide a detailed description of the specific

special construction techniques that Mountain Valley would use for slopes greater than

30 percent. Clarify if the expanded workspaces for steep slopes were included in

appendix 1-D (Additional Temporary Workspace Table).

Response:

As stated in Section 6.6.1.2, Mountain Valley will include additional erosion and sedimentation

control measures on steep slopes in order to control water movement on the right-of-way.

Special construction techniques, including winching equipment and cut-and-fill grading on steep

side slopes, are discussed in detail in said section, and also in Resource Report 1, Section 1.4.1.2.

As stated in resource report 1, Section 1.4.1.2, for special techniques greater than 35%:

Equipment used for the construction activity will be suspended from a series of winch tractors to

maintain control of the equipment and provide an additional level of safety. All construction

equipment and their winch lines will be inspected prior to operation to ensure the equipment is

operable and sound. Spoil piles adjacent to the trench will be protected by temporary sediment

barriers to keep excavated soils on the right-of-way. Pipe joints will be stockpiled at the top or

bottom of each slope. A side-boom tractor will be suspended from a winch that will carry one

joint at a time up or down the slope and place the joint along the trench line. The joint will then

be lowered into the ditch by a tractor. Welders will connect the joint to the previous joint within

the trench to assemble the pipeline. Once welding is complete, the welds will be visually and

radiographically inspected. The weld joints will be hand coated with fusion bonded epoxy

coatings in accordance with required specifications. The coating will be inspected for defects,

and repaired, if necessary. Sand or aggregate-filled sack trench breakers will be installed in the

trench along the pipeline to prevent or slow the movement of water along the trench. The

pipeline will be padded and the trench backfilled by equipment tethered to the winch tractors.

The surface of the right-of-way will be restored to original contours, and permanent slope

breakers will be installed in accordance with the erosion and sedimentation control plan. Erosion

control blankets or hydroseed, in lieu of mulch, will be installed on steep slopes to provide

stabilization for vegetation to help control sediment and water runoff.

On steep slopes, various measures will be taken in order to properly control erosion and

sedimentation on the right-of-way. Spoil piles from trenching operations will be staged along the






232

side of the right-of-way and will be compacted via rolling with dozers on site as additional

material is added. Once a soil pile is completed it will be temporarily mulched to control

washouts. Additionally, spoil piles will be separated at intervals of 50 feet by temporary water

bars which will serve to slow the flow of runoff down the right-of-way and divert it into straw

bales or No. 3 aggregate. Silt fence and super silt fence would be used to stop rocks from rolling

off the right-of-way. Other measures such as erosion control blankets, temporary mulching,

hydroseed, and sock filtration may be used.

Within the trench, sand filled sacks will be stacked across the width of the trench as necessary

based on field conditions. This will permit water to slowly filter through without carrying large

amounts of soil with it. Similarly, permeable trench breakers constructed of sand or aggregate-

filled sacks will be installed along the open ditch. Rock fall protection measures such as rock

fences, placement of concrete barriers, or creating catchment areas may be added where

excavation is planned at the top of steep slopes, as determined by the contractor. Once the area is

stabilized, following construction, Mountain Valley will remove any temporary stabilization

methods. Contours will be returned to pre-existing conditions to the extent practicable.

In addition to the measures taken on slopes to control erosion and sedimentation, trench drains

will be installed on side slopes and excessively steep slopes before the pipe is placed in order to

channel water away from the ditch and will not be removed after construction is complete. These

drains will consist of perforated tile or pipe surrounded with rock 1 inch stone or similar, which

may be taken from excavated spoils) that will terminate either at the bottom of a very steep slope

into a well vegetated area, near a roadway at the edge of the right-of-way, at the low point along

a side cut onto a riprap pad near the edge of the right-of-way, or at a wooded area off the right-

of-way.

In limited areas where the pipeline crosses laterally along the side of a slope, cut-and-fill grading

will be necessary to create a safe, flat work terrace. Generally, on steep side slopes, soil from the

high side of the right-of-way will be excavated and moved to the low side of the right-of-way to

create a safe and level work surface. After the pipeline is installed, soil from the low side of the

right-of-way will be returned to the high side, and the slope’s original contours will be restored.

Within a side-slope area, cut-and-fill operations to create a flat area require the excavation and

movement of large volumes of soil, which requires a construction right-of-way footprint upwards

of 200 to 300 feet wide. After installation of the pipeline, the cut-and-fill area must be restored to

preconstruction conditions and stabilized through soil packing, seeding, and other site-specific

soil stabilization measures, as necessary.










233


Request:


30. With regards to seismicity, as briefly mentioned in section 6.6.1.3, provide the specific

design criteria that would be adopted by Mountain Valley to meet standards under U.S.

Department of Transportation Title 49 CFR Part 192, the American Society of Civil

Engineers, American Society for Mechanical Engineers, and American National

Standards Institute to protect its proposed facilities from earthquakes.

Response:

The statement concerning design criteria in Section 6.6.1.3 of Resource Report 6 is stating that

the design criteria for buried steel pipe will withstand stress created from potential seismic

activity in the vicinity of the pipeline route. The standards governing the design criteria for

buried steel pipe are 49 CFR Part 192 Subpart C and D; ASME B31.8-2014, Paragraph 840,

Design, Installation, and Testing, Paragraph 841, Steel Pipe, Paragraph; PRCI - Guidelines for

the Seismic Design and Assessment of Natural Gas and Liquid Hydrocarbon Pipelines.










234


Request:


31. In regards to section 6.6.2, discuss Mountain Valley’s proposed inspection program, to

monitor construction through areas with geological hazards, such as karst, and areas with

a high potential for subsidence and landslides.

Response:

Mountain Valley Pipeline will employ qualified and dedicated geotechnical inspectors to be on-

site during construction and restoration of the Project in areas of subsidence and landslide

concern. These inspectors will be tasked with daily inspections in the Project in areas with

geological concerns during construction and post-construction. Monitoring for environmental

concerns such as potential subsidence and landslides will be a part of the geotechnical inspectors

daily responsibilities.

The inspection regimen for karst resource protection prior to and during Mountain Valley

Pipeline construction is detailed in the Karst Mitigation Plan, Appendix 6-D, Resource Report 6.

Mountain Valley Pipeline will deploy a Karst Specialist Team prior to tree clearing and complete

a Level 1 inspection (defined in Karst Mitigation Plan) of karst features observed in the limit of

disturbance (LOD).

Mountain Valley Pipeline will deploy an on-site karst specialist team during construction

activities (clearing and grubbing, trenching, blasting, boring or drilling) within karst terrain. The

role of the Karst Specialist is to observe construction activities to assist in limiting potential

negative impacts, and to inspect, assess and if necessary mitigate karst features that are

encountered or form during construction in conjunction with recommendations from the

appropriate state agency (Virginia Department of Conservation and Recreation, Karst Protection;

West Virginia Department of Environmental Protection). Two or more Karst Specialists will be

available to conduct multiple inspections in karst terrain where Mountain Valley Pipeline

Construction crews may be working at different locations simultaneously.

If a suspected karst feature is intercepted during work activities, or forms within the LOD during

construction activities (clearing and grubbing, trenching, blasting, boring or drilling), the Karst

Specialist will conduct a combined Level 1 and Level 2 Inspection (both defined in the Karst

Mitigation Plan) of the feature.






235










236


Request:


Appendix 6-D – Karst Hazards Assessment

32. The Karst Hazards Assessment provides recommendations for minor route adjustments

ranging from 10 to 150 feet. Clarify if Mountain Valley would follow all of the

recommendations in the Karst Hazard Assessment, and adopt the modifications into its

proposed route.

Response:

Mountain Valley Pipeline will follow recommendations provided in the Karst Hazards

Assessment (Appendix 6-D.2, Resource Report 6) to avoid karst features. The specific distance

and direction for adjustments to land disturbance provided in the Karst Hazards Assessment were

intended to be general and to convey a relative scale of adjustment. In some cases, the

recommended adjustments were based solely on desktop review since property access for field

confirmation was not granted. Actual and specific alignment adjustments will be determined in

the field based on observed site conditions.










237


Request:



33. Table 2.7 and Karst Review (FERC 4.0.0) figures identify a significant number of

sinkholes, sinkhole complexes, and other karst features that are crossed by the pipeline

route. In addition, Canoe Cave (MP 213.71) is identified as extending at shallow depths

below the pipeline alignment. The results for non-linear pipe-soil interaction finite

element analysis (RR 6, section 6.4.2.1 and appendix 6-D.2) indicates that the bridging

capability of Class 2 pipe with a pipe wall thickness of 0.74 inches is 145 feet for 3 feet

of soil cover and 57 feet for 10 feet of soil cover. For each karst feature that crosses the

pipeline alignment provide the:

a. results for site-specific geophysical and geotechnical investigations to confirm that

each feature crossed would be within the limits of the bridging capabilities of the

proposed pipe, particularly where the pipeline traverses through the Mt. Tabor

Sinkhole Plain (MP 220.6 to MP 222.3); and

b. mitigation measures for each karst feature crossed that does not conform with the

minimum (modeled) bridging capabilities.

Response:

a. The Karst Hazards Assessment (Appendix 6-D.2, Resource Report 6) identifies karst

features within 0.25-mile of the Project area, and karst hazards within the proposed limit

of disturbance (LOD). Mountain Valley Pipeline has not been allowed to access certain

properties within the karst area to complete field confirmation of karst features, but is

diligently pursuing access agreements with the property owners. The results of the Karst

Hazards Assessment completed to date were used to provide recommendations for karst

hazard avoidance. Alignment adjustments (see Resource Report 10) have been completed

to avoid identified hazards where possible. Mountain Valley Pipeline continues to

evaluate options in the vicinity of Canoe Cave, Giles County, Virginia. In the case of the

Mount Tabor sinkhole plain (milepost 221.1 to milepost 222.3) the geologic formations

that host the sinkhole development has a geologic strike of approximately North 60-

degrees east, which is nearly perpendicular to the Mountain Valley Pipeline route.

Therefore, based on the current route alignment, the sinkhole plain cannot be completely

avoided. The Karst Mitigation Plan and Sinkhole Hazards Assessment (Appendix 6-D.2,

Resource Report 6) provides guidelines for mitigating karst features if they cannot be






238

avoided, or if one forms during construction. Post-construction backfill and redress of the

ground will restore topography and drainage to pre-construction conditions that will not

promote long-term karst feature activation. With these measures in place, Mountain

Valley Pipeline has addressed the majority of concerns related to karst, and is prepared to

address new concerns that may arise during construction. Unless and until a feature is

encountered that cannot be mitigated in accordance with the guidelines provided in the

Karst Mitigation Plan and Sinkhole Hazards Assessment (Appendix 6-D.2, Resource

Report 6), for which additional geotechnical and geophysical evaluations may be

recommended by the Karst Specialist Team (see Karst Mitigation Plan) there are no site-

specific data available for submittal at this time.”

b. As noted in the previous discussion addressing Data Request 33a, Mountain Valley

Pipeline has completed (where access was granted) a Karst Hazards Assessment to

identify features and implement avoidance through alignment adjustment. The Karst

Mitigation Plan and Sinkhole Hazards Assessment documents (Appendix 6-D.2) discuss

inspection, assessment and mitigation measures for karst features. The specific mitigation

measure for a karst feature that does not conform to the minimum bridging capabilities

will be unique to the feature, and cannot be specified. The Karst Specialist Team will

inspect and assess a karst feature if encountered, where necessary notify the appropriate

state agency, and provide recommendations to Mountain Valley Pipeline on how best to

mitigate the hazards. This process will result in the most effective mitigation measures to

be employed. If this level of mitigation is required, the appropriate state agency will be

consulted, as discussed in the Karst Mitigation Plan (Appendix 6-D.2).










239


Request:



34. Table 2.7 and Karst Review (FERC 4.0.0) identifies a “large spring” 300 feet northwest

of the pipeline at MP 213.63 that appears, based on topography, to discharge to Sinking

Creek just north of the spring. For this spring:

a. provide the results of spring discharge measurements; and

b. determine if the spring is connected to Canoe Cave.

Response:

The karst spring located approximately 300 feet northwest of the Project Area milepost 213.63

flows into Sinking Creek approximately 850 feet further downstream.

a. The karst spring is anticipated to have a highly variable discharge pattern correlated with

local precipitation patterns and seasonal variations. Spring discharge data does not provide a

specific benefit or added protection for the spring. Karst-specific erosion and sediment

control measures, and guidelines provided in the Karst Mitigation Plan (Appendix 6-D.2,

Resource Report 6) will be implemented during construction to protect the karst features,

spring and stream.

b. It appears that the karst spring is hydrologically connected to Canoe Cave, located

approximately 900 feet from the spring. This conclusion was reached by observing that

historic cave mapping indicates pools in the lower passages of Canoe Cave and the karst

spring discharge are both at approximately the same topographic elevation.










240


Request:



35. The Karst Mitigation Plan (attachment 3.0) stated that mitigation would be conducted per

state guidelines, and indicated that Karst Level 1 and 2 inspections that would be

conducted prior to tree clearing. Provide a discussion and general construction

drawings/schematics for the range of mitigation measures that would be used to ensure

that recharge rates to the karst groundwater system is not compromised.

Response:

The primary karst protection measure employed by Mountain Valley has been to conduct a Karst

Hazards Assessment (see Resource Report 6) and from these results adjust the proposed

alignment to avoid karst features (see Resource Report 10). Mountain Valley also compiled a

Karst Mitigation Plan (see Resource Report 6) to address the protection of karst features, and

ensure pipeline safety relative to karst hazards. The Mitigation Plan specifies that a Level 1

inspection will be completed by the Karst Specialist team on a karst feature observed within the

limits of disturbance. If the Level 1 inspection results suggest further assessment of the karst

feature is necessary, a Level 2 inspection would be conducted by the Karst Specialist team. The

Level 2 inspection will be used to evaluate whether mitigation is required, and serve to support

the design of mitigation measures by the Karst Specialist team.

Based on the experience of the Karst Specialist team, the most common mitigation effort that

may be required (assuming feature avoidance is not practical) is sinkhole stabilization. The most

common procedure is a reverse-gradient back-fill to stabilize the sinkhole against further

collapse (see following schematic drawings that summarize the sinkhole stabilization procedure

for different sized watersheds). Karst-specific erosion and sediment control activities will also be

employed to maintain pre-construction stormwater drainage characteristics and prevent acute or

long-term sediment transport directly to a karst feature.

Given that the proposed construction trench is relatively shallow, and acknowledging Mountain

Valley’s avoidance measures to protect karst resources, it is assumed that only a limited range of

mitigation measures to stabilize sinkholes would be required. If unanticipated karst features other

than sink holes are encountered during land disturbance or construction, the Karst Specialist will

coordinate with Mountain Valley Construction and the appropriate state agency to identify the

most appropriate mitigation strategy. At this time, we cannot anticipate the nature of measures

that may be required other than sinkhole stabilization. The details of any additional mitigation

efforts that may be required in karst areas would be forthcoming at the time of construction and






241

in coordination between the Karst Specialist team, Mountain Valley Construction, and the

appropriate state agency.






242






243






244

Source: West Virginia Department of Environmental Protection, Division of Water and Waste

Management, Groundwater Protection Program, Sinkhole Mitigation Guidance, August 8, 2005










245


Request:



36. Table 2.7 referenced attachment 7 – Karst Area Geology and Geotechnical Report. This

document does not appear to have been included with Mountain Valley’s application to

the FERC. Provide a copy of this document.

Response:

The reference provided in Table 2.7 regarding an Attachment 7 – Karst Area Geology and

Geotechnical Report was a remnant from an earlier reporting format for Mountain Valley

Pipeline. The referenced document currently does not exist. With the October 2015 filing, the

information that was slated for Attachment 7 was integrated into Resource Report 6 for

Mountain Valley Pipeline.










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Request:

Resource Report 7 – Soils

1. As previously requested in our comments dated August 11, 2015, provide a discussion of

contaminated areas that maybe be located within 0.25 mile of the proposed pipeline

route. Provide the following:

a. sources searched to identify potentially and known contaminated areas; and

b. provide a timeframe for when the Unanticipated Discovery of Contamination Plan

will be made available.

Response:

The potential contaminated areas located within 0.5 miles of the pipeline route are identified in

Section 2.1.3.5 Potential Contaminated Groundwater and listed in Appendix 2-D Identified Sites

of Potential Contamination Concern, within 0.5 Mile of the Proposed Mountain Valley Pipeline

Project Work Space.

The sources used to compile this list were the EPA’s Facility Registry System database. This

database includes information on regulated sites for hazardous waste handling, releases to air,

water and federal cleanup sites. In addition, digital databases available from the West Virginia

Department of Environmental Protection and Virginia Department of Environmental Quality

were also searched for locations of potential contamination areas. This information is compiled

in Appendix 2-D.

Mountain Valley Pipeline also identified potential brine pits and well pads based on Google

Earth Imagery (September 2014) within 0.25-mile of the construction right-of-way (see Resource

Report 6 Appendix 6-C). Based on the imagery analyses, there is one potential brine pit located

within 150 feet of the Project construction right-of-way at milepost 54.3; and a total of 41

potential brine pits located within 0.25 mile of the construction right-of-way.

If contaminated soil or groundwater is encountered during construction, Mountain Valley

Pipeline will notify the affected landowner and will coordinate with the appropriate federal and

state agencies in accordance with applicable notification requirements.






247

An Unanticipated Discovery of Contamination Plan will be included as an Appendix to the Final

SPCC plan. This plan is currently in development. Mountain Valley expects to submit it to

FERC by February 26, 2016.










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Request:


2. As previously requested in our comments dated August 11, 2015, revise and update

tables and appendices to provide the information requested below:

a. temporary and permanent acreage impacts on soils for all project components,

including meter stations, compressor stations, pipe storage and contractor yards,

temporary and permanent access roads, and cathodic protection sites; and

b. impacts should be listed on a table formatted to address the following soil limitations:

prime farmlands and farmlands of statewide importance, compaction potential, water

erosion potential, wind erosion potential, revegetation potential, hydric soils,

rocky/stony soils, shallow depth to water table, and poor drainage potential. Hazard

potentials can be evaluated using the following criteria:

i. Prime Farmland Soils includes both prime farmlands and farmlands of

statewide importance, as designated by the U.S.D.A. Natural Resources

Conservation Service;

ii. High Compaction Potential include soils identified as clay loam or finer

texture and somewhat poor, poor, or very poorly drained drainage class;

iii. High Water Erosion Potential should be determined via the FS method for

determining soil erosion hazard as per the FS general comment;

iv. High Wind Erosion Potential for wind erodible soils include those with wind

erodibility groups of 1 or 2; and

v. Poor Revegetation Potential reports soils with a poor revegetation potential for

grasses.

Response:











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Request:


3. As previously requested in our comments dated August 11, 2015, provide a discussion of

revegetation procedures including:

a. the specific type of soil amendments and conditions under which the soil amendments

would be used; and

b. a summary of the methods that would be used in areas where there is a potential for

poor revegetation including seed bed preparation, seeding methods, seeding rates, and

anchoring methods.

Response:

a. There are no soil amendments proposed without a specific request from a landowner as to

type and application rates.

b. A detailed seeding plan developed by the Wildlife Habitat Council specifically for the

Mountain Valley Pipeline Project using tailored seed mixes for the Project’s native

restoration is included in Resource Report 3 and specifically in Appendix 3-D Right-of-

Way Seeding Plan.










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Request:


4. Provide the documented or estimated frost depth or frost line depth (in feet) in the project

area with regards to ground heaving as discussed in section 7.3.1.5.

Response:

Section 7.3.1.4 includes a discussion on frost heaving in this section on hydric soils as these soil

types are usually most affected by soil saturation, soil characteristics and cold temperatures.

According to the NOAA 1978 Geodetic Bench Marks, the maximum depth of frost penetration

within the area of the pipeline is between 20 and 30 inches. In many cases along the pipeline

ROW, specifically in the areas most likely affected by ground heaving, the frost line will be

above the top of the buried pipe.










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Request:

Resource Report 8 – Land Use, Recreation and Aesthetics

1. Clarify the following discrepancies between tables 3.2-1 and 8.1-2 and tables 1.3-1 and

1.3-2. Provide updated tables where necessary:

a. tables 1.3-1 and 1.3-2 report the total land required for construction of compressor

stations and meter stations as 94.6 acres, while tables 3.2-1 and 8.1-2 report

construction impacts from permanent aboveground facilities as 0.0 acres; and

b. tables 1.3-1 and 1.3-2 report the total land required for operation of compressor

stations and meter stations as 22.3 acres, while tables 3.2-1 and 8.1-2 report operation

impacts from permanent aboveground facilities as 20.52 acres.

Response:

Mountain Valley expects to provide a response by January 22, 2016.










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Request:


2. Update table 8.1-2 to include impact acreages by state/county and land use type for each

of the three compressor stations and four meter stations. If there are no impacts in a

county from any aboveground facilities, do not include in the table under that heading.

Response:











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Request:


3. Clarify the following discrepancies between appendix 1-C-1 and table 8.1-2:

a. table 8.1-2 listed impacts for contractor and staging yards in Fayette County, West

Virginia and Pittsylvania, Virginia; however appendix 1-C-1 does not include aerial

maps for contractor yards in these counties. Provide the missing aerial maps or

update table 8.1-2; and

b. verify that all project-related impacts listed in table 8.1-2 are based on current land

use for each state/county, correlated to recent aerial map data. For example, table

8.1-2 indicated that 23.17 acres of forested land, 5.46 acres of open land, and 2.95

acres of agricultural land would be impacted by contractor yards in Wetzel County,

West Virginia. However, the aerial maps in appendix 1-C-1 depict a single contractor

yard in Wetzel County located on predominantly industrial land.

Response:

a. There are no contractor and staging yards in Fayette County, West Virginia or Pittsylvania

County, Virginia. Mountain Valley is updating Table 8.1-2 and expects to file the updated

table by January 22, 2016.

b. All Project-related impacts listed in Table 8.1-2 are based on existing NLCD land use data.

No aerial interpretation was completed for land use GIS calculations.










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Request:


4. Table 8.1-2 listed 0.0 acres of total construction impacts due to aboveground facilities,

and 20.52 acres of operation impacts. Since construction impacts should include both

temporary and permanent impacts, clarify why there are permanent impacts but no

construction impacts. Verify that construction impacts throughout the table include both

temporary and permanent acres, and provide a revised table 8.1-2 containing the

appropriate corrections.

Response:

Mountain Valley expects to file a response by January 22, 2016.










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Request:


5. Clarify the discrepancy between tables 1.3-1, 3.2-1, and 8.1-2 and table 1-D.

Tables 1.3-1, 3.2-1, and 8.1-2 list construction impacts associated with additional

temporary work space areas as 738.2 acres, while the total area of impacts listed in

table 1-D is 723.5 acres.

Response:

Mountain Valley expects to file a response by January 22, 2016.










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Request:


6. Identify, by MP, all drain tiles and irrigation systems that would be crossed by the

pipeline. Summarize communications with landowners to specify measures that would

be implemented to protect drain titles and irrigation systems during construction, or

repair damages.

Response:

As stated in Section 8.1.3.1, Mountain Valley Pipeline will maintain irrigation and drainage

systems that cross the right-of-way to the extent practicable. Prior to construction, Mountain

Valley Pipeline will survey landowners and local agricultural agency personnel regarding the

potential presence of drain tiles and irrigation systems in affected agricultural fields. In addition,

observations will be made before and during construction for evidence of the presence of drain

tiles and irrigation systems. As drain tiles are discovered, Mountain Valley Pipeline will flag the

known locations of drain tiles.

In fields with drain tiles and irrigation systems, pipeline construction will be conducted in

accordance with the FERC Plan and Procedures. The pipe will be installed below agricultural

drainage lines, except in the rare circumstance of a deep main drainage line. If agricultural

drainage features must be modified during pipeline installation, these features will be restored to

pre-construction condition or repositioned if necessary in a manner consistent with drainage

orientation.

Should drainage tiles or irrigation piping be damaged during construction, Mountain Valley

Pipeline will repair/restore their function within three days of damage to the tiles. Mountain

Valley Pipeline will carefully mark the location of the damage in a prominent manner, such as a

securely staked lath with survey tape attached. Drain tile used for replacement shall be of the

same size and quality as the original tile encountered on site. If original tile is not available,

replacement tiles will be of appropriate size and materials to connect with the existing line

without loss of function. Mountain Valley Pipeline will coordinate the permanent repairs with

the landowner to ensure satisfaction of the repairs being completed by local tile experts.

Operation of the pipeline following construction and repair of damaged tiles and irrigation lines

is not expected to affect operation of drainage and irrigation systems.

Mountain Valley Pipeline is inquiring with landowners to determine if they have such systems

on their property and can assist Mountain Valley Pipeline in locating. To date, no landowners






257

have identified drain tiles or irrigation systems on their property. If damage occurs during

construction Mountain Valley Pipeline has committed to landowners with drain or irrigation

systems that will be repaired or replaced.










258


Request:


7. Identify, by MP, all organic farms that would be crossed by the pipeline. Summarize

communications with landowners to outline measures that would be implemented to

protect organic farms during construction, or site-specific measures that would be

implemented to minimize or mitigate impacts.

Response:

Landowners thus far that have indicated transitioning to organic farming on their property are

WV-MO-012.345 at MP 193.6, and VA-FR-160 at MP 273.1.

As discussed in Section 8.1.3.1, Mountain Valley Pipeline recognizes that certified organic land

is a unique feature of this landscape and is committed to treating this land with the same level of

care as other sensitive environmental features. Mountain Valley Pipeline is committed to

minimizing impacts to organic farms to the extent feasible. Mountain Valley Pipeline has

developed an Organic Farm Protection Plan (OFPP) to outline the special procedures and best

management practices (BMPs) that will be implemented during construction on farms in Virginia

and West Virginia that are organic certified or that are in active transition to being organic

certified by the United States Department of Agriculture (USDA). The OFPP is intended to

address the unique management and certification requirements of these organic farm operations.

These special procedures and BMPs may be implemented in addition to the other plans,

procedures, and BMPs Mountain Valley Pipeline has specified for use on the Project and used in

conjunction with those plans, procedures, and BMPs, as applicable. The provisions of the OFPP

will apply to certified organic agricultural land for which the landowner or tenant has provided

proof to Mountain Valley Pipeline of certification for organic farming within the affected

property. The OFPP will be provided to appropriate state agencies for review and comment and

will be re-filed with FERC when finalized.

Mountain Valley Pipeline will work with identified organic farms that are certified or are in

transition to be sure that all requirements are met to preserve the organic qualifications necessary

on landowners’ properties.










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Request:


8. Clarify in section 8.1.3.3 that only a 30-foot-wide corridor (15 feet on each side of the

pipeline centerline) would be kept in an herbaceous state. Indicate if Mountain Valley

would replant trees in the remainder of the permanent right-of-way and all temporary

workspaces in formerly forested areas. If not, explain why.

Response:

Appropriate vegetation management of the border zone with an objective of diversifying the

habitat, including structural and species diversity, without additional plantings is typically done

through integrated vegetation management practices under a ‘pipe zone – border zone’ approach

and typically leads to a healthy scrub-shrub habitat which acts as an ecotone between the forest

and the low growing early successional pipe zone.

Mountain Valley proposed to plant multiple native species with varying maturation

characteristics of growing. Mountain Valley does not intend to replant trees on the permanent

right-of-way to prevent damage to the pipeline caused by deep-rooted vegetation. A revegetation

plan was included in Resource Report 3 Appendix D and addresses native restoration seed mixes

that Mountain Valley Pipeline intends to utilize on all disturbed areas.










260


Request:


9. Table 8.1-4 listed 261 public roadway crossing, while table 8-A (appendix 8-A) listed

247 crossings. Clarify the apparent discrepancy and provide updated tables as necessary.

Response:











261


Request:


10. Table 8.1-5 listed 10 railroad crossing sites, while table 8-A (appendix 8-A) listed 11

railroad crossings. Clarify the apparent discrepancy and provide updated tables as

necessary.

Response:











262


Request:


11. As previously requested in our comments dated August 11, 2015, there are several

special use and recreation areas discussed in section 8.4.3 as being crossed or within 0.25

mile of the pipeline, but are not listed in table 8.3-1 or discussed in section 8.3. Revise

table 8.3-1 to include these areas and provide an updated discussion related to potential

project impacts on all special use and recreation areas crossed or in close proximity to the

pipeline. Outline measures Mountain Valley would implement to avoid, minimize, or

mitigate impacts on these special use facilities and recreation areas (such as, but not

limited to the Staunton-Parkersburg Turnpike, Interstate 79, and the Coal Heritage

Trail/Midland Trail).

Response:











263


Request:


12. As previously requested in our comments dated August 11, 2015, provide an updated

discussion of proposed mitigation measures developed in communication with nearby

landowners for visual impacts due to the Stallworth Compressor Station.

Response:

It is anticipated that there would be minimal visual impacts to the residence due to the

intervening forest vegetation and high relief terrain. This compressor station is located on a

forested hilltop with a forest vegetation buffer between the station site and the residence. If there

are visual impacts, it is anticipated that it will be from night lighting that will be necessary for

the security of the site.










264


Request:


13. Explain why Mountain Valley believes that installing its pipeline 0.04 mile from the

Mayapple Preschool and 0.05 mile from the Sunshine Valley School would have no

impacts on those schools. Indicate the measures that could be implemented to protect

those schools during construction and operation. Explore alternative routes that would

increase the distance between the pipeline and those schools. If those reroutes are

feasible, present an alternatives analysis for them.

Response:

Impacts to the Mayapple Preschool and the Sunshine Valley School may include temporary

limitations on access and visual/noise disturbance from construction equipment. Impacts to these

schools and other special use areas located near the Project would be minimized through

implementation of a traffic plan, construction schedules, and noise mitigation as necessary.. In

areas where traffic volumes are high or other circumstances (e.g., congested areas and school

crossings) exist, Mountain Valley Pipeline will employ a police detail to ensure traffic flow and

the safety of pedestrians and vehicles. Mountain Valley Pipeline will incorporate measures to

maintain safety and minimize traffic disruption, and ensure that construction activities will not

prevent the passage of emergency vehicles. Work space limits would not extend to the property

where the Mayapple Preschool is located. Further, additional temporary work space (ATWS) is

not located near the Mayapple Preschool and has been limited to a small portion of the Sunshine

Valley School’s property, located more than 500 feet southeast of the school building. Mountain

Valley Pipeline will coordinate with officials at both of these schools to ensure that construction

schedules do not interfere with anticipated school activities. Mountain Valley Pipeline will

implement over-sized vehicle truck traffic curfews to prevent traffic problems during the hours

when busses will be transporting students to these schools.

Mountain Valley has also committed to increasing the pipe from Class II to Class III. This

change has been reflected in the updated Class Location table, HCA Location table attached as

Attachment RR8-13, and on the alignment sheets. Mountain Valley expects to file updated

alignment sheets by January 22, 2016.

Mountain Valley Pipeline evaluated 4 alternative routes that would move the pipeline farther

from the Mayapple Preschool/Newport Recreation Center. These alternatives are listed below,

including the distance between the pipeline and school and the Section of Resource Report 10

where they are described:






265

• Route Alternative 1, 12.8 miles, Section 10.5.2;

• Northern Alternative, 90 miles, Section 10.5.3;

• Variation 110 (including 110R and 110J), 10.7 miles, Section 10.6.4; and

• AEP-Newport Variation, 0.5 miles, Section 10.6.7.

Mountain Valley Pipeline evaluated 3 alternative routes that would move the pipeline farther

from the Sunshine Valley School. These alternatives are listed below, including the distance

between the pipeline and school and the Section of Resource Report 10 where they are

described:

• Route Alternative 1, 74 miles, Section 10.5.2;

• Northern Alternative, 15.5 miles, Section 10.5.3; and

• ETNG Alternative, 33.3 miles, Section 10.5.5.










266


Request:


14. Document communications between Mountain Valley and the planning department for all

of the counties that would be crossed by the pipeline regarding future residential and

commercial developments in those counties.

Response:

The Mountain Valley Pipeline team has been working with county elected officials, county

administrators, planning departments, and economic development agencies in the various

counties since the project was announced in 2014. A list of contacts with planning departments is

included in Attachment RR8-14 that documents the communication with these officials, where

the relationship of Mountain Valley Pipeline to future development was open for discussion.

Please note that there was also dialogue between FTI Consulting and local officials when

Mountain Valley Pipeline’s economic impact study was originally conducted, which also

provided the opportunity to discuss this topic.










267


Request:


15. Identify, in communication with the FS, any Forest-specific amendments to the Land and

Resource Management Plan for the Jefferson National Forest that may be necessary to

allow for the crossing of the pipeline.

Response:

Mountain Valley included the consistency analysis in Appendix 8-E of its certificate application.

Mountain Valley will continue to work with the Forest Service on its Management Plan

amendments following submittal of the SF-299, which it expects to submit by January 22, 2016.










268


Request:


16. Document that Mountain Valley submitted its plan for crossing the Appalachian Trail to

the FS, the NPS, and the Appalachian Trail Conservancy, and file their comments on the

plan.

Response:

The application (SF-299) for authorization to construct and operate the Project across the

Appalachian Trail is in preparation. Mountain Valley expects to submit the SF-299 to the United

States Forest Service Jefferson National Forest office by January 22, 2016.










269


Request:


17. Document that Mountain Valley’s plan for crossing the Blue Ridge Parkway was

submitted to the NPS, and file the NPS’ comments on that plan.

Response:

A meeting with the U.S. Forest Service, National Park Service and Appalachian Trail

Conservancy was held at the U.S. Forest Service George Washington and Jefferson National

Forest office on September 14, 2015. At this meeting plans for crossing the Blue Ridge Parkway

were presented.

Mountain Valley has requested approval to survey USDOI NPS land adjacent to the Blue Ridge

Parkway. Once permission is granted and surveys are complete, Mountain Valley Pipeline will

submit a SF-299 for authorization to construct and operate the pipeline across USDOI NPS

owned land. Until survey permission is granted, Mountain Valley cannot speculate on a date for

submittal to FERC.










270


Request:


18. Document that Mountain Valley provided the WVDNR with plans for the crossing of the

Burnsville Lake Wildlife Management Area (WMA), the Elk River WMA, and the

Meadow River WMA, and file the WVDNR’s comments on those plans.

Response:

On December 12, 2015 Mountain Valley Pipeline met with Cliff Brown, a representative of the

West Virginia Division of Natural Resources to discuss areas such as the Burnsville Lake

Wildlife Management Area (WMA), the Elk River WMA, and the Meadow River WMA. During

that meeting, Mr. Brown was given a sheet from the proposed alignment sheets showing the

pipeline route in the vicinity of Burnsville WMA. During the meeting, there was discussion

about moving the pipeline slightly to the west to only cross Knawl Creek rather than crossing

both Knawl Creek and Left Fork Knawl Creek in such close proximity. The area of this crossing

is unavoidable due to steep topography to the west of the proposed crossing and numerous

homes to the east. The proposed crossing provides an open field at the bottom which allows the

pipeline to cross the stream at a near perpendicular angle with adequate workspace to construct

the area responsibly and safely. As erosion and sedimentation plans are developed for this area,

consultation will continue with the West Virginia Division of Natural Resources.

During the meeting, Mountain Valley Pipeline’s route in the area of the Elk River and Meadow

River WMAs were also discussed. Mountain Valley Pipeline is routed approximately 0.25 mile

from the Elk River WMA and does not cross WMA property. Similarly, a temporary pipeyard is

on private property within the vicinity of the Meadow River WMA, no disturbance is proposed

to the WMA property.










271


Request:


19. Document that Mountain Valley provided the West Virginia Department of State Parks

with its plan for crossing the North Bend Rail Trail, and file the park department’s

comments on the plan.

Response:

The North Bend Rail Trail, part of the American Discovery Trail, is a 72-mile, multi-use

recreational trail operated by the West Virginia State Park system. The pipeline will cross the

trail at milepost 26.0 where the trail crosses under US Route 50. In addition to the pipeline there

will be a laydown yard and a temporary work area directly adjacent to the trail to facilitate

crossing of U.S. Route 50. Due to the site being currently used as a laydown yard by another

project, it is likely that changes resulting from the Mountain Valley Pipeline would be minimal.

Mountain Valley Pipeline will work with the West Virginia State Park system during final

pipeline design to identify site-specific measures if needed to minimize disturbance to users of

the North Bend Rail Trail in this vicinity.

West Virginia Division of Natural Resources (WVDNR) is the permitting/licensing agency for

the North Bend Rail Trail. We have worked with them in the past to cross this trail in Doddridge

County, West Virginia. The WVDNR will Grant a License Agreement much like a Right of Way

with an Exhibit attached. This crossing is affected by the US Route 50 crossing as well.

Mountain Valley Pipeline will file our plan with the WVDNR after we have further discussions

with West Virginia Department of Highways regarding the US Route 50 crossing.










272


Request:


20. Document that Mountain Valley provided the Nature Conservancy and the Virginia

Department of Conservation and Recreation with a plan for crossing the Mill Creek

Springs Natural Area Preserve, and file their comments on the plan.

Response:

Mountain Valley has provided The Nature Conservancy with a plan for crossing the Blake

Preserve. To date, Mountain Valley has not been in contact directly with the Virginia

Department of Conservation and Recreation on this issue. Currently, The Nature Conservancy is

evaluating allowing Mountain Valley to conduct surveys on the property. Once surveys are

complete, Mountain Valley will work out specific land disturbance and revegetation with The

Nature Conservancy. When specifics of the crossing are coordinated locally, Mountain Valley

will seek approval for the crossing of the Blake Preserve from the Virginia Department of

Natural Heritage and the Virginia Attorney General.










273


Request:


21. Document that Mountain Valley provided the Virginia Outdoors Foundation with plans

for crossing open space parcels (at sites 3333 and 1871), and file the Foundation’s

comments on the plans.

Response:

Mountain Valley Pipeline has been in contact with the Virginia Outdoors Foundation (VOF)

since June 2014. Mountain Valley Pipeline notified the VOF of its FERC application filing on

October 23, 2015, and that the application included Mountain Valley Pipeline’s proposed route

and access roads, which would cross three VOF easements. Mountain Valley Pipeline presented

to the VOF Energy and Infrastructure Committee on November 5, 2015 to introduce the Project

to the VOF Board of Trustees and exhibit the three proposed easement crossings. Mountain

Valley Pipeline received formal comments from VOF on November 30, 2015 regarding each of

these easements and their respective application requirements. Mountain Valley Pipeline and

VOF are continuing to communicate on these proposed easement crossings, and Mountain

Valley Pipeline is preparing and expects to submit the relevant VOF applications by January 22,

2016.










274


Request:


22. Document that Mountain Valley provided the New River Conservancy with a plan for

crossing its easement near MP 203.4, and file the Conservancy’s comments on the plan.

Response:

Mountain Valley Pipeline sent an introduction letter to the New River Conservancy (previously

named the National Committee for the New River) on October 24, 2014 (Attachment RR8-

22a). Mountain Valley Pipeline has been communicating with the landowners (Sizemore, Inc.)

associated with the easement at milepost 203.4 since September 2014. Ziegler & Ziegler, L.C.

sent a letter on June 16, 2015 on behalf of the New River Conservancy stating the proposed

Project activities are prohibited in the conservation easement on the property (Attachment RR8-

22b). Mountain Valley Pipeline intends to continue to coordinate with the New River

Conservancy, their legal counsel, and the landowner to discuss the Project, their concerns, and

potential restoration and/or mitigation.










275


Request:


Appendix 8-B – Site Specific Residential Construction and Mitigation Plans

23. In all cases, where the pipeline would be within 50 feet of a house, explain why an

alternative route elsewhere on the property further away from the residence or reduction

in workspace width (i.e., a neckdown) is not feasible. In those situations where a reroute

away from a house is possible, provide a site-specific alternatives analysis.

Response:











276


Request:



24. Several of the site-specific residential construction and mitigation plans in appendix 8-B

appear to show barricade fences that may block roads or driveways. Confirm that access

will be maintained and if access will not be maintained, provide a plan for alternate

access.

Response:

Access will not be restricted to any residence. Mountain Valley Pipeline will work with all

affected landowners to ensure adequate access is maintained to their property while resources are

being protected, or as specified in landowner agreements between the landowner and Mountain

Valley Pipeline.










277


Request:



25. Document that the site-specific Residential Construction Plans in appendix 8-B were

submitted to the individual landowners, and file the landowners’ comments on the plans.

In providing copies of letters sent to landowners to the FERC, Mountain Valley should

redact individual addresses, but include the tract number.

Response:











278


Request:



26. In the case of the Residential Construction Plan for Property Owner WV-HA-101 at

MP 29.95 the construction right-of-way would go through several out-buildings, such as

sheds and barns. In a narrative discussion to accompany this plan, explain how Mountain

Valley would mitigate for the removal of those buildings.

Response:

On property WV-HA-101 the structures exhibited are portable water tanks. The landowner is

willing to have them relocated during construction.










279


Request:



27. In the case of Mountain Valley Pipeline-GB-193, workspaces such as Mountain Valley

Pipeline-ATWS-1203 appear to touch or even envelope houses. In a narrative discussion

to accompany this plan, explain how Mountain Valley would mitigate for impacts on

these houses.

Resolve any instances where affected landowners are listed as “Property Owner –

Unknown.”

Response:











280


Request:


Appendix 8-C – Structures within 50 Feet of the Proposed Pipeline

28. Update table 8-C to include all residential construction plan drawing numbers.

Response:











281


Request:


Appendix 8-C – Structures within 50 Feet of the Proposed Pipeline

29. Fill in “TBD” in table 8-C to list future mitigation measures.

Response:











282


Request:


Appendix 8-F – Visual Simulations

30. Provide a visual simulation of the communication towers from nearby roads, points of

interest, and residences.

Response:











283


Request:



31. Provide visual simulations for all key observation points that have a high potential for

visual impacts as discussed in section 8.4.3, such as the pipeline crossings at:

a. North Bend Rail Trail;

b. Tully Ridge adjacent to I-79;

c. Weston Gauley Turnpike;

d. Red Spring Mountain adjacent to I-64;

e. Greenbrier River;

f. Farm Heritage Road;

g. Mountain Shadow Trail;

h. Roanoke River;

i. Blackwater River B; and

j. Pigg River.

Response:











284


Request:



32. Provide the length of the road bore associated with Craig Creek Road. Unless the road

bore has extended length, it would appear based on the visual simulation that the use of

bore pits at this road crossing would necessitate tree clearing potentially visible from

Craig Creek Road (which is not depicted in the simulation), especially to the north.

Response:

Estimated bore length is 60 feet.










285


Request:

Resource Report 9 – Air Quality and Noise

Air Quality

1. According to section 1.4.1.1, burning would be used to dispose of brush and slash from

clearing; however, section 9.1.6 stated that: “Mountain Valley Pipeline will mulch the

piles generated during construction to ensure particulate matter emissions are

minimized.” Resolve the apparent discrepancy. In addition, revise tables 9.1-10 through

9.1-13, and appendix 9-A, to include estimates and methodology used to calculate

emissions from open burning for each area of occurrence and discuss the effects upon

associated permitting.

Response:











286


Request:


Air Quality

2. Confirm that the WB/TCO Interconnect (identified in appendix 9-A) and the Columbia

Interconnect (as discussed in RR 9) are referring to the same interconnect.

Response:

The WB/TCO Interconnect and the Columbia Interconnect are the same interconnect.










287


Request:


Air Quality

3. Provide the following for the operation of the project:

a. a table showing potential-to-emit emissions in tons per year for all criteria pollutants

(NOx, VOC, CO, SO2, PM10, PM2.5), and hazardous air pollutants (HAPs) from

emission generating equipment for each of the compressor stations; and

b. a table showing potential-to-emit greenhouse gas emissions in tons per year for each

of the compressor stations.

Response:

Table 9.1-9 has been revised to include a summary of potential-to-emit HAP emissions and

greenhouse gas emissions for each of the compressor stations. Detailed emissions can be found

in Appendix 9-B.

Table 9.1-9 (revised)

Emissions from Compressor Stations versus NSR Major Source Thresholds

Pollutant

Bradshaw Compressor

Station Site-Wide PTE

(TPY)1

Harris Compressor Station Site-Wide

PTE (TPY)

1

Stallworth Compressor

Station Site-Wide PTE

(TPY)1

Major Source

Threshold (TPY)

2

NSR Program

Subject to Major NSR?

PM10 47.47 21.39 20.30 250 PSD No

PM2.5 47.36 21.36 20.20 250 PSD No

SO2 10.98 4.95 4.74 250 PSD No

CO 197.78 97.06 91.28 250 PSD No

NOX 178.62 86.73 79.84 250 PSD No

VOC 31.94 13.99 13.46 250 PSD No

Total HAP 10.79 4.79 4.53 NA NA NA

GHG (as CO2e)

391,794 180,861 169,866 NA PSD No

1 PTE includes emissions from fugitive sources. 2The PSD major source threshold is 250 tpy since the sources do not belong to one of the 28 specifically defined industrial source categories in 40 CFR 52.21(b)(1)(i)(a).






288










289


Request:


Air Quality

4. As identified in tables 9.1-6, 9.1.7, and 9.1-8 of RR 9, discuss potential air quality

impacts on all Class I areas within 100 kilometers of the pipeline, and provide copies of

correspondence with the federal land managers of the Class I areas as appropriate.

Response:











290


Request:


Air Quality

5. Section 9.1.4.6 stated that: “Mountain Valley Pipeline will operate all equipment in a

manner as to avoid causing or contributing to an objectionable odor at any location

occupied by the public.” Outline specific measures Mountain Valley would implement to

avoid producing odors that the public may find objectionable.

Response:

Odors are not expected to be an issue with the Mountain Valley Pipeline facilities. During

normal operations, emissions from the facilities are expected to be in relation to combustion

processes associated with the turbine driven compressors, fuel gas heaters, and microturbine

generators. Emissions from these pieces of equipment do not produce objectionable odors.

The gas to be transported on Mountain Valley Pipeline will be dry, un-odorized, transmission

quality gas with very limited amounts of liquid present. All of the measurement and compressor

stations will be equipped with filter separator equipment to remove liquid contaminants

(water/liquid hydrocarbons) from the pipeline. If required, removed liquids will be stored in

enclosed bulk storage tanks. The storage tanks at the facilities will be equipped with

pressure/vacuum vents to protect the tanks from overpressure while limiting venting. Any

venting that would take place would be minor and brief in duration making it extremely unlikely

that any odors could be detected outside the facility fence lines. The gas to be transported on the

Mountain Valley Pipeline will not be odorized and will be lighter than air. Natural gas emissions

from any infrequent depressurizing activities will dissipate and disperse therefore making

detection of any odors unlikely. This also applies to main line valve settings and measurement

sites that will occasionally vent a small amount of natural gas from the valve operators as they

open and close. The compressor station valves will utilize instrument air that has no odor

associated with it.










291


Request:


Noise

6. Expand table 9.2-8 to list worst-case noise impacts at nearby residences, similar to

tables 9.2-11, 9.2-12, and 9.2-13.

Response:

As requested, Table 9.2-8 has been expanded to include the measured sound levels at all Noise

Sensitive Areas for each of the compressor stations. In addition, the predicted short-term

construction sound levels have been compared with the measured daytime sound levels to show

the short-term impact of the construction noise at these nearby NSAs. Construction is expected

to occur almost exclusively during daylight hours, between 7:00 am and 7:00 pm, so the

predicted construction sound levels have been compared with the measured existing daytime

average sound levels at each NSA location. The predicted temporary increase in sound levels at

each NSA is shown in the last column of the table.

Table 9.2-8 – Revised

Predicted Sound Level Impact Due to Construction

Compressor Station

NSA Distance

feet Direction

Measured Existing Daytime Ambient

Predicted Temporary

Sound Levels due to

Construction Equipment

Predicted Daytime

Sound Levels during

Construction

Predicted Temporary Increase in

Daytime Sound Levels during Construction

Ld dBA Ld dBA Ld dBA Ld dBA

Bradshaw

1 1,335 NW 43.6 42.3 46.0 2.4

2 2,135 WNW 43.6 29.2 43.8 0.2

3 3,105 WSW 43.6 24.4 43.7 0.1

4 3,030 SE 44.0 43.8 46.9 2.9

5 2,380 NE 46.4 50.1 51.6 5.2

Harris

1 1,445 N 47.9 42.5 49.0 1.1

2 1,825 SW 48.7 47.3 51.1 2.4

3 1,965 SSE 48.7 53.7 54.9 6.2

4 3,340 WSW 53.1 44.4 53.6 0.5

Stallworth

1 2835 WNW 54.2 40.8 54.4 0.2

2 1985 West 37.8 40.2 42.2 4.4

3 2085 SW 42.2 43.1 45.7 3.5

4 1465 SSW 34.7 32.8 36.9 2.2

5 1340 SE 51.9 42.0 52.3 0.4






292

6 2755 ESE 51.9 42.8 52.4 0.5










293


Request:


Noise

7. Estimate potential sound levels from construction and operation of aboveground

facilities. Provide projected noise impacts at noise sensitive areas (NSA) in proximity to

the aboveground facilities, in tables similar to edited table 9.2-8.

Response:

Compressor Sites:

Operational and construction noise for the compressor stations is provided in Resource Report 9

with additional data provided in the responses to Resource Report 9, Requests 6 and 8.

Valve Sites:

Construction of the valve sites will generate short term noise from heavy machinery and

equipment as construction moves in phases along the right-of-way, similar to the pipeline itself.

The noise from constructing the valve site will be indistinguishable from the construction noise

associated with the pipeline. Sound from valve site construction will generally be temporary,

sporadic, and short-term at each location along the pipeline route. Because of the temporary and

generally daytime-only nature of valve site construction activities, no special noise mitigation or

noise monitoring program will be implemented during the construction phase.

An operational noise evaluation is not necessary for the valve sites because normal operational

noise from the valves will be negligible as the pipeline and main line valve itself will be buried.

Measurement/Interconnect Sites:

Mountain Valley is working to determine the operational and construction noise impact

associated with each of the interconnect facilities through a noise study. The study will include

the following facilities:

Mobley Interconnect Receipt

Sherwood Interconnect Receipt

WB Interconnect Delivery

Transco Interconnect Delivery






294

Mountain Valley expects to file this information by February 26, 2016.










295


Request:


Noise

8. Provide an analysis of low frequency noise for each compressor station to determine if

any perceptible vibration would affect nearby NSAs.

Response:

The existing noise models for each compressor station have been used to predict the low-

frequency sound level contributions from the proposed compressor station (CS) equipment.

Table RR9-8, below, shows the predicted sound levels in the 31.5 and 63 Hz octave bands for

each Noise Sensitive Area (NSA) along with the measured average sound levels in those octave

bands. Also shown is the predicted sound level impact of the compressor station low-frequency

sounds.

Table RR9-8

Compressor Station Low-Frequency Sound Level Evaluation All levels shown are unweighted 24-hour averages, in decibels re 20 microPa

Compressor Station

NSA

Measured Existing Ambient Level

Predicted Sound Levels due to

Compressor Station Equipment

Predicted Sound Levels with

Compressor Station in Operation

Predicted Increase in Low-frequency

Sound Levels due to Station Contribution

31.5 Hz 63 Hz 31.5 Hz 63 Hz 31.5 Hz 63 Hz 31.5 Hz 63 Hz

Bradshaw

1 45.0 46.6 58.4 54.3 58.6 55.0 13.6 8.4

2 45.0 46.6 49.6 44.4 50.9 48.7 5.9 2.1

3 45.0 46.6 44.8 39.8 47.9 47.5 2.9 0.9

4 47.9 44.5 62.5 61.5 62.6 61.6 14.7 17.1

5 46.8 42.4 61.1 59.8 61.3 59.9 14.5 17.5

Harris

1 50.1 49.1 52.2 53.1 54.3 54.6 4.2 5.5

2 44.6 44.6 57.9 59.6 58.1 59.7 13.5 15.1

3 44.6 44.6 59.6 61.8 59.7 61.9 15.1 17.3

4 54.7 55.3 56.4 58.5 58.6 60.2 3.9 4.9

Stallworth

1 57.6 59.6 48.3 50.2 58.1 60.1 0.5 0.5

2 44.5 44.6 54.0 55.3 54.5 55.7 10.0 11.1

3 52.4 50.4 53.9 55.3 56.2 56.5 3.8 6.1

4 43.1 39.4 49.5 49.3 50.4 49.7 7.3 10.3

5 57.5 56.5 52.5 53.1 58.7 58.1 1.2 1.6

6 57.5 56.5 47.1 48.3 57.8 57.1 0.3 0.6






296

It is important to note that the sound levels shown in Table RR9-8 are unweighted, and do not

include any A-weighting factors. The human ear is much less sensitive to low frequency sounds,

and therefore the A-weighted scale is very commonly used to approximate the response of the

human ear. A-weighting applies standardized weighting factors by frequency to adjust the sound

level to more closely match the human response. The A-weighting factor at 31.5 Hz is -39.4 dB.

This means that sound levels in the 31.5 Hz band are reduced by 39.4 dB before being included

in the overall A-weighted level. The highest predicted 31.5 Hz sound level for all three stations

is 62.5 dB at the Bradshaw CS NSA 4. This level corresponds to an A-weighted sound level of

23.1 dBA, a very quiet sound level.

There is no manufacturer data available for frequencies below the 31.5 Hz full-octave band for

any of the proposed equipment for the Project. However, SLR, Mountain Valley’s consultant

who conducted the noise surveys for the Project, has performed sound level measurements of

many installed Solar turbine units similar in make and model to the proposed turbine units.

Figure RR9-8, below, shows the measured one-third octave sound level spectrum of a

compressor station powered by one Solar Mars 100 along with a Rolls Royce turbine. The figure

is the result of a single measurement, with both the unweighted and A-weighted spectra

displayed.

As shown in Figure RR9-8, sound levels from turbine-driven equipment typically drop off at

frequencies below the 25 Hz one-third octave band. The one-third octave bands from 12.5 to

20 Hz were about 3 decibels lower than the measured levels at 25 Hz. Levels would be expected

to decrease substantially for the frequencies below the 12.5 Hz octave band.






297

Figure RR9-8: Measured sound levels at 530 feet from 1 Solar Mars 100 and 1 Rolls-Royce with

both the unweighted and A-weighted spectra displayed.

Harvey Hubbard and Kevin Shepherd of NASA have presented criteria curves12

that give

thresholds for the amount of low-frequency energy generally necessary to induce vibration in

building elements such as windows, walls, and floors of typical residential structures. Graph

RR9-8 shows the predicted low-frequency sound levels at the worst-case NSA, NSA 4 at the

Bradshaw CS, compared with the criteria curves for noise-induced vibration of windows, walls,

and floors. As shown in this Graph, the predicted low-frequency sound levels do not exceed the

criteria curves, and would not be expected to cause noise-induced vibration of standard

residential windows, walls, or floors.

In addition, gas turbines do not typically generate strong low-frequency tonal components such

as those associated with reciprocating gas engines. While there is significant low-frequency

sound energy radiated from the gas turbine exhaust outlet, this sound energy is broadly

distributed across the low-frequencies. Gas turbines do not have strong low-frequency tonal

sound levels in the low-frequencies below the range of human hearing, from 4 up to 20 Hz.

1 Hubbard, Harvey H. and Shepherd, Kevin P. "Aeroacoustics of Large Wind Turbines"; Journal of the

Acoustical Society of America, Volume 89, 2495; (June 6, 1991). 2 Hubbard, Harvey H. and Shepherd, Kevin P. "Guide to the Evaluation of Human Exposure to Noise

from Large Wind Turbines," NASA Technical Memorandum 83288, (May, 1982).

10 12.5 16 20 25 31.5 40 50 63 80 100

One-Third Octave Band Center Frequency, Hz

-15

-5

5

15

25

35

45

55

65

75

dB

Sound P

ressure

Level, d

ecib

els

re 2

0 m

icro

Pa 59 58 58

61 62 62 62

57 57

53 53

-5

2

8

16

23

27

31 3134 33

37

Unweighted Sound Pressure Level

A-weighted Sound Pressure Level






298

Without noise-induced vibration or significant tonal components, it is extremely unlikely that

there will be perceptible vibration from the low-frequency sounds contributed by the compressor

stations at any of the NSAs.

Graph RR9-8: Predicted low-frequency sound levels at Bradshaw CS NSA 4, compared with

noise-induced vibration criteria curves.





50.0

60.0

70.0

80.0

90.0

100.0

12.5 16 20 25 31.5 40 50 63 80

Un

we

igh

ted

So

un

d P

ress

ure

Le

ve

l, d

eci

be

ls

re 2

0 m

icro

Pa

One-Third Octave Band Center Frequency, Hz

Predicted Bradshaw CS sound level contribution at NSA 4






299


Request:


Noise

9. Discuss potential noise levels that would be generated during construction of the pipeline.

Provide existing ambient noise levels along portions of the pipeline route that cross near

residential neighborhoods. List all NSAs within 0.25 mile of the pipeline, and estimate

construction noise and duration at those locations. Explain how construction noise would

attenuate with distance and time. Identify any NSAs where construction noise may

exceed 55 decibels. Summarize results in tables similar to edited table 9.2-8.

Response:

Resource Report 8 (Appendix 8 C) contains a 22-page list of all structures within 50 feet of the

proposed pipeline route. Listing all NSAs within 0.25 mile of the pipeline could result in list of

hundreds of pages in length.

Potential impacts from pipeline construction could include short-term increases in sound during

construction. Construction of the pipeline will generate noise from heavy machinery and

equipment as construction moves in phases along the right-of-way (see Resource Report 1 for

description of pipeline construction). In the typical pipeline construction scenario, the

construction contractor will construct the pipeline along the construction right-of-way using

sequential pipeline construction techniques, including survey, staking and fence crossing;

clearing and grading; trenching; pipe stringing, bending and welding; lowering-in and

backfilling; hydrostatic testing; clean-up and restoration; and commissioning.

Sound from pipeline construction will generally be temporary, sporadic, and short-term in any

one location along the pipeline route. It is anticipated that construction noise could exceed

existing ambient conditions for short-term periods. Existing ambient sound levels will vary

across the 300 mile pipeline. Estimates of outdoor acoustic environments are provided in

Figure 9-2.1. The equipment likely to be used during pipeline construction and the associated

noise levels are presented in Table RR9-9 below. Construction equipment noise levels will

typically be less than the identified 85 Lmax dBA at 50 feet when equipment is operating at full

load. For NSAs further away, construction noise levels would be lower, generally decreasing by

3–6 dBA with a doubling of distance (e.g., 50 feet to 100 feet to 200 feet). Modeled sound levels

were calculated using maximum noise levels generated from the pipeline construction. Received

sound levels at 0.25 miles range from 52 Lmax dBA to 57 Lmax dBA. Sound calculations at 0.25

miles did not take into account how the equipment operational noise levels would change over






300

time. Noise levels generated by the construction operations over a full day would be less than the

maximum noise levels because the equipment would not be utilized under the full load the entire

day. A utilization factor of 40% was used for all the equipment to calculate Ldn values for two

scenarios: daytime construction and full-day construction. Daytime only values show Ldn sound

levels below 55 dBA at 0.25 miles.

Table RR9-9

Noise Levels of Construction Equipment

Source Sound Level

at 50 Feet (Lmax dBA)

Predicted Sound Level at 0.25 Miles

(Lmax dBA)

Daytime Only Predicted Sound Level at 0.25

Miles (dBA Ldn)

Daytime And Nighttime Predicted Sound Level at 0.25

Miles (dBA Ldn)

Bulldozers 85 57 52 60

Fork Lift 85 57 52 60

Backhoes 85 57 52 60

Dump Trucks 85 57 52 60

Front End Loader 80 52 47 55

Welding Trucks 85 57 52 60

Road Maintainer/Grader

85 57 51.8 60

Source: Referenced noise levels obtained from the Federal Highway Administrations (“FHWA”) Roadway Construction Noise Model (FHWA 2006).










301


Request:


Noise

10. Discuss potential noise and vibration levels due to blasting, and impacts on NSAs in

proximity to areas where blasting may be conducted. Summarize results in tables similar

to edited table 9.2-8.

Response:

Noise associated with blasting for the pipeline trench and/or grade excavation will result in

temporary elevated instantaneous noise generation. The noise associated with blasting is

dependent on the amount of explosives used, distance of blast site to receptor, depth below grade

where explosives are placed, and the pertinent protective measures implemented. Therefore, it is

difficult to model a predicted noise level at noise sensitive areas. The blasting will typically

generate one instantaneous noise or multiple instantaneous noises associated with consecutive

blasts with each blast separated by several milliseconds delay(s).

Since the blasting noise is temporary, instantaneous and not recurring, adverse impact on noise

sensitive areas near the work area is anticipated to be minimal.










302


Request:


Noise

11. Estimate the length of time of construction for each project component (i.e., compressor

station, meter stations, and typical pipeline construction spread).

Response:

Though continued monitoring and restoration may require additional time, average construction

time for Mountain Valley Pipeline components are as follows:

Compressor Station: 8 Months

Interconnect Sites: 8 Months

Typical Pipeline Construction Spread: 10 Months










303


Request:


Noise

12. Discuss how Mountain Valley would identify any noise complaints from nearby residents

due to the construction and operation of the project facilities, and describe how the

complaints would be resolved.

Response:

Noise complaints during construction and post construction will be routed through the Mountain

Valley Pipeline landowner resolution process as outlined in the Public, Stakeholder, and Agency

Participation Plan in Resource Report 1. Construction activities will generally occur at the

compressor stations between the hours of 7:00 am and 7:00 pm in order to prevent nighttime

disturbance to any noise sensitive receptors in the area. While noise levels may increase in the

area during construction activities, they will be temporary. Also, refer to data request number 9

for Resource Report 9.

Mountain Valley Pipeline performed pre-construction a noise analyses at each of the proposed

facilities in order to gather ambient noise data for the identified NSA’s surrounding the proposed

compressor stations. The ambient noise data collected was utilized during the design of each

compressor station to develop noise attenuation plans as necessary to reduce noise levels at

existing noise sensitive areas around each compressor station. Noise suppression methods

included building design techniques, insulation, filters, and mufflers. Once each compressor

station is built and running at full capacity, post construction noise surveys will be conducted at

the identified NSA’s to ensure that sound level contributions remain within FERC’s sound level

guidelines. Should noise readings be above 55 dBA Ldn at any particular NSA or a complaint is

filed by a resident regarding the noise from a station, Mountain Valley Pipeline will conduct

additional noise surveys at that particular NSA to establish the potential cause. Once a cause can

be identified, appropriate noise attenuation methods and/or equipment will be utilized to reduce

the sound level.










304


Request:

Resource Report 10 – Alternatives

1. Section 10.1.2 indicated that: “The project will deliver natural gas from…and other future

receipt points in Wetzel County, West Virginia.” Identify the other future receipt points.

Response:

Mountain Valley has not identified any other future receipt points in the referenced area and has

not included any such points in its Project scope. The statement was made in section 10.1.2 for

potential future receipt points over the life of the pipeline.










305


Request:


2. As previously requested in our comments dated August 11, 2015, describe Mountain

Valley’s ability (or inability) to relocate natural gas receipt and delivery points to

accommodate route modifications to avoid or minimize impacts on environmental

resources.

Response:

Mountain Valley will receive natural gas from MarkWest’s Mobley Plant and Equitrans’

Mainline System and will deliver natural gas to Columbia’s WB System and Transco’s Station

165, all of which are existing pipeline and processing facilities. In addition, Mountain Valley

will deliver natural gas to a site-specific delivery point in Franklin County, Virginia for the

growth and expansion of Roanoke Gas’s local distribution system. Thus, Mountain Valley’s

receipt and delivery points are located to meet the transportation needs of its shippers and are

site-specific. Mountain Valley cannot address its ability or inability to relocate such points

absent any specifically-identified environmental resources to be avoided or mitigated. Relocation

evaluation of several feet versus dozens of miles yields differing answers to each point. See also

the response to Resource Report 10, FERC Data Request 19.










306


Request:


3. As previously requested in our comments dated either March 13, 2015 or August 11,

2015, supplement all alternative comparison data tables to also include the following

parameters: steep side slopes, not just steep vertical slopes (miles); areas with landslide

potential (feet or miles); interior forest (miles and acres affected during both construction

and operation); major river crossings (number); number (and length crossed) of NRHP

listed or eligible sites; and streams with drinking water designation (number).

Response:











307


Request:


4. Provide a table that compares the “straight line” alternative to Mountain Valley’s

proposed route. The table should include length (miles); miles of steep side slopes

crossed; acres of forest cleared; number of waterbodies crossed; number of wetlands

crossed; federally listed threatened and endangered species and miles of habitat crossed;

number of historic properties affected; miles of National Forest system lands crossed;

other recreation or special use areas crossed; and number of residences within 50 feet.

On a map, illustrate the straight line alternative in comparison to Mountain Valley’s

proposed route.

Response:











308


Request:


5. Identify the roads that could be followed by an “all highway” alternative. On a map,

illustrate the highway alternative in comparison to Mountain Valley’s proposed route.

Provide a table comparing impacts on the environmental resources listed above in

question 10-4. Discuss the laws and regulations that may impede installing a natural gas

pipeline adjacent to or within an access-controlled highway right-of-way easement.

Response:

A map that illustrates a conceptual “all highway alternative” is included in Attachment RR10-5.

Roads followed by this alternative include U.S. Highway 250, U.S. Highway 19, Interstate 79,

Interstate 77, U.S. Highway 58, and U.S. Highway 29. Short sections of new right-of-way would

also be required at both ends of the alternative to connect the Mountain Valley Pipeline start and

end points to the nearest highways. Mountain Valley expects to provide a table that compares the

“all highway alternative” to the Proposed Route by January 22, 2016.

Regulations generally restrict the placement of a natural gas pipeline longitudinally within an

access-controlled highway easement. There are generally no regulations that restrict placement

of a natural gas pipeline adjacent to but outside of access-controlled highway rights-of-way,

however paralleling a highway right-of-way has other constraints such as highway cuts and fills,

elevated roadway sections, bridges, overpasses and underpasses, clover leaf and other

interchanges, and adjacent commercial, industrial, and residential developments. Laws and

regulations are summarized below.

The Federal Highway Administration (FHWA) historically prohibited the installation of new

utility facilities within the rights-of-way of access-controlled freeways except in some

extraordinary cases. This prohibition was consistent with the American Association of State

Highway Transportation Officials (AASHTO) policies for longitudinal accommodation.

However, with a 1988 amendment to the FHWA regulations, the FHWA's policy changed to

allow each state to decide whether to permit new utility facilities within these rights-of-way, or

continue to adhere to the stricter AASHTO policies (FHWA 2013).

State policies for utility installation within access controlled highways in West Virginia are

described in the manual Accommodation of Utilities on Highway Right of Way and Adjustment

and Relocation of Utility Facilities on Highway Projects (WVDOT 2007). According to

WVDOT policy, with the exception of telecommunications facilities, utility installations are not

be allowed longitudinally inside controlled access right of way, including the median.






309

The Virginia DOT’s policy and procedure affecting the accommodation of utilities within

controlled access right of way are included in the Land Use Permit Regulations (24 VAC 30-

151), and are summarized in the manual Utility Manual of Instructions, Utility Relocation

Policies & Procedures (Virginia DOT 2011). The policies outlined in the VDOT utility manual

apply to all investor-owned and publicly-owned utilities, but can be used as a guide in dealing

with privately-owned utilities during right of way and construction activities. According to

VDOT policy, new utilities will not be permitted to be installed longitudinally within the

controlled access lines of any highway, except that in special cases such installations may be

permitted under strictly controlled conditions and then only with the approval of the Chief

Engineer. However, in each such case the utility owner must show the following:

1. That the accommodation will not adversely affect maintenance safety, design,

construction, operation or stability of the highway;

2. That the accommodation will not interfere with or impair the present use or future

expansion of the highway;

3. That any alternative would be contrary to the public interest; and

4. In no case will parallel installations be permitted which involves tree removal or

severe tree trimming.

FHWA. 2014. Guidance on Utilization of Highway Right-of-Way, Longitudinal Accommodation

of Utilities in the Interstate System Right-of-Way. Updated: 09/05/2014. Website:

http://www.fhwa.dot.gov/real_estate/right-of-way/policy_and_guidance/guidutil_a.cfm

West Virginia Department of Transportation. 2007. Accommodation of Utilities on Highway

Right of Way and Adjustment and Relocation of Utility Facilities on Highway Projects.

WVDOT, Railroads and Utilities Unit, Division of Highways, June.

Virginia Department of Transportation. 2011. Utility Manual of Instructions, Utility Relocation

Policies & Procedures. 10th

Edition. January. http://www.virginiadot.org/business/resources/

right_of_way/utility_manual02132012_techrev.pdf










310


Request:


6. As previously requested in our comments dated August 11, 2015, evaluate the feasibility

of a single pipeline (42-inches-in-diameter or larger) that could accommodate the firm

transport capacity required of both the Mountain Valley and Atlantic Coast Pipeline

(ACP) projects combined, using a single route from the ACP point of origin in West

Virginia, following the ACP proposed route, to near the existing Transco Station 165 in

Virginia. With data available in both the Mountain Valley and ACP dockets, compare

impacts on environmental resources (geology, soils, waterbodies, wetlands, vegetation,

wildlife, cultural resources, land use, and air quality) along both the ACP and Mountain

Valley pipeline routes.

Response:

Mountain Valley considered the feasibility to transport the combined capacity of the proposed

Mountain Valley Pipeline and Atlantic Coast Pipeline (ACP) projects in a single route from the

ACP point of origin in West Virginia to the Transco Pipeline in Virginia. Mountain Valley

assumed a total of 3.44 Bcfd of firm transportation deliveries for both projects. The current

Mountain Valley design utilizes 171,600 horsepower (hp) of compression at three station

locations. The current ACP design utilizes 117,545 hp of compression at three station locations

according to ACP’s Resource Reports. As a result, the current planned design of Mountain

Valley and ACP, as designed totals 289,145 hp of compression at six station locations. See the

map document attached hereto as Attachment RR10-6a for an overview comparison of the

Mountain Valley and ACP Mainline routes.

Mountain Valley evaluated a scenario of installing 37.4 miles of 42-inch pipeline from Mountain

Valley’s Interconnect with Equitrans at Mobley to the ACP point of origin in West Virginia and

utilize 175.2 miles of the ACP route as a single 42-inch pipeline to the Transco Pipeline in

Virginia at ACP’s Compressor Station 2. See the map document attached hereto as Attachment

RR10-6b for an overview of the single pipeline route analysis of the Mountain Valley and ACP

Mainline routes. To meet the combined requirements of the two projects while utilizing a

MAOP of 1,480 psig, Mountain Valley and ACP would need to install an additional 583,870 hp

of compression. The total combined horsepower necessary to move 3.44 Bcfd would be 873,015

hp of compression and would require a total of eight sites to accomplish the needs of the two

projects.

As a result, this scenario would add two additional greenfield compressor station locations as

compared with the two separate projects and increase the total compression by 583,870 hp.






311

Additionally, it would require Mountain Valley to install approximately 64.7 miles of additional

42-inch pipeline adjacent to the Transco corridor from the ACP Interconnect point with Transco

down to Transco Station 165 in order to access the market point requested by Mountain Valley’s

shippers. Additionally, the ACP route does not take into account the delivery point to Roanoke

Gas Company in Franklin County, Virginia. In order to service the Roanoke Gas Company,

Mountain Valley estimates that it would require 38.3 miles of 8-inch pipeline to be installed in

the proposed Mountain Valley corridor in Pittsylvania and Franklin Counties, Virginia from

Transco Station 165 to the proposed tap location. The service to Roanoke Gas Company and

other potential local demand in Virginia and West Virginia could be lost as a result of utilizing

the ACP route. Modifying the locations of the Mountain Valley receipt and delivery points

would impact existing agreements with customers, and would limit the customers’ abilities to

move the natural gas to local and regional markets.

Given the Federal Energy Regulatory Commission’s, United Stated Forest Service, and the West

Virginia Department of Environmental Protection agencies recent ACP docket filings concerning

the route, the soils, geology, waterbodies, wetlands, vegetation, wildlife, cultural resource

comparison evaluation as requested would obviously be more detrimental due to added acreage

of disturbance with two more greenfield compressors and 38.3 miles of 8-inch pipeline to feed

the Roanoke demand. The air quality impacts would also essentially triple given the added

horsepower requirement calculations of one pipeline system versus the currently proposed two

individual projects.










312


Request:


7. Provide an analysis of the “one route-two pipeline” alternative. Discuss if both the

Mountain Valley pipeline and the ACP pipeline could be installed adjacent to each other

along a single route within a wider right-of-way, following Mountain Valley’s proposed

route.

Response:

Mountain Valley considered the feasibility to install the Mountain Valley Pipeline and Atlantic

Coast Pipeline (ACP) projects adjacent to each other along a single route within a wider right-of-

way, following Mountain Valley’s proposed route. Mountain Valley assumed a total of 3.44

Bcfd of firm transportation deliveries for both projects. The current Mountain Valley design

utilizes 171,600 horsepower (hp) of compression at three station locations in order to transport

supplies to the Transco Pipeline. The current ACP design utilizes 95,730 hp of compression at

Stations 1 and 2 between ACP Point of Origin and the Transco Pipeline according to ACP’s

Resource Reports. As a result, the current planned design of Mountain Valley and ACP totals

267,330 hp of compression at five station locations between their respective points of origin and

the Transco Pipeline.

The scenario that Mountain Valley considered was to install a 42-inch ACP Pipeline adjacent to

Mountain Valley’s 42-inch Pipeline from the ACP point of origin in West Virginia to the

Transco Pipeline at Station 165. To meet the combined requirements of the two projects while

utilizing a MAOP of 1,480 psig, Mountain Valley and ACP would not have to install any

additional compression in order to deliver at Transco Station 165. Therefore, the resultant

horsepower remains at a combined 267,330 hp at five station locations for the two projects from

their respective points of origin and the Transco Pipeline. However, there may be modifications

to ACP’s design that may require additional pipeline or compression in order to achieve the ACP

design per their customer commitments. Collocating Mountain Valley and ACP in the Mountain

Valley corridor would avoid impacts to the Monongahela National Forest (MNF) and George

Washington National Forest (GWNF). The Mountain Valley route does cross a portion of the

Jefferson National Forest (JNF), but the overall impacts to National Forest lands would be

substantially less with the Mountain Valley route.

The greatest disadvantage to the “one route-two pipeline” alternative is the rugged terrain along

several segments of the Mountain Valley route. See the map document attached hereto as

Attachment RR10-7 for examples of the terrain. The narrow ridgelines and steep slopes in much

of West Virginia and portions of Virginia would not allow for the safe installation of two large






313

diameter pipelines. Mountain Valley requires 125 feet of workspace along much of the route to

achieve a safe installation of one 42-inch pipeline. ACP also requires 125 feet of workspace

along much of the route to achieve a safe installation of one 42-inch pipeline as per ACP’s

alignment sheets. In addition, ACP has requested an additional 25 feet of temporary workspace

along multiple portions of the route for topsoil segregation. Therefore, the total workspace

requirements of the combined projects would be a minimum of 250 feet in order to

simultaneously install two collocated pipelines with safe construction practices. The potential for

excessive mountain top removal in order to install two large diameter pipelines would exist,

which would reduce the probability of restoration to original grade and increase destabilization

risks of soils due to a greater area of disturbance for the pipelines. Examples of problematic

terrain along the Mountain Valley route include:

• the crossings of U.S. Route 119 and the ridgetops near Camden in Lewis County, WV

between MP 47.0 and 53.0 (See Attachment RR10-7 Map A);

• the crossings of multiple mountaintops and associated ridgelines in Lewis County, WV

between MP 53.0 and 65.0;

• the crossings of the Little Kanawha River, multiple mountaintops and associated

ridgelines in Braxton County, WV between MP 66.0 and 77.0;

• the crossings of the Elk River, Big Mountain and additional mountainous terrain near Big

Run in Webster County, WV between MP 85.0 and 92.0 (See Attachment RR10-7

Map B);

• the crossings of multiple ridgelines near Halo in Webster County, WV between MP 96.0

and 102.0 (See Attachment RR10-7 Map C);

• the crossings of the Gauley River, multiple mountaintops and associated ridgelines in

Nicholas and Greenbrier Counties, WV between MP 118.0 and 139.0;

• the crossings of Little Sewall, Goddard and surrounding Mountains in Greenbrier

County, WV between MP 144.0 and 153.0;

• the crossings of Red Spring and Keeney Mountains in Summers County, WV between

MP 157.0 and 169.0;

• the crossing of Peters Mountain in Monroe, WV and Giles County, VA between MP

194.0 and 198.0 (See Attachment RR10-7 Map D);

• the crossings of Sinking Creek and Brush Mountains in Craig and Montgomery Counties,

VA between MP 216.0 and 221.0;

• the crossings of Paris and Fort Lewis Mountains in Montgomery County, VA between

MP 226.0 and 232.0;

• and the crossing of Poor Mountains in Roanoke County, VA between MP 236.0 and

240.0.






314

Based upon the extensive environmental disturbances, slope stabilization risks, and worker and

community safety issues detailed above, the “one route-two pipeline” scenario is not

constructible in this terrain.










315


Request:


8. Revise the environmental resources tables for all alternative routes in comparison to the

proposed route to include data on the miles of side slopes crossed. Use that newly

supplied data to support the contention that some of the alternatives (such as

Alternative 1, Modified Alternative 1, and Hybrid Alternative 1) located along severe

side slopes would not be suitable because they “represented insurmountable construction

challenges.”

Response:











316


Request:


9. As previously requested in our comments dated August 11, 2015, further assess in detail

the viability and constructability of the Northern Pipeline Alternative, and provide data

and/or example figures to support the statement that “there is insufficient space along the

tops of the ridgelines for two adjacent, large diameter pipelines in these areas.”

Reconcile the apparent discrepancy regarding the number of perennial waterbodies

crossed between the text in section 10.5.3 and table 10.5-2.

Response:

As previously discussed in Resource Report 10 Section 10.5.2, Mountain Valley considered the

feasibility of constructing the Northern Pipeline Alternative, which was a collocation of a portion

of the Mountain Valley Pipeline and Atlantic Coast Pipeline (ACP) along a single route within a

wider right-of-way, essentially following ACP’s proposed route. Mountain Valley’s response to

Resource Report 10, Request 7 addressed the insufficient space along the ridgelines for two

adjacent, large diameter pipelines in these areas.

Regarding the perennial waterbodies, the number in table 10.5-2 is correct. The text in section

10.5.3 on perennial waterbodies was a typographical error.










317


Request:


10. As previously requested in our comments dated August 11, 2015, perform a more

detailed analysis of the viability and constructability of the Supply Header Collocation

Alternative, and support with adequate data and/or example figures the contention that

there is a “lack of suitable construction area” for two parallel pipelines along the

alternative route.

Response:

Mountain Valley considered the feasibility to install a portion of the Mountain Valley Pipeline

and Dominion Supply Header Project (SHP) adjacent to each other along a single route within a

wider right-of-way, following SHP’s proposed route. The scenario that Mountain Valley

considered was to install a 42-inch Mountain Valley Pipeline adjacent to the proposed SHP 30-

inch Pipeline from the SHP Mockingbird Station in Wetzel County, WV southeasterly to the

Atlantic Coast Pipeline (ACP) point of origin in Harrison County, WV. See the map document

attached hereto as Attachment RR10-10a for an overview of Mountain Valley and SHP.

To meet the combined requirements of the two projects while utilizing a MAOP of 1,480 psig,

Mountain Valley would have to install approximately eight miles of 42-inch pipeline from

Bradshaw Compressor Station west to SHP’s Mockingbird Station in order to align with the SHP

route. One disadvantage of collocating Mountain Valley and SHP in the SHP corridor would be

the crossing and impacts to approximately 3.6 miles of West Virginia Division of Natural

Resources lands in the Lewis Wetzel Wildlife Management Area (WMA). The Mountain Valley

route was designed to avoid as many public resources like the Lewis Wetzel WMA as

practicable.

The greatest disadvantage to the “one route-two pipeline” alternative is the rugged terrain along

several segments of the SHP route. See the map document attached hereto as Attachment RR10-

10b for examples of the terrain. The narrow ridgelines and steep slopes in much of West Virginia

would not allow for the safe installation of two large diameter pipelines.

Additionally, there are several occurrences of existing Dominion Transmission (DTI) pipelines

and/or gathering pipelines from various operators along many of the ridgelines that SHP

traverses , which would place three or more pipelines for portions of the same corridor if

Mountain Valley were to collocate.






318

The potential for mountain top removal in order to install two or more large diameter pipelines

would exist, which would reduce the probability of restoration to original grade and increase

destabilization risks of soils due to a greater area of disturbance for the pipelines.

Examples of problematic terrain along the SHP route include:

• the crossings of a few ridgetops with an existing 30-inch DTI pipeline near the point of

origin of ACP in Harrison County, WV between MP 0.0 and 1.5 (See Attachment RR10-

10b Map A);

• the crossings of multiple mountaintops and associated narrow ridgelines with some side

slopes in Doddridge County, WV between MP 3.5 and 7.0;

• the crossings of US Highway 50, multiple mountaintops and associated narrow ridgelines

with some side slopes in Doddridge County, WV between MP 8.0 and 11.0;

• the crossings of multiple mountaintops and associated ridgelines in the same right-of-way

as an existing 30-inch DTI pipeline and several gathering pipelines in Doddridge County,

WV between MP 12.0 and 19.0 (See Attachment RR10-10b Map B);

• the crossings of multiple narrow ridgelines and existing DTI pipelines in Doddridge and

Tyler Counties, WV between MP 21.0 and 23.0;

• the crossings of multiple mountaintops and associated ridgelines through the Lewis

Wetzel WMA and surrounding terrain in Wetzel County, WV between MP 23.0 and 28.0

(See Attachment RR10-10b Map C);

• the multiple crossings of the South Fork Fishing Creek, and crossings of multiple

mountaintops with associated ridgelines in Wetzel County, WV between MP 28.0 and

31.0 (See Attachment RR10-10b Map D);

• and the crossing of multiple ridgelines in the same right-of-way as existing transmission

and gathering pipelines in Wetzel County, WV between MP 31.0 and 33.0.

Based upon the extensive environmental disturbances, slope stabilization risks, and worker and

community safety issues detailed above, the “one route-two pipeline” scenario is not

constructible in this terrain.










319


Request:


11. Section 10.6.4 indicated that: “the proposed Route incorporates route changes along the

segment of the route that avoids some of the areas of concern identified above.” List the

identified areas of concern that would be avoided, and also the areas of concern not

avoided by the proposed route.

Response:

The text referenced in this request is referring to the Proposed Route between mileposts 174.8

and 227.5. In this area the Proposed Route avoids:

• Peters Mountain Wilderness Area, Mountain Lake Wilderness Area, and Brush Mountain

Wilderness Area;

• Known occurrences of two rare species;

• Some areas of karst geology in the Pembroke and Newport areas;

• Residential areas including Preston Forest;

• Newport Recreation Area athletic fields, and about 0.2 mile of a parcel protected under

easement to the Virginia Outdoors Foundation; and

• several cave openings, including Tawney Cave.

In this area the Proposed Route would not avoid:

• All areas of karst geology (although crossings of karst are minimized by the Proposed

Route, it is not avoided entirely); and

• The Blake Preserve (the Proposed Route has been modified in this location to reduce the

crossing length of the preserve, but it does not avoid crossing it entirely (see discussion in

Section 10.6.8)).










320


Request:


12. Section 10.6.8 indicated that the proposed route would cross approximately 350 feet of

the Blake Preserve, but table 10.6-8 stated that 800 feet of the Blake Preserve would be

crossed. Resolve the apparent discrepancy.

Response:

Section 10.6.8 states that Blake Preserve is crossed by the Proposed Route at milepost 223.5 for

approximately 350 feet and is adjacent to the Proposed Route at milepost 223.8 for

approximately 450 feet. See also Figure 10.6-8. The total length crossed plus length adjacent

equals 800 feet. Where the Proposed Route is adjacent to the preserve at milepost 223.8 the

pipeline centerline does not cross the preserve boundary, but some construction and permanent

right-of-way does intersect the boundary of the preserve. Therefore, a conservative estimate of

length crossed is 800 feet.










321


Request:


13. Provide the “forested land affected” data missing from table 10.6-12.

Response:

The requested information is provided below.

Table 10.6-12

Comparison of Cahas Mountain Variation and the Proposed Route

Feature Cahas Mountain

Variation Proposed Route

Resources

Forested land affected during construction (acres) 116.8 98.2

Forested land affected during operation (acres) 46.7 39.4










322


Request:


14. Regarding the analysis in section 10.6.17, provide a comparative discussion regarding

potential impacts to hikers during construction such as duration and visibility of

construction activities, accessibility for heavy equipment (such as boring machines), and

noise levels and duration.

Response:

Section 10.6.17 compares potential impact on the Appalachian National Scenic Trail (Trail)

between the eight pipeline alternatives that cross the Trail, including the Proposed Route.

Mountain Valley Pipeline has prepared a site-specific crossing plan for the Proposed Route

where it crosses the Trail, which includes crossing underneath the Trail by horizontal bore

leaving a vegetative buffer on either side of the Trail, and is evaluating potential additional

mitigation measures including timing of construction during non-peak use, flagging of work

zones, signage for Trail users, and temporary Trail re-routes if appropriate. Mountain Valley

Pipeline has not prepared plans or evaluated mitigation options for any of the alternative Trail

crossings therefore directly comparing potential impacts is somewhat speculative. However, it is

assumed that similar mitigation designed to minimize impact on hikers could be implemented, or

may be required, at any of the crossings, with the primary variation being whether the Trail could

be crossed by horizontal boring or would require traditional open cut. Mountain Valley Pipeline

has not evaluated the feasibility of horizontal boring underneath the Trail for any of the

alternative crossings, and therefore is not able to assume a specific crossing method for the

alternatives. However, a comparative discussion of impacts to hikers from either a horizontal

bore or an open cut method is included below. Visual impacts to hikers resulting from the

pipeline crossing location relative to existing man-made forest clearings, for each alternative, is

described in Section 10.6.17 and Table 10.6.17 of Resource Report 10.

In general, a horizontal bored crossing of the Trail would result in the least impact on hikers at

the immediate point of the pipeline crossing because a bored crossing would preserve vegetation

on either side of the Trail. The amount of vegetation buffer at any crossing location would

depend on site-specific construction evaluation. During a bored crossing construction noise may

or may not be audible to hikers along the Trail depending on construction activity at the moment

in time when a hiker is present, and construction equipment may or may not be visible to hikers

depending on the width and density of the vegetation buffer, and season (leaf on or leaf off).

Noise levels audible to hikers would vary depending on stage of construction and the topography

and vegetation between the work space and the Trail. The duration of a bored crossing could be

longer than an open cut crossing because of the preparation of bore pits and boring equipment,






323

however during the actual bore some noise-generating equipment would be below grade within

the bore pit which would reduce audible noise to hikers. With a bored crossing there would be

periods of time during pipeline construction when a hiker could pass the pipeline crossing and

not realize the presence of the project. Immediately following construction there would be no

visible presence of the pipeline construction activity because of the undisturbed vegetation buffer

maintained through use of horizontal bore. Therefore long-term visual impacts on hikers would

be greatly reduced through the use of a bored crossing.

An open cut crossing of the Trail would require vegetation clearing for the full construction

right-of-way width (125 feet) which would create an opening immediately visible to hikers as

they approached the crossing location. The visual impact on hikers would depend on whether

the pipeline is adjacent to an existing clearing or on new right-of-way. As shown in Table

10.6.17, Route Alternative 1 and Variation 110J would be adjacent to existing rights-of-way at

the location of the Trail crossing; therefore, visual impact from vegetation clearing would be less

at these crossings. During an open cut crossing construction noise may or may not be audible to

hikers along the Trail depending on construction activity at the moment in time when a hiker is

present, and actual construction equipment may or may not be visible to hikers depending on

construction phase. Noise levels audible to hikers would vary depending on stage of

construction and the topography and distance between active construction equipment and the

hikers. The duration of active construction in the immediate Trail area could be reduced for an

open cut crossing because specialized construction methods would not be required, and the

crossing could be treated as a “tie-in” similar to a road crossing. However, with an open cut

crossing, once the construction right-of-way is cleared of vegetation, the presence of the pipeline

construction project would be obvious to hikers crossing the right-of-way even if there was no

active construction in the area at the time a hiker was present. A primary concern for an open cut

crossing of a Trail is maintaining a safe and clearly marked path across the construction work

area at all times. This concern begins with vegetation clearing of the right-of-way and extends

through every construction phase to the completion of right-of-way restoration, and must be

addressed on a daily basis, around-the-clock. Signage and fencing must be maintained and

relocated as needed and safety monitors/escorts may be appropriate during certain construction

phases. Following construction by open cut crossing, the right-of-way will be regraded and

seeded, and will be clearly noticeable to hikers at the crossing location for several growing

seasons.










324


Request:


15. As previously requested in our comments dated August 11, 2015, supplement appendix

tables 10-D-1 and 10-D-2 (which are subsequent iterations of former table 10.6-19) to

also include data columns for individual tract/parcel numbers (which can be directly

connected to names in the landowner list in appendix 1-M and also to tract/parcel

numbers in the alignment sheets) as well as a conclusion statement (where applicable)

regarding whether all stakeholder’s routing or specific resource avoidance concern (e.g.,

proximity to a home, well, spring, wetland, future residential development, etc.) have

been resolved (resolution including not just route or work space adjustments, but also

potentially changes in construction method or other mutually agreeable mitigation). The

analysis should be based on direct stakeholder discussions and on-site evaluations, if the

landowner is willing, and on available desktop imagery and data if landowner contact or

access is denied. Update the amended appendix tables 10-D-1 and 10-D-2 to reflect any

landowner accommodations completed since the filing of the application and also include

two additional, comparable tables with one detailing any requested route

modifications/mitigation that were rejected by Mountain Valley and the other describing

any such requests that are pending while under review by the company.

Response:











325


Request:


16. As previously requested in our comments dated August 11, 2015, include applicable

information for all proposed and alternate compressor station sites as described in

section 10.4 of our Guidance Manual for Environmental Report Preparation (such as

land availability, wetlands, waterbodies, and zoning) and provide comparative data in

tables including total parcel size, area disturbed during construction, and area used during

operation. Include information on the location and number of NSAs for all four

directions (not just the closest). Show the actual size and shape of the specific parcels for

the proposed and alternative compressor station sites on figures 10.7-1a, 10.7-1b,

10.7-2a, 10.7-2b, 10.7-3a, and 10.7-3b not just map dots or generic rectangles.

Response:











326


Request:


17. As previously requested in our comments dated August 11, 2015, identify and fully

assess at least one viable, constructible alternative site for the Stallworth Compressor

Station.

Response:

Alternatives 3A and 3B were identified in resource report 10 section 10.7.1.3. These sites were

considered viable, but the primary location for the site was chosen over these due to the expected

lower amount of earthwork involved and the terrain shielding it offered from the local noise

sensitive areas. The following table summarizes some of the preliminary figures that were used

in the selection of the site:

Site Approximate Cut/Fill

Volume (yd3)

Construction Acreage

Operational Acreage

Pad Elevation

(fasl)

Distance to Closest NSA (ft)

Primary 33,300 25 5.7 2771 1340

Alternative 3A 82,600 24 5.7 2500 1355

Alternative 3B 184,500 29.3 5.7 2538 2455

Note that these earthwork figures were determined using a desktop analysis software for cut/fill

design while evaluating site alternatives.

Alternative 3B is expected to require the construction of a stockpile due to excess material,

require steep cut and fill slopes to construct, and could potentially impact a local stream. For

these reasons, Alternative 3A and the primary site were considered more attractive than

Alternative 3B.

Although the construction area for the primary site is slightly larger than Alternative 3A, the

expected cut/fill volumes were lowest of all the sites. Alternative 3A is within 50 feet of the

same local stream, so going with the primary site eliminated any potential risk of impacting it.

Aside from the lower amount of earthwork involved, the primary site offered greater terrain and

vegetative shielding over Alternative 3A to reduce noise impacts on any nearby noise sensitive

areas. Most of the nearby homes are at an elevation of approximately 2470 ft. Going with the

primary site allows the station to sit approximately 300 ft above them in a forested area.

Alternative 3A is at nearly the same elevation as the nearby homes and sits adjacent to an open






327

field that would provide little shielding to the homes. It is expected that it would be possible to

meet the 55 dBA Ldn requirement at site 3A, but the primary site shielding offers lower noise

levels to minimize the noise impact on the local residents. The expected noise impacts to the

local NSA’s from the primary site can be found in resource report 9, table 9.2-13, reproduced

below.

Table 9.2-13

Predicted Sound Levels –Stallworth Compressor Station

NSA

Distance from Compressor

Station to NSA (feet) D

ire

cti

on

Measured Existing Ambient

Estimated Contribution of Station Equipment

Combined, All Sources Including Ambient

Increase Above Existing

Condition

Ldn dBA Leq dBA Ldn dBA Ldn dBA dB

1 2,835 WNW 54.9 30.4 36.8 55.0 0.1

2 1,985 West 39.6 34.0 40.4 43.0 3.4

3 2,085 SW 44.9 34.0 40.4 46.2 1.3

4 1,465 SSW 35.8 27.2 33.6 37.8 2.0

5 1,340 SE 54.1 33.0 39.4 54.2 0.1

6 2,755 ESE 54.1 29.7 36.1 54.2 0.1










328


Request:


18. As previously requested in our comments dated August 11, 2015, report each

landowner’s willingness to accommodate all aboveground facilities, such as the Harris

and Bradshaw Compressor Stations, pig launchers/receivers, meter stations, MLVs, and

communication towers.

Response:

See Attachment RR10-18. This attachment contains privileged information and is labeled

“Contains Privileged Information – Do Not Release.”










329


Request:


19. As previously requested in our comments dated March 13, 2015, include an analysis of

alternative sites for all other (non-compressor station) aboveground facilities, such as

meter stations and mainline valves, that considers their potential for visual impact or

noise effects upon residences in comparison to the proposed aboveground facilities

locations.

Response:

Mainline Valves: The mainline valve settings were selected based upon the valve spacing

requirements of 49 CFR 192, valve spacing requirements for railroad crossings, location of

company facilities, location of population, access to the site, and location of above ground

electric utilities. The visual impact of the mainline valve sites will be insignificant due to being

installed below ground. The minimal amount of surface riser pipe for the valve operators

aboveground will be painted green that will blend in with the plants and trees. The noise level of

normal operations of the mainline valve will be insignificant due to being installed below

ground.

Meter Stations. For the meter stations, the station locations were dictated by criteria such as

terrain, existing land uses, size of the parcel, proximity to residences, and with willingness of the

landowner to sell the parcel. As part of Resource Report 9, FERC Data Request 7, Mountain

Valley will conduct noise surveys at the Mobley, WB, Sherwood, and Transco meter station

sites.

Mobley Interconnect. Mountain Valley Pipeline will extend from Equitrans’ H-302 pipeline

near the MarkWest Liberty Midstream & Resources Mobley Processing facility. Due to the

rugged topography of Wetzel County, WV, and the location of the Equitrans line H-302 which

runs from the MarkWest Mobley facility north into Pennsylvania, the selected site is the closest

suitable location for the interconnect. Movement of the Interconnect to another location would

result in an increase in environmental impacts due to an increase in pipeline footage and earth

disturbance due to the lack of an area flat and large enough to install a meter station. There are

limited access points north of the selected site for approximately a mile which would also

increase the environmental impacts due to the construction of new access roads. Therefore,

Mountain Valley selected the best origin point of the project starting from H-302. There is one

hunting camp approximately 350 feet from the selected site which is occupied a few weeks out

of the year and is visually shielded via deciduous trees. This hunting camp will be part of the

noise modeling study in Resource Report 9, Request 7.






330

WB Interconnect. Due to the terrain at the intersection of the Mountain Valley Pipeline and

Columbia’s WB and WB-5 lines, the selected site is the closest suitable location for the

interconnect. Mountain Valley reviewed a location approximately 950 feet east of the selected

site, Alt WB-1. The Construction Acreage for Alt WB-1 would change from 6.2 acres to 6.4

acres, a net increase of 0.2 acres while the Operational Acreage for both sites would remain the

same at 1.2 acres. Movement of the site to the alternate location would also result in an increase

in environmental impacts due to an increase in required pipeline footage (1.7 acres). Alt WB-1

does not offer any visual impact advantages over the selected site. The final site location also

required approval from Columbia Pipeline Group, which has occurred. There is one permanent

residence in the area and is shielded via deciduous trees from both locations. The Mountain

Valley Pipeline Harris Compressor Station is located about 1,000 feet away from the proposed

interconnect site and 1,950 feet away from Alt WB-1.

Sherwood Interconnect. Like the Mobley interconnect, the rugged topography limited the

selection of suitable locations. The proposed location was based on the proximity to the

MarkWest Sherwood Processing facility. Mountain Valley reviewed two alternate locations. Alt

SW-1, near milepost 21.65, was eliminated due to an existing overhead distribution power line

and underground Dominion Transmission pipeline in the proposed Construction Acreage. Alt

SW-2 is near milepost 24.8. The Construction Acreage for Alt SW-2 would result in a decrease

of 0.1 acres while the Operational Acreage would remain the same at 2.0 acres. Alt SW-2 is not

adjacent to the Mountain Valley pipeline route. It would require approximately 1,200 feet of

additional pipeline resulting in about 2.1 acres of additional environmental impact. The

proposed site and Alt SW-2 are both about 150 feet higher in elevation than the nearest residence

which serves to minimize both noise and visual impacts.

Transco Interconnect. Mountain Valley Pipeline will extend to Transcontinental (Transco) Gas

Pipe Line Company’s Zone 5 compressor station 165. The proposed site is located at the

intersection of the Mountain Valley Pipeline and Transco’s Station 165. Alt T-1, approximately

700 feet south of the selected site, was eliminated due to existing wetlands. Alt T-2 is

approximately 1,300 feet south and is suspected to contain wetlands similar to what was found at

Alt T-1, but is under further review. Alt #3 is approximately 900 feet north of the proposed site

and Alt T-4 is located approximately 900’ southwest of the proposed site. There is one residence

about 900 feet west of the proposed site and is visually shielded via dense evergreen trees. This

same residence is about 1,450 feet from Alt T-1, 1,750 feet from Alt T-2, 1,200 feet from Alt T-

3, and 900’ from Alt T-4. Due to the relatively flat nature of the terrain in this area, all three

alternatives produce the same Construction (6.2 acres) and Operational (2.4 acres)

Acreage. Being the terminus, there is no difference in acreage for the piping from the proposed

or alternates to the tap locations. The final site location requires approval from Transco, which

has not occurred. Mountain Valley is currently reviewing a final location with Transco and

expects to finalize the location by March 31, 2016.






331

Table RR10-19

Site Construction

Acreage Operational

Acreage Interconnect

Piping Acreage Nearest

Residence

WB 6.2 1.2 1.7 550'

Alt WB-1 6.4 1.2 3.4 750'

Sherwood 7.1 2.0 0.1 850'

Alt SW-1 6.3 2.0 0.1 450’

Alt SW-2 7.0 2.0 2.1 750'

Transco 6.2 2.4 3.1 900'

Alt T-1 6.2 2.4 3.1 1,450'

Alt T-2 6.2 2.4 3.1 1,750'

Alt T-3 6.2 2.4 3.1 1,200'

Alt T-4 6.2 2.4 3.1 900’










332


Request:


20. Evaluate the feature “Old growth forest crossed within National Forest” for all

alternatives that cross National Forest System lands. For example, the feature is

presented in table 10.6-4 but it is not presented in table 10.5-4 with the East Tennessee

Natural Gas (ETNG) Alternative crossing National Forest System lands.

Response:











333


Request:

Resource Report 11 – Reliability and Safety

1. As previously requested in our comments dated August 11, 2015, describe other actual or

potential components of natural gas, with emphasis on likely other or trace components

that may be particular to any known source areas for the natural gas to be transported.

Describe potential risks to public health from leakage, venting, compressor stations, or

any other project component, along with any plans to avoid, minimize, or mitigate

potential impacts.

Response:

Mountain Valley has filed a tariff with specific gas quality specifications that outline the gas

quality that would be accepted into the pipeline. These gas quality specifications hold the

shipper accountable for gas delivered to Mountain Valley. The majority (greater than 96%) of

gas composition will be methane with the remaining constituents being the longer hydrocarbon

chains of ethane, pentane, etc. The transported gas will primarily come out of gas plants that

chill the gas to remove the heavier hydrocarbons in a liquid state. The residual gases are the

lighter hydrocarbons above pentanes. There may be very small percentages (less than 1%) of

pentanes plus from transported gas that is not processed.

There are minimal potential risks to public health from leakage, venting, compressor stations, or

any other project component. Best Management Practices are designed into the compressor

stations to minimize any venting or leaking at stations for public health impacts. For example,

the equipment pneumatic control system is designed to use compressed air rather than natural gas

that has a tendency to bleed off control valves used in older stations. The compressors are

turbine compressors that have a sealed body design versus reciprocating compressors that have a

rod packing system that is designed to slightly vent gas from the seals on each cylinder. Power

generated on-site for either back-up or primary power will be through micro-turbines versus

legacy reciprocating compressor generators. Should emergency venting occur, the contained gas

volume in the section of pipe to be vented is small and will dissipate rapidly to avoid any

noxious high concentration related health issues.










334


Request:


2. Section 11.1.7 indicated that: “Mountain Valley Pipeline is in the process of reviewing

identified areas of potential slope stability issues.” Provide the results of the analyses or

a timeframe for their submittal.

Response:











335


Request:


3. As previously requested in our comments dated August 11, 2015, include an analysis of

existing emergency responders, equipment, labor, status (full-time or volunteer), and

capability along the pipeline route, particularly for fire departments in remote or

relatively inaccessible areas. While a numerical summary of law enforcement and fire

departments by county is provided in RR 5 (table 5.2-9), no assessment of the adequacy

of first responder capability in relation to pipeline incidents in the project area in general

or in remote areas in particular was provided.

Response:

Existing emergency responders are trained and qualified in their respective disciplines to respond

to emergency situations. Specifically for fire departments, the states of West Virginia and

Virginia have defined requirements for staffing, training and equipment that prepare and enable

firefighters to successfully manage public safety and fight secondary fires as a result of a

pipeline emergency. A map (Attachment RR11-3) was developed to show the proximity of fire

departments in relation to the proposed pipeline route. In the most remote portion of the

pipeline, the furthest distance between a fire department and the pipeline is approximately eight

(8) miles.

Natural gas pipeline fires are extinguished by eliminating the source of fuel through isolation

valves, which will be performed remotely or locally by Mountain Valley personnel. Emergency

responders will be responsible for managing public safety and fighting any secondary fires that

may have occurred as a result.

The states of West Virginia and Virginia provide requirements for establishing and maintaining

fire departments, which ensures departments are adequately staffed, trained and equipped to

successfully respond to and manage fire emergencies.










336


Request:


4. Table 11.1-2 indicated that alignment sheets and maps included in RR 1, appendix 1-A

has information on township and land use within each high consequence area (HCA);

however, HCAs were not identified on these sheets. Provide the location of HCAs

identified in table 11.1-2 on alignment sheets.

Response:

The HCAs are identified on the alignment sheets in the Class Location/HCA Band.










337


Request:

Supplemental Filing – December 7, 2015

Waterbody Crossing Drawings

1. On December 7, 2015, Mountain Valley filed site-specific waterbody crossing profile

drawings for the Elk River, Gauley River, Greenbrier River, Little Kanawha River, and

Pigg River. Table 2-A-2 lists the crossing length for the Pigg River as 83 feet. Clarify

why a site-specific drawing was provided for this crossing. Also, according to

table 2-A-2 the Left Fork Holly River has a crossing length of 151 feet. Provide a site-

specific crossing plan for this waterbody.

Response:











338

U.S. Environmental Protection Agency Comments on the Application

Request:


General The Purpose and Need Statement (P&N) should present the need, “problem” or

deficiency for energy conveyance, the need for the project in the proposed

location and the need for the project at this time, including the market. It would be

useful to explain to the public how the project fits into the network of pipelines,

how need is demonstrated to FERC and the public in light of other proposed

projects. The purpose and need should go beyond the applicant’s need for the

project and should for example include addressing specific quantifiable,

measurable energy demand for the target area.

Questions are presented below. Some responses may be appropriate in the P&N,

other responses may be addressed in other chapters of the Draft EIS. It might be

helpful to cite in Executive Summary and early chapters where additional

information can be found in the EIS (body, appendices or Resource Reports)

when it is prepared.

Response:











339


Request:


Page 1-4 The document should discuss when the interconnects will be finalized. The

distance of the interconnections from the proposed pipeline should also be

discussed.

Response:

The Mobley Interconnect, Sherwood Interconnect, and the Columbia WB Interconnect are

scheduled to be placed in service no later than December 2017. The Transco Interconnect is

scheduled to be placed in service no later than December 2018.

The Mobley, Sherwood and Transco Interconnects will be located adjacent to the Mountain

Valley Pipeline right-of-way. The Columbia WB Interconnect will be located approximately

1,000 ft. away from the Mountain Valley Pipeline right-of-way.










340


Request:


Page 1-8 The size, type (above ground or below ground), and material type for the tanks in

the compressor stations should be mentioned so in order to comply with Federal

or state hazardous containments regulations.

Response:

Each compressor station will have two vertical above ground storage tanks. There will be a

10,000 gallon pipeline liquids/waste water storage tank and a 4,000 gallon used oil tank. Both

tanks will be double wall and will be of carbon steel construction. The tanks will be designed to

meet NFPA-30 (Flammable and Combustible Liquids Code) and will be manufactured in

accordance with UL-142 standards (Steel Above Ground Tanks for Flammable and Combustible

Liquids).










341


Request:


Page 1-9 The mainline block valves should be described including their appearance, the

use, as well as its environmental effects.

Response:

The mainline valve setting will be used to meet operational needs and the design and installation

requirements described in 49 CFR 192.179(a) – Transmission Line Valves.

Each valve site will be surrounded by a chain link fence contained within the permanent right-of-

way of the pipeline. Each site will consist of a 42” mainline valve installed below grade in-line

with the Mountain Valley Pipeline. Hence, the suction and discharge piping is in-line with the

Mountain Valley Pipeline. The setting will have two below ground branch connections serving

an above ground bypass assembly with two blow off connections. The 42” mainline valve will be

equipped with aboveground extensions connecting valve actuators to allow for local or remote

operation.

There will be no additional environmental effects because the mainline valve sites are located

within the pipeline operational right-of-way.






342










343


Request:


Page 1-16 With the physical changes of the contractor yards (grading, graveling, placement

of surface materials, etc.) the document should discuss the potential for the sites

to be returned to previous conditions including the time in which it will take to re-

establish pre-construction conditions and if all the contractor yards are expected

to return to preconstruction conditions.

Response:

All contractor yards will be restored to original conditions post project completion. The

approximate completion time to restore contractor yards is approximately two weeks.










344


Request:


Page 1-23 Any chemicals and waste caused from welding and construction of the pipeline

should be discussed. This description should include any environmental effects

on water output from hydrostatic testing.

Response:











345


Request:


Page 1-23 The chemical properties and use of the epoxy coating in the construction process

should be described in the draft EIS.

Response:











346


Request:


Page 1-25 The document should discuss if Mountain Valley Pipeline will segregate topsoil

in the rare occasion it goes past 12 feet.

Response:

Mountain Valley Pipeline plans to segregate topsoil, subsoil, in addition to substrate soil in the

rare event the trench exceeds 12 feet.










347


Request:


Page 1-26 Unsaturated wetlands may depend on the time of year, conditions and weather at

the time. Additionally, wetland soils that are observed as “unsaturated” may still

be hydric and delineated as wetlands. Mountain Valley Pipeline should consider

building practices that protect wetland soils beyond wetlands with standing water.

Response:











348


Request:


Page 1-39 If restoration success is contingent upon state and federal agency approval, what

measures does Mountain Valley Pipeline take if the agencies don’t approve of the

conditions.

Response:

Restoration success along the Mountain Valley Pipeline will be determined by revegetation

success and stability. Site reviews will be conducted by applicable agencies to determine if

restoration has been completed properly. Should an area be deemed by an agency as

unsuccessful, Mountain Valley Pipeline will work with that agency to develop a site specific

plan to resolve the restoration issue.










349


Request:


Page 1-39 The document should mention how much of the pipeline’s route might fall under

the exception in herbaceous vegetative cover. Regarding the statement that some

right-of-way will not be returned to the original land contours to prevent erosion,

approximately how much of the pipeline’s route might fall under this exception?

Response:











350


Request:


Page 1-40 To what extent would soil compaction prevent successful and natural

revegetation. Explain if monitoring of succession will take place and if there are

contingencies if it is prevented.

Response:











351


Request:


Page 1-50 The document should discuss the process in which a landowner makes an

environmental complaint and how it goes to the project’s environmental inspector

to assess the complaint’s validity.

Response:

Mountain Valley Pipeline established a step-wise protocol to address landowner issues and

environmental complaints prior to and during the construction phase as outlined in Resource

Report 1 Appendix 1-N. The process will utilize Mountain Valley Pipeline's 24-Hour toll-free

phone line (844-Mountain Valley Pipeline-TALK) and/or email submission to

[email protected]. Mountain Valley Pipeline will keep a formal record of all

calls and emails received in order to effectively track inquiries and resolutions. The responding

Mountain Valley Pipeline Project representative will request all necessary information to

complete the informational section of the Tracking Log, including the individual’s name,

address, parcel number, phone number, and Project reference. Additionally, any details offered

regarding the purpose of the call will be entered on the Tracking Log. All call logs are then

routed to the appropriate Mountain Valley Pipeline representative

Environmentally related complaints will be routed to the Mountain Valley Pipeline lead

environmental inspector. To clearly define an individual’s issue, the Mountain Valley Pipeline

Project representative will work with the landowner to help understand their concerns.

If the issue can be resolved during initial discussion with the individual, the Mountain Valley

Pipeline representative will document how the resolution was reached on the Tracking Log. If a

field visit is necessary, the environmental will make arrangements with the landowner, land

agent, and construction representative (if necessary) to meet in the field. Communication with

the landowner will continue until a resolution can be reached. If a ROW agent receives a direct

phone call relating to environmental issue from a landowner during construction or post-

construction activities, the agent will request all necessary information (as outlined above) and

will initiate submission of the information on the Tracking Log and follow this progression until

a resolution is reached.






352

After working with the appropriate Mountain Valley Pipeline representatives and agents, if the

landowner is still not completely satisfied with the resolution, the individual should contact the

Commission’s Landowner Helpline at (877) 337-2237, or by email, [email protected].










353


Request:


Table 1.10-1 The draft EIS should describe the size of the Transco pipeline to help the reader

understand how the Mountain Valley Pipeline project will correlate with it. The

build material and diameter will help the reader know if they are compatible

infrastructures.

Response:

The Transco Pipeline system constructed of carbon steel stretches over 10,000 miles from the

Gulf Coast states up to the Northeast. It has 56 compressor stations and has been in operation

since the 1950s, with periodic expansion projects. The Mountain Valley Pipeline Project will

terminate at Transco’s Station 165 in Pittsylvania County, Virginia.

At Transco’s Station 165, there are four (4) pipelines (A – 30”, B – 30”, C – 36”, D – 42”)

coming into the station and three (3) pipelines (A – 30” , B – 30”, C – 36”) leaving the

station. Mountain Valley Pipeline plans to have taps on each of the pipelines.










354


Request:


Page 1-61 Under “Projects Geology and Soils,” is there evidence from past pipeline projects

to say how long “temporary” construction impacts last? Although construction of

two projects in proximity to each other may not overlap in time, their impacts

may overlap in time.

Response:











355


Request:


Page 1-62 The value and functions of interior forest loss should be characterized and

quantified; the replacement by alternative habitat does not necessarily replace

functions. Recommendations for replacement of forest and interior forest in

particular should be made (e.g. identifying areas of “holes” in resources that could

be restored and preserved). Edge effects may increase habitat for species that

prefer open areas, but edge also favors establishment of invasive species.

Response:











356


Request:


Page 1-65 The point of cumulative impacts (CI) is to consider activities in the CI study area

that impact resources affected by the project. These are activities related or

unrelated to the project. Please include the emissions footprint of other known

projects, not just the 1.0% of West Virginia’s emissions from the Mountain

Valley Pipeline project.

Response:

Detailed emissions information related to other past, present and reasonably foreseeable projects

in the vicinity of the Mountain Valley compressor stations is found in Resource Report 9 at

Table 9.1-14. Although the Table title references only reasonably foreseeable planned projects, it

includes past and present projects.










357


Request:


General It is important for the analysis done in the NEPA document to use the information

of the resource reports, including the potential changes in resource quality,

functions and values to clearly assess impacts of any proposed project. This

analysis is important to determine if mitigation can offset losses to the resources.

Some specific questions are presented below. You will also note that we’ve

provided some added information (e.g. on wetland quantity). We have used some

locally available GIS to corroborate data presented in the reports. We are not

suggesting that our numbers are more accurate, more that order of magnitude

values are comparable. Beyond numbers, will we will be trying to understand

how the levels of impact will affect the environment; we look forward to seeing

draft analysis as it is prepared.

As described in the resource report, some environmental effects from construction

(example: sedimentation) may only be temporary, there is potential for acute

water contamination from construction on a watershed or stream if construction

occurs in several sections of a stream or watershed at one time. Mountain Valley

Pipeline should provide details of construction scheduling to allow analysis of any

potential for acute pollution from construction.

Response:

Table (1.4-2) Construction Schedule for Major Components of the Project was included in

Resource Report 1.

Construction will be conducted in spreads in 2017 and 2018. The following table outlines the

year and location in which each spread will perform construction.






358

Year SPREAD MP Begin MP End

2017 1 0.00 25.9

2017 2 25.9 48.05

2017 3 48.05 77.6

2017 4 77.6 104.25

2017 5 104.25 127.9

2018 6 127.9 154.2

2018 7 154.2 181.9

2018 8 181.9 204.75

2018 9 204.75 234

2018 10 234 261.5

2018 11 261.5 300.95










359


Request:


Page 2-23 Soil compaction is likely neither minor nor temporary creating more water runoff.

Please discuss effects of soil compaction on water resources and reference

potential mitigation measures for soil compaction as it relates to water infiltration.

Response:











360


Request:


Page 2-30 Soil compaction has the potential to alter floodwater absorption patterns and thus

affect FEMA zones.

Response:

Construction within FEMA flood zones will be subject to a local permitting approval process.

Mountain Valley Pipeline will be required to submit a plan for construction that will include a

plan to address soil compaction. In most cases, Project reclamation will be reviewed and

approved by the applicable agencies.










361


Request:


Page 2-34 (Table 2.2-5) With regards to Meadow Creek in Green Breenbrier County, why

is a 265-ft. crossing needed for a 30-ft.-wide waterbody?

Response:

Assuming that the data request is referencing Meadow Creek in Greenbrier County, typical

construction will require a minimum two joint section to cross this waterbody. An additional two

joint section on each end will be required due to change in elevation at the edges of the

waterbody to level out.










362


Request:


Section 2.2.3 The documents should discuss in more detail the locations of the discharges to the

hydrostatic testing. Hydrostatic testing can be very water intensive with potential

negative effects to a community’s water supply and potential chemical effects to

used water. The document should discuss any alternatives to hydrostatic testing

such as pneumatic pipeline testing. The amount and sources of water to be

withdrawn should be explained, explanation of storage requirements, impacts of

withdrawal, contingencies to mitigate potential impacts, etc.

Response:

Hydrostatic test discharges will take place in upland areas through energy-dissipating devices,

generally near the source water location. Data on nearby streams is provided in Table 2.2-10 (see

Attachment RR2-35). Mountain Valley Pipeline will comply with all state and local regulations

regarding water withdrawal and discharge, including those related to discharging within

watersheds and impaired waters.

DOT regulations, per 49 CFR 192.503, restrict the maximum allowable pressure of a pneumatic

pipeline test. The pressures required to achieve a successful test for Mountain Valley pipeline

exceed these criteria. Therefore, pneumatic testing is not considered a viable alternative to

hydrostatic testing.

The sources and volumes of water required to complete the hydrostatic test are detailed in

Table 2.2-10 (see Attachment RR2-35). Water will be withdrawn and stored in tanks prior to

pumping it into the pipe. The type and size of these storage tanks will be determined based on

variables such as the flow of the source stream, the size of the test section, and the space

available at the proposed withdrawal site. Withdrawal from the identified source streams will be

in compliance with all state and local regulations. Typically these withdrawals will be scheduled

so that annual low flows are avoided, and be regulated such that they account for no more than

10% of the measured streamflow. As shown in Table 2.2-10 (Attachment RR2-35), in many

instances the proposed withdrawal rate is much less than 10%, sometimes less than 1% of the

anticipated streamflow.






363










364


Request:


Table 2.2.10 The table should add the annual flow per day for the intake and discharge water

sources to help the public understand the extra volume of water from the

completion of hydrostatic testing.

Response:

The percentage of the water required for a hydrostatic test section with respect to the sources

average daily discharge is listed in Table 2.2-10 (see Attachment RR2-35).










365


Request:


Page 2-49 The percentage of each waterbody’s daily flow should be indicated that will

remove water for hydrostatic testing.

Response:

Withdrawal from streams will be limited to a maximum of 10% of the instantaneous flow so as

to minimize hydrologic impacts. These data are shown in the Table 2.2-10 (see Attachment RR2-

35).










366


Request:


Section 2.3.2 Beyond presenting the acreage of wetlands affected by the project, it is important

to know the condition of the resource and the functions and value of the wetlands

to the watershed. Mountain Valley Pipeline should inventory for these factors in

order to properly analyze the effects the project will have on wetland systems and

the effects of any lost functions of the wetlands to the watershed.

Response:











367


Request:


Page 2-66: Table 2.3-1 A total of 9.42 acres of wetlands will be permanently affected by

the project. Using mapping information and the alignment data,

EPA calculated close to 16.13 acres of permanent impact from the

alignment.

Response:

Depending on the methodology used, desktop wetland mapping methods may not accurately

represent field conditions. If impacts were calculated for unsurveyed portions of the route, these

numbers may differ at this time. The total acreage of permanent impacts will be updated once

these areas are field surveyed.










368


Request:


Page 2-71 If an adjacent wetland is impacted by pipeline construction or operation, will

Mountain Valley Pipeline be held accountable for those impacts?

Response:

FERC can elect to address this comment in the EIS.










369


Request:


General The resource reports gather data regarding existing conditions and potential losses

if the project is constructed. Forest loss is a significant potential impact.

Quantification of loss is important, but also assessment of the implications of the

loss. For instance, how will losses effect populations of species that use the

specific habitat and what functions are lost with the quantity of resources

impacted. Functions such as special habitat or carbon sequestration should be

considered and mitigation evaluated. Identification of areas where forest could be

restored to generate forest interior habitat and other forest functions could be

pursued.

The potential loss of 1,600+ acres of forest could release many pounds carbon

held in the plant material, and loose future sequestration potential. The Forest

Service has several tools to help calculate lost carbon sequestration from

deforestation. Mountain Valley Pipeline should consider both lost carbon

sequestration from short and long-term deforestation. 3

Response:

Special habitat for various species are addressed with the state and federal wildlife agencies

through species specific consultations, including surveys for individuals and habitat and

implementation of habitat mitigation as appropriate.

Regarding carbon sequestration:

The U.S. Forest Service PRESTO: Online Calculation of Carbon in Harvested Wood Products

was used to calculate carbon sequestration from short and long-term deforestation. The following

assumptions were made when using the online calculator.

1. Acreage of permanent deforestation in West Virginia (50-foot right-of-way) is 1,184

acres.

2. Acreage of permanent deforestation in Virginia (50-foot right-of-way) is 639 acres.

3. Acreage of temporary deforestation in West Virginia (125-foot right-of-way minus 50-

foot permanent right-of-way) is 1,012 acres.

3 http://www.fs.usda.gov/ccrc/tools/carbon-primer






370

4. Acreage of temporary deforestation in Virginia (125-foot right-of-way minus 50-foot

permanent right-of-way) is 911 acres.

5. Average tree height is 50 feet.

6. 66% of forest is hardwood

a. 70% of hardwood is sawlogs

b. 30% of hardwood is pulpwood

7. 15% of forest is softwood

a. 70% of softwood is sawlogs

b. 30% of softwood is pulpwood

The PESTO results are as follows:

Name Region Area Area Units

Products (C100)

Landfill (C100)

Stored (C100)

Energy Capture

(C100)

No Capture

(C100)

Products (CAvg)

Landfill (CAvg)

Stored (CAvg)

Energy Capture

(CAvg)

No Capture (CAvg)

Short-term WV NE 1012 Acres 1660.7 6818.7 8479.4 10856.4 9653.4 4586.2 5795.8 10382 10197.3 8427.1

Short-term VA SE 912 Acres 1576.8 6707.6 8284.4 11487.5 10835.3 4467.5 5766.4 10233.9 10917.7 9461.4

Long-term WV NE 1184 Acres 1660.7 6818.7 8479.4 10856.3 9653.3 4586.1 5795.8 10381.9 10197.3 8427.1

Long-term VA SE 640 Acres 1575.3 6701.2 8276.5 11476.5 10824.9 4463.3 5760.8 10224.1 10907.2 9452.4

TOTAL - 3,748 Acres 6473.5 27046.2 33519.7 44676.7 40966.9 18103.1 23118.8 41221.9 42219.5 35768

Source: Hoover, M. Coeli, Sarah J. Beukema, Donald C. Robinson, Katherine M. Kellock, and

Diana A. Abraham. 2014. PRESTO: Online Calculation of Carbon in Harvested Wood Products.

U.S. Forest Service. Northern Research Station. General Technical Report NRS-141.










371


Request:


Page 3-4 This section should include if there is any known population that fish for food and

their population. Subsistence fishing should be discussed and the effects the

project has on populations that use fisheries to live.

Response:











372


Request:


Page 3-2 A map should illustrate the closest EFH location to the project, the distance to the

closest EFH, and if there are any waterbodies impacted by the project flows to

EFH streams/waterbodies.

Response:











373


Request:


Page 3-11 The document should describe the process of picking the aboveground sites and if

Mountain Valley Pipeline tried to avoid sensitive riparian zones.

Response:

Route and facility selection criteria are discussed in Resource Reports 1 and 10.










374


Request:


Page 3-13 The document should discuss temporal losses; how long mitigation measures will

take to implement, how long it is expected to take for removed riparian cover to

reestablish.

Response:

The current route, as proposed, includes a permanent 50-foot right-of-way. This encompasses a

total of 1,184.56 acres in West Virginia and 639.44 acres in Virginia. The width of the temporary

construction right-of-way is 125 feet (except in wetlands and stream crossings where clearing

will be reduced to 75 feet) which will temporarily impact an additional 1,012.22 acres in West

Virginia and 911.68 acres in Virginia. Tree clearing activities will occur generally occur during

cooler months to minimize impacts to various species, including birds and bats. However,

construction activities may take place any time of year. Reclamation activities will be completed

within approximately 4 weeks of the start of trenching for a given pipe section.

As discussed in Resource Report 3, Section 3.2.11 Vegetation Impacts and Mitigation, the

timeframe for successful revegetation of areas disturbed by Project construction will depend on

factors such as site topography, aspect, soil texture, and micro climate. All areas not in active

farming (i.e. cultivated crops) will be seeded with restoration seed mixes of native grasses and

forbs, in in coordination with the Wildlife Habitat Council. All areas are expected to be

successfully vegetated with grasses within one or two growing seasons and other forbs and

legumes within 2 to 6 growing seasons. Seed mixes will be developed to maximize the success

of revegetation, including a localized analysis of mixes best suited for use on specific segments

of the pipeline.

At this time, Mountain Valley Pipeline does not intend to plant tree saplings in the temporary

impact area (also often referred to as the “Border Zone”). Replantings within this boarder zone

are designed with the objective of diversifying the habitat, including structural and species

diversity. The result of this type of integrated vegetation management approach allows an

environmentally balanced "feather cut" landscape from the “Pipe Zone” as it moves outward to

the “Border Zone”. Mountain Valley Pipeline proposed to plant native shrubs as fast growing

native shrubs with varying mature characteristics within the “Border Zone”. Properly selected

shrubs should establish within two growing seasons, and reasonably should not take longer than

five.






375

Because the limits of disturbance are drastically reduced in riparian areas (from 125 to 75 feet),

tree removal is already being minimized. The same pipe zone-border zone appraoch is planned

for riparian areas with similar re-establishment timelines to other parts of the right-of-way.










376


Request:


Page 3-23 The EIS needs describe why burning is the final method of clearing brush.

Burning has several negative environmental effects as well as potential hazard to

forest, wildlife, and surrounding communities.

Response:











377


Request:


Page 3-24 Reference material and examples should be cited for the examples of expected

revegetation timeframe of 2-6 growing seasons.

Response:

As discussed in Resource Report 3, Section 3.2.11 Vegetation Impacts and Mitigation, the

timeframe for successful revegetation of areas disturbed by Project construction will depend on

factors such as site topography, aspect, soil texture, and micro climate. All areas not in active

farming (i.e. cultivated crops) will be seeded with restoration seed mixes of native grasses and

forbs, in in coordination with the Wildlife Habitat Council. All areas are expected to be

successfully vegetated with grasses within one or two growing seasons and other forbs and

legumes within 2 to 6 growing seasons. Seed mixes will be developed to maximize the success

of revegetation, including a localized analysis of mixes best suited for use on specific segments

of the pipeline.










378


Request:


Page 3-30 The document should reference its sampling methodology for bats and its choice

of the time of the year.

Response:

Bat surveys were completed in accordance with guidelines in the US Fish & Wildlife Services’

Range Wide Indiana Bat Summer Survey Guidelines (Appendix A, B, D, E and F) and Northern

Long Eared Bat Interim Conference and Planning Guidance (Appendix B and H) as well as the

West Virginia Draft Protocol for Assessing Abandoned Mines/Caves for Bat Use and Virginia

Hibernacula Survey Guidance. All of these documents are referenced in Study Plans that were

provided to, and approved by the US Fish & Wildlife Service, Virginia Department of Game and

Inland Fisheries and the West Virginia Department of Natural Heritage prior to initiating

surveys. Copies of these Study Plans are included in Appendix 3-B of Resource Report 3.










379


Request:


Page 3-31 Please provide a description or reference to the USFWS-FERC Memorandum of

Agreement.

Response:











380


Request:


Page 3-33 (Table 3.3-4) Table 3.3-4 has the calculations for West Virginia. The headings

“Patch”, “Edge”, and “Perforated” should be described and a form

of measurement should be included. Additionally, Virginia should

have a table equal to that of West Virginia describing loss of forest

and edge effects created.

Response:

The data used to populate Table 3.3-4 was specific to core forest areas in West Virginia and was

derived from a state-wide dataset produced by the Natural Resource Analysis Center (NRAC) at

West Virginia University in 2012. This dataset ranks stands of forested land in West Virginia and

determines Core Forest Areas based on acres of continuous habitat and splits forested area into

five categories: patch, edge, perforated, core (<250 acres), core (250 – 500 acres), and core

(>500 acres). Edge and perforated areas occur along the periphery of land tracts containing the

core forest areas. Edge width, designated as 328 feet in this dataset, indicates distance over

which other land uses (i.e. agricultural, urban development, infrastructure) degrade tracts of

continuous forest. Patches are small forest fragments that are completely degraded by the “edge

effect”, but forest cores are large enough to avoid influence from the “edge effect” and are thus

not degraded by the proximity of other land uses. Mountain Valley Pipeline does not intend nor

has the ability to extrapolate values used in NRAC’s dataset and apply them to forested land in

the state of Virginia.










381


Request:


Page 3-33 (Table 3.3-4) From Table 3.3-4, it seems that a large portion of the construction

of the project will affect large core forests. The document should

explain why a disproportionate amount of large core forest will be

affected.

Response:

See the response to Resource Report 3, EPA Comment on Page 3-33 (Table 3.3-4).










382


Request:


Page 3-34 Discuss some of the mitigation Mountain Valley Pipeline will do to replace forest

cover using native plants and shrub. It does not discuss how it will affect

fragmentation for those species that use interior forest. Analysis of this impact

should be presented in the EIS. Mitigation should be evaluated.

Response:

At this time, Mountain Valley Pipeline does not intend to plant tree saplings in the temporary

impact area (also often referred to as the “Border Zone”). Replantings within this boarder zone

are designed with the objective of diversifying the habitat, including structural and species

diversity. The result of this type of integrated vegetation management approach allows an

environmentally balanced "feather cut" landscape from the “Pipe Zone” as it moves outward to

the “Border Zone”. Mountain Valley Pipeline proposed to plant native shrubs as fast growing

native shrubs with varying mature characteristics within the “Border Zone”. Properly selected

shrubs should establish within two growing seasons, and reasonably should not take longer than

five.

FERC can address the associated comments in the EIS.










383


Request:


Page 3-44 Mountain Valley Pipeline should consider revising the impacted acreage for bats,

as the trees that actually represent suitable habitat will not grow back in a

reasonable timeframe. In this case, the construction right-of-way impacts may not

be “temporary” because trees require a large amount of time to grow and become

hollow or fall (i.e., the suitable habitat).

Response:











384


Request:


Page 3-55 The document should discuss why avoiding the 100-year-old forest stands was

not an option. These impacts are effectively permanent due to the age of the trees.

Response:

See the detailed discussion of alternatives in Resource Report 10.










385


Request:

Resource Report 5 – Socioeconomics / Environmental Justice

Page 5-23 The top paragraph makes the analysis of West Virginia of block groups that are

disturbed by the pipeline route. The resource report does not make the same

analysis for Virginia and should do so in the draft EIS.

Response:

Resource Report 5, Section 5.2.7.2 states that at least 20 percent of households were below the

poverty level in 16 of the 38 census block groups crossed by the pipeline in West Virginia (Table

5.2-16). These block groups were distributed along the pipeline route in nine of the 11 counties

that will be crossed. In Virginia, at least 20 percent of households were below the poverty level

in five of the 22 census block groups that will be crossed (Table 5.2-17). This paragraph

presents information for both West Virginia and Virginia. Review of the Environmental Justice

section indicates that all variables analyzed for West Virginia are also analyzed for Virginia.










386


Request:

Resource Report 5 – Socioeconomics / Environmental Justice

Page 5-24 In addition to county and census block data, if the information is available, the

draft EIS should include other sensitive receptors such as nearby daycare

facilities, schools, hospitals, and nursing homes that are in close proximity to the

project. If there are none, it should be stated.

Response:

Information on sensitive receptors within 0.5 mile of Mountain Valley Pipeline is presented in

Resource Report 11 (see Section 11.3.13 Schools, Nursing Homes, and Hospitals within 0.5 Mile

of Mountain Valley Pipeline). The information from this section is repeated below.

11.3.13 Schools, Nursing Homes, and Hospitals within 0.5 Mile of Mountain Valley

Pipeline

In its August 11, 2015 comments on draft Resource Report 11, FERC asked for a listing of

schools, nursing homes, hospitals, and other facilities with sensitive sub-groups that may be

difficult to evacuate that are located within 0.5-mile of any Project facility. Such facilities that

have been identified by Mountain Valley Pipeline using publicly available data are listed in

Table 11.3-1.

Table 11.3-1

Schools, Nursing Homes, and Hospitals Within 0.5 Mile of Mountain Valley Pipeline

State County MP Facility a/ Distance and Direction from Project Work Area

West Virginia Nicholas 122.1 Panther Creek Elementary School 0.33 mile East

Summers 170.2 Greenbrier Academy for Girls 0.55 mile East

Virginia Franklin 249.6 Monte Vista School 0.42 mile South

Franklin 265.2 Sunshine Valley School 0.05 mile North

a/ No nursing homes or hospitals were identified within 0.5 mile of any Project facility using publicly available data sources.










387


Request:

Resource Report 6 – Geological Resources

Page 6-11 (Table 6.3-1) Table 6.3-1 shows there are mines and quarries in close proximity

of the project. Please discuss if affected mines due to movement

from the project or even from project construction may have

negative effects on the environment and the operation of the mines.

Response:

Mountain Valley Pipeline plans to employ conventional construction methods on or in the

vicinity of all mines and quarries. Conventional construction techniques and trench depths

should have no negative effect on the environment or operation of the mines.










388


Request:


Section 6.3.2 (Table 6.C-1 Table 6.C-1 in Appendix 6-C.1 lists over oil and gas 800 wells

in Appendix 6-C.1) that come within .25 miles of the proposed project. The document

should discuss the environmental effects of going through or

around operating gas and oil wells. The Mountain Valley Pipeline

should discuss mitigation for broken gas lines, if PCB’s are found

in the gas wells, and other environmental impacts from the lines.

Response:

If oil and gas wells are located within Mountain Valley’s construction limits, Mountain Valley

will install the appropriate environmental and sedimentation controls and barriers to protect the

equipment. Mountain Valley Pipeline will require contractors to submit requests to the West

Virginia and Virginia one calls system every ten working days. In addition, Mountain Valley

Pipeline will dedicate a survey crew to locate any foreign lines. In the event of a line strike,

Mountain Valley Pipeline will notify the operator to make any needed repairs. Should PCB’s be

found in local gas wells or pipelines, Mountain Valley will implement the procedures outlined in

Resource Report 12.










389


Request:


Table 6.3-2 The text mentions that there are 347 wells within .25 miles of the project line but

the first column has 337 wells in West Virginia (WVGES). It should be clarified

the difference between the WVGES and WVDEP columns and why there is a

difference in total gas wells.

Response:

See the response to Resource Report 6, Request 6.










390


Request:


Page 6-14 The draft EIS should document or list all the oil pipelines that would be affected

by Mountain Valley Pipeline by company. It should indicate how Mountain

Valley Pipeline will avoid these lines or how it might affect them.

Response:

Foreign Pipelines, whether they contain oil, or natural gas, will be located during civil survey

and identified on alignment sheets where possible. Special operation qualified construction crews

will be equipped with utility locating devices such as radio detection cable and line locators to

precede all other work crews as to identify and visually examine known foreign lines. All

pipelines will be clearly identified with fluorescent markings to ensure high visibility. Mountain

Valley Pipeline will require its contractors to submit one call’s through both the West Virginia

and Virginia 811 system. One call tickets will be audited regularly by Mountain Valley Pipeline

and required renewal will be set to every 10 days.










391


Request:


Page 6-14 Mountain Valley Pipeline should explain how the project may interfere or interact

with coal mining in the area, this would include the active, permitted, or post-

mining reclamation. Would these activities affect the pipeline? It is unclear if the

project’s interaction with these coal mines (activity or inactivity) will have on the

environment.

Response:

Mountain Valley will follow all applicable construction and reclamation processes during

construction and reclamation while working in these areas. Through initial planning discussions,

Mountain Valley will minimize or completely negate all affect coal activities would have on the

pipeline.


Position: Landman








392


Request:


Page 6-24 “Significant karst formation” should be defined and differentiate the difference

between a significant and “non-significant” karst formation. Implications of karst

including to drinking water, pipe placement, compressor station siting and HDD

drilling should be evaluated in the draft EIS.

Response:

See the response to Resource Report 6, Request 18. Karst and Mountain Valley’s mitigation of

effects thereof are discussed at length in the resource reports, particularly Resource Reports 6

and 10, and in responses to data requests on those reports.










393


Request:


Page 6-29 Mountain Valley Pipeline should describe and quantify the habitat loss of this

cave. Additionally, according to figure K3 (Appendix 6D) it seems like the

project will transect Smokehole cave, Tawneys cave E2 and E3, and Johnsons

cave. Please describe how the operation and construction of the project will affect

these cave systems.

Response:

The Project area alignment does not transect Smokehole Cave, Tawneys Cave, or Johnsons

Cave. There is negligible risk for impact to the geology, hydrology, or recreational value of these

features from Mountain Valley Pipeline construction.










394


Request:


Page 6-37 It should be determined what the dangers exist from high gradient slopes.

Avoidance, mitigation and safety efforts in construction for all the dangerous

construction areas should be clearly investigated and explained in the EIS.

Response:

High gradient slopes require special construction methods to be performed safely due to gravity

and its effect on equipment, the people operating that equipment, and the material being moved

by the equipment. Types of incidents that can occur are vehicle roll-overs, equipment roll overs,

rolling debris, and material instability. Often times, steep slopes are paired with rocky terrain, or

a rocky sub-surface, which multiplies the potential of incidents and mechanical damage to the

pipeline.

Specialized equipment is used when constructing on these slopes, such as welding sleds, and

winch tractors which are utilized by attaching to working machinery for stability. All Winch hill

construction will be performed in compliance with OSHA standards. Each contractor will

develop a winch plan for winch hill construction to be reviewed and approved by Mountain

Valley Pipeline safety personnel prior to the start of construction on steep terrain.










395


Request:


Page 6-38 Blasting should be re-considered if it is in close proximity to a sensitive habitat.

Alternatives for rock removal should be evaluated.

Response:

As stated on page 6-38 of Resource Report 6:

Where unrippable subsurface rock is encountered, approved

alternative methods of excavation will be explored including: rock

trenching machines, rock saws, hydraulic rams, jack hammers, or

blasting. The alternative method to be used will be dependent on

the proximity to: structures, pipelines, wells, utilities, water

resources, etc., and the capabilities of the alternative excavation

method. Should blasting for ditch excavation be necessary, care

will be taken to prevent damage to underground structures (e.g.,

cables, conduits, and pipelines) or to springs, water wells, or other

water sources.










396


Request:


Page 6-40 Long term stability should be considered in all situations and slope monitoring

should not be a long-term solution in known failure areas. If long-term stability is

not considered or not a long term possibility, the route should be changed.

Additionally, a map or diagram should be provided of the known failure areas.

Response:

Mountain Valley Pipeline has completed the field reviews of the 26 areas listed in Table 6.4-6.

The results and recommendations from said reviews, including mitigation measures, are being

compiled. Mountain Valley expects to submit the results and recommendations by February 26,

2016.










397


Request:


Page 6-41 It should be described or a citation for another section should be recommended of

the environmental effects of rockfall and sediment on watersheds below the

slopes. Rockfall should be described to include the rate of falling rock in a year

and compared to other projects or research on the subject.

Response:

Rockfalls or debris from slides which enter waterbodies can have various effects. These may

include increased sedimentation, increased stream turbidity, increased water temperature,

decreased dissolved oxygen concentrations, modification of stream banks and vegetation,

alteration of flow patterns, harm to animal habitats, and increased erosion. The global effect on a

watershed is more difficult to define. This would depend on variables such as the size of the

affected stream and the time it remained impaired by the earthen movement event.

Rockfalls are described as “...abrupt movements of masses of geologic materials, such as rocks

and boulders, that become detached from steep slopes or cliffs (“Landslide Types and

Processes”, Fact Sheet, USGS, 2004).” By their nature, rockfalls are highly dependent on local

conditions, geology, and triggering mechanisms. Examples of triggering events include deep

excavations of rock, heavy precipitation or water infiltration events, and earthquakes. As such,

predictive measures tend to be applicable only to particular sites or regions, and little historic

data for rockfalls are available.










398


Request:


Page 6-42 Mountain Valley Pipeline should describe in more detail the effects of extra

equipment and space needed in constructing on severe slopes. In describing the

construction in slope areas greater than 35%, please describe what type of

equipment will anchor the winched equipment and how that equipment will

anchor into the ground. Sediment and erosion control should be described for

areas with high slope, during construction and operation. Safety of the project,

people, and the environment should be described so that the public better

understands the risks associated with building on severe slopes.

Response:

Additional work-space at the top and bottom of severe slops is required for this type of

construction were applicable. Additional access roads are also a necessity to reach staging points

to prohibits any unnecessary traveling of the right of way by hauling to the staging areas.

Multiple pieces of equipment will be joined together by winch lines from the hydraulic

controlled spools at the rear of the machine to the front blade or undercarriage of the next

machine. Each machine will be of equal or greater weight capacity; tie off points will be factory

mounts or certified welded and factory approved which will hold the cleaves and "D" rings

required for this operation. The winch cable itself will be of approved diameter to handle the

desired weight, and checked every day for wear or tear. Each piece of equipment will perform a

"dig in" which consists of digging the tracks into soil and creating a mound behind the machine

much like a nest. Every piece of equipment will have an on ground laborer to help with attaching

and detaching winch cables, and keeping an eye on operations from a safe location. Laborers will

be equipped with communication radios located in the equipment, and will also help equipment

operators with hand signals when needed. At the end of each day the final piece of equipment

will put in temporary water bars, which will divert any water to pre-build sumps with erosion

and sediment control to collect runoff. Every morning crews will perform a Job Safety Analysis

of the task they are to perform on the steep slope. Equipment will also be inspected prior to each

task performed.










399


Request:


Page 6-44 The draft EIS should provide a scale of seismic magnitude with the potential peak

ground acceleration. How much acceleration would a 6.0 magnitude earthquake

have on the pipelines? A 5.8 was seems pretty close to the threshold of the

pipeline.

Response:

Seismic data in relation to the Mountain Valley Pipeline Project is provided in Resource

Report 6.










400


Request:


General The third party Karst Specialists hired by Mountain Valley Pipeline should have a

standard operating procedure to communicate and notify Virginia Department of

Conservation and Recreation, Karst Protection; West Virginia Department of

Environmental Protection if they find potential of a sinkhole or other geological

hazard.

Response:

The role of the Karst Specialist Team deployed by Mountain Valley Pipeline prior to, and during

construction, is to assist in limiting potential negative impacts to existing karst features, and to

inspect, assess and if necessary mitigate new karst features that are encountered or form during

construction in conjunction with recommendations from the appropriate state agency (Virginia

Department of Conservation and Recreation, Karst Protection; West Virginia Department of

Environmental Protection).

The Karst Mitigation Plan (Appendix 6-D.2, Resource Report 6) specifies the standard operating

procedure to communicate and notify the appropriate agency if a new karst feature and/or

hazards is observed prior to or during construction.

As part of the standard procedures for karst specialists, Mountain Valley Pipeline will

correspond with the Virginia Department of Conservation and Recreation when unanticipated

karst features are uncovered during construction.










401


Request:


Page 6-49 Mountain Valley Pipeline should discuss habitat loss or recreational loss when

building through Canoe Cave. Included in the description of factors why it was

not able to be avoided.

Response:

See the response to Resource Report 6, Request 1.










402


Request:


Section 7.3.1 There should be a calculation of the area/volume of disturbed soil from the project

and an estimate of how much soil area/volume will be restored. Mountain Valley

Pipeline should discuss the effectiveness of soil restoration techniques to reduce

compaction and bring function back to pre-construction use.

Response:











403


Request:


Page 7-16 List the state or local soil guidelines/regulations that the project needs to abide.

Response:

Any guidelines or regulations would be included in the permit requirements. A list of the permits

required for the project is included in Table 1.7-1.










404


Request:


Page 7-19 The document should cite or describe the number of acres that will have soil

compaction in the body of the document. The document should describe how 80

acres was calculated. Is this acreage of total construction impact from the

project?

Response:

Section 7.3.1.3 states that Based on the particle size, soil description of the various soil types

presented by milepost in Appendices 7-A1 and 7-A2, it is expected that approximately 80 percent

of the pipeline route could see some evidence of compaction.

Mountain Valley expects to submit to FERC a table with the percentage of compacted soil by

project component by January 22, 2016. See the response to Resource Report 7, Request 2.










405


Request:


Page 7-21 Is the SPCC required by FERC? How does the SPCC coordinate with the local

community?

Response:

An SPCC Plan will be submitted to FERC and the West Virginia Department of Environmental

Protection and the Virginia Department of Environmental Quality offices as part of the NPDES

permit applications. Mountain Valley expects to submit the SPCC Plan to FERC by February 26,

2016.










406


Request:


Section 8.3.2 What is the use for all these resources. The document should state the number and

the type of use for each resource. Also, the document should state if this includes

recreational use and/or transportation use.

Response:

The resources discussed in Section 8.3.2 include private recreational and special use areas and

lands enrolled in USDA programs managed through Natural Resources Conservation Service

and the Farm Service Agency.










407


Request:


Page 8-10 A description of the contractor yards should be provided, for construction and use,

including vegetation removal, compaction, sediment and erosion control, paving

material, spill prevention methods, How will runoff and ground infiltration be

affected?

Response:

Mountain Valley Pipeline will use contractor yards during construction to stage construction

operations, store materials, park equipment, and set up temporary construction offices.

Depending upon the condition of these yards and their current use, some surface grading,

drainage improvements, placement of surface materials (e.g., crushed rock), and internal

roadways may be required. Upon completion of construction, all temporary facilities will be

removed and the site will be re-vegetated, permanent erosion control measures will be installed,

and temporary erosion control measures will be removed. Where needed for erosion control,

measures outlined in the FERC Plan and Procedures and Mountain Valley Pipeline’s E&SCP

will be implemented. BMPs will be properly maintained throughout construction and will remain

in place until permanent erosion controls are installed or restoration is completed.

A description of contractor yards is provided in Section 1.3.5 of Resource Report 1 and

Section 8.1.1.5 of Resource Report 8. Restoration of contractor yards is addressed in

Section 1.4.3.4 of Resource Report 1.










408


Request:


Page 8-12 The document should mention and locate the historical agricultural land affected

by the occupation of the pipeline its construction or cite the section where it can

be located.

Response:

The West Virginia Association of Conservation Districts established the Century Farm Program

in 2011. To qualify, ownership must be kept in the same family for at least 100 years, farms must

consist of at least ten acres of the original tract, and the current owner must generate at least

$1,000 annually from farm products. Information on Century Farms or other historical

agricultural land in West Virginia is not publicly available, nor is any information on historical

agricultural lands in Virginia; however, the discussion of impacts and mitigation regarding

agricultural land potentially impacted by the Project in Section 8.1.3.1 of Resource Report 8

would apply to all agricultural lands in the Project area, including any historical agricultural

lands.

As discussed in Section 8.1.3.1, impacts from construction through agricultural lands will be

limited to the growing season during which construction occurs. Mountain Valley Pipeline will

maintain landowner access to fields, storage areas, structures, and other agricultural facilities

during construction and will maintain irrigation and drainage systems that cross the right-of-way

to the extent practicable. Mountain Valley Pipeline will protect active pasture land during

construction through the installation of temporary fencing, the use of alternative locations for

livestock to cross the construction right-of-way, and/or alternate feeding arrangements, as

negotiated with the landowner.

Following construction, impacted agricultural land will be restored to pre-construction

conditions in accordance with the FERC Plan, and any specific requirements identified by

landowners, or state or federal agencies with regulatory jurisdiction over or interest in

agricultural land. Agricultural land affected by the construction right-of-way and ATWS would

be allowed to revert to prior use, with the exception of tree crops within the permanent right-of-

way. Mountain Valley Pipeline will work with landowners to understand post-construction land

use activity and the construction would be designed in order to allow use of the easement for

farming activity and to identify specific areas where heavy machinery could cross the easement

without damaging the pipeline.






409










410


Request:


Page 8-24 The draft EIS should mention what is the usage in the areas of crossing for the

Blue Ridge Parkway and the Appalachian Trail. Recreational vehicles and

tourism. The time period they will affect those resources. Will construction affect

operation of those resources as well.

Response:

Current land use at the planned crossing locations of the Blue Ridge Parkway and the

Appalachian National Scenic Trail is discussed in Sections 8.3.1 and 8.4.3 of Resource Report 8.

Impacts to recreation and tourism in the Project Area is discussed in Section 5.3.2.3 of Resource

Report 5.

Mountain Valley Pipeline continues to consult with the NPS, USFS and ATC with regards

potential impacts and mitigation strategies for the proposed crossing of the Jefferson National

Forest and the Appalachian National Scenic Trail.










411


Request:


Page 8-27 The draft EIS should describe if the project will effect Pig Cave, how significant

effects will be. The document should also describe the cave and if there are any

inhabitants in the cave.

Response:

The Project area alignment is approximately 1,900 feet southwest and downgradient

topographically from the Pig Hole Cave. Based on this relative position with respect to the

Mountain Valley Pipeline alignment, there is negligible risk for impact to the geology,

hydrology, or recreational value of these features from Mountain Valley Pipeline construction.










412


Request:


Section 8.3.3 The document should discuss if leaking underground storage take cases were

included in the analysis for hazardous waste sites close to the pipeline. This

section should also mention if there were any Superfund (CERCLA) sites were

within the .5 mile. If none were found, it should mention this.

Response:

Mountain Valley performed a CERCLA database search during the routing process, which

included a search for underground storage tanks. None were identified.










413


Request:


Page 8-35 The sentence “Due to screening and lack of contrast there would be no visual

impacts to the WMA,” should be clarified for the reader and explain in more

detail. The height of the screens, what the screens will look like, and why the

lack of contrast does not impair visual resources should also be described.

Response:











414


Request:


General Analysis of direct, secondary and cumulative impacts is important for the EIS.

This should include emissions associated with compressor stations, pipeline

construction, operation and emergency scenarios. Cumulative impacts should first

select a reasonable area/airshed for analysis to balance local sources and

contributions that move into or from the study area. Cumulative impacts can

include emissions in the airshed from the project as well as other activities.

Response:

A summary of (past, present and reasonably foreseeable future) activities in the counties for the

proposed compressor stations was included in Table 9.1-14. This included all currently proposed

activities (i.e., includes those unrelated to the project) in the area from air permit applications

from the West Virginia Department of Environmental Protection, as well as the proposed

emission increases and distance to the nearest proposed facility. In all instances, the emission

increases are minor sources (i.e., below 100 tons per year of all regulated pollutants). As such,

WVDEP ensures that air quality will be maintained through its minor source permitting program

and monitoring network.










415


Request:


Table 9.1-14 Table 9.1-14 lists potential other projects that will be near the Mountain Valley

Pipeline stations. If ACP is co-located, will there be any stations from ACP close

to Mountain Valley Pipeline?

Response:

Mountain Valley is unaware of any additional potential projects not previously reported or

referenced within the application filing. By definition, if ACP is co-located, there would be ACP

stations close by.










416


Request:


General Alternatives should include a discussion of other solutions to satisfy the needs

presented in the Purpose and Need. Other solutions to energy demand can be

referenced and if dismissed, explanation should be provided. Alternative locations

for the project that would meet need should be presented. This can be corridor

wide or options which would avoid natural or community resources. Evaluation of

a range of alternatives is a keystone of the project and environmental analysis.

Response:

Resource Report 10 includes evaluation of a range of alternatives, including no action, energy

alternatives, system alternatives, and pipeline route alternatives and variations. See

Sections 10.2 through 10.6.










417


Request:


Page 10-5 It should be listed and discussed if any energy generation projects (such as

nuclear, solar, wind or coal) are alternatives to or being built within the regional

markets that this natural gas pipeline will serve.

Response:

A discussion of energy alternatives such as nuclear, solar, wind, and coal, can be found in

section 10.3 of Resource Report 10.










418


Request:


Page 10-6 It would be helpful to visually understand the connecting lines for the project.

This should include the Columbia system.

Response:

Maps for FERC-jurisdictional interstate natural gas pipelines, including Transco, Columbia, and

Equitrans, are publicly-available in their respective tariffs, on their informational postings

websites, or both.










419


Request:


Page 11-11 From the chart, there was a spike in fatalities in 2000 and 2010. These two

incidents should be described and include the reasons for the accidents and any

major environmental effects.

Response:

Ten fatalities in 2000 were due to a single incident along the Pecos River near Carlsbad, NM.

The cause of the incident was ruled as internal corrosion. The line that ruptured never had an in-

line-inspection prior to the rupture so the internal corrosion was not detected. Mountain Valley

is being designed to allow in-line inspections to be performed as per DOT requirements (see

11.3.1.2). 2010 was the year that PG&E had an incident in San Bruno that resulted in eight

fatalities. The rupture was caused by an undetected manufacturing defect. The line, as in New

Mexico, was not inspected with an internal inspection tool.










420

U.S. Army Corps of Engineers Comments on the Application

Request:

A complete wetland delineation package must be submitted to the Corps of Engineers for

confirmation.

Response:

Mountain Valley expects to submit the complete wetland delineation packages to the Corps of

Engineers with the Nationwide 12 application process by February 26, 2016.










421


Request:

Was LIDAR utilized for the inaccessible portions of the Virginia pipeline corridor? If so please

provide this data with the wetland delineation package. Please provide a map in the wetland

delineation package depicting all wetlands along the route calling out those areas that were

ground truthed, and all areas the Corps has completed a site visit.

Response:

LIDAR was used for the inaccessible portion of the Virginia and West Virginia pipeline corridor.

This information will be submitted to the Corps of Engineers with the Nationwide 12 application

process, which Mountain Valley expects to submit by February 26, 2016. Additionally, infrared

analysis was utilized to augment evaluation and delineation of streams, waterbodies, and

wetlands where access was not available.










422


Request:

All converted/restored wetlands will have a pre and post construction report.

Response:

Mountain Valley agrees with this statement.










423


Request:

All converted/restored wetlands will have a 5 year monitoring period with yearly reports due to

the Corps.

Response:

Mountain Valley Pipeline will conduct all wetland monitoring in compliance with the FERC

Wetland and Waterbody Construction & Mitigation Procedures. In accordance with FERC

Procedures, Mountain Valley Pipeline will monitor and record the success of conversion wetland

revegetation annually until wetland revegetation is successful. Wetland revegetation shall be

considered successful when it meets the criteria set forth in section VI.D.5. Within 3 years after

construction, Mountain Valley Pipeline will file a report with the Commission identifying the

status of the wetland revegetation efforts and documenting success. For any wetland where

revegetation is not successful at the end of 3 years after construction, Mountain Valley Pipeline

will develop and implement a remedial revegetation plan to actively revegetate wetlands.

Mountain Valley Pipeline will continue revegetation efforts and file a report annually

documenting progress in these wetlands until wetland revegetation is successful.










424


Request:

All stream channels impacted and restored to pre-project contours will have a 5 year monitoring

period with yearly reports due to the Corps.

Response:

Mountain Valley Pipeline will conduct all stream monitoring in compliance with the FERC

Wetland and Waterbody Construction & Mitigation Procedures and USACE permit closure

conditions. In accordance with section V.C.3 of the FERC Procedures, Mountain Valley Pipeline

will return all waterbody banks to preconstruction contours or to stable angle of repose as

approved by the Environmental Inspector. An environmental inspector will be required to

monitor stream stabilization weekly until sign off has been received from the applicable

agencies.










425


Request:

Applicant needs to differentiate between permanent, temporary and conversion impacts to waters

of the U.S. to be included in their permit submittal to the Corps.

Response:

Permanent, temporary and conversion impacts to waters of the U.S. will be clearly defined in the

Nationwide 12 Preconstruction Notification submittal to the Corps and the FERC. Mountain

Valley expects to submit this by February 26, 2016.










426


Request:

List alternatives for wet crossings in waters of the U.S. for the state of Virginia.

Response:

Alternatives for wet crossing in water in Virginia are currently being evaluated in Virginia. The

crossing method re-evaluation will be completed on available tracts. Mountain Valley expects to

resubmit any changes to FERC by February 26, 2016.










427


Request:

Table 2.2-5 has water body width and length of crossing. Please explain the difference in these

numbers as the table would indicate that the crossing is greatly different from the water body

length.

Response:

Mountain Valley will submit an updated waterbody table to the Corps as part of its Nationwide

permit application, which Mountain Valley expects to submit by February 26, 2016.










428


Request:

Appendix 2-A refers to an artificial path with regard to a waters of the U.S. Please define this

term.

Response:

An artificial path is a channelized portion of a natural stream or river.










429


Request:

Impact at or near MP 299.4, please provide an alternatives analysis that justifies this large impact

to PFO wetlands.

Response:

While impacts are anticipated to PEM Wetlands W-H2 and W-H3 at mile post 299.4, the impacts

will be temporary in nature. Due to residences, additional streams, and a very large pond to the

west, and densely forested areas which would have to be cleared just east of the proposed route,

Mountain Valley Pipeline will not be able to avoid temporary impacts to the wetland. The

wetland will be restored and allowed to revegetate to pre-construction conditions.










430


Request:

Impact at or near MP 300.7, please provide an alternatives analysis that justifies this large impact

to PFO wetlands.

Response:

During field reviews, the tract of clear cut land directly northwest of 300.7 was a restricted

access area. The original proposed route dissected this tract of land. Upon surveying further

north, several additional PFO wetlands were discovered in addition to a significant cultural find,

both of which deterred the original route. The route was then adjusted west to dissect the existing

pipeline right-of-way and parallel said right-of-way into Transco station, as to co-locate.

Multiple existing lines were located in this corridor which prohibited Mountain Valley Pipeline

from encroaching south east into said right of way. This created an additional right of way to be

designed paralleling existing easements. Options were analyzed to cross the multiple lines twice

and traverse on the south side for a distance. The following obstacles prohibited this option;

drainage from an existing pond that construction activities could possibly undermine the pond

wall, the other being new construction or expansion of the existing station. Another concern is

the escalated danger of crossing the multitude of pressurized lines twice. In conjunction with the

desired wetland specifications Mountain Valley Pipeline reduced work space width to 75’

through the subject area to help reduce impact to wetland, there is also additional work space

outside of the wetland limits to allow for segregating soils.










431


Request:

Impact between MP 256.3 and 256.9, please provide an alternatives analysis that justifies this

large impact to waters of the U.S.

Response:

Between mileposts 256.3 and 256.9, lands that lie to the south east of the proposed line on the

opposite side of the forested stream have been determined to be extreme slope and deemed not

suitable for construction. The following structures also played a factor to the north east

including: a century farm house which housed an art studio providing classes, a large church

across route 919 (Grassy hill road), and a barn being used for goat farming. Mountain Valley

Pipeline designed the limits of disturbance in this area to be greater than or equal to the 15’

minimum offset required in specifications of paralleling existing stream bodies. This section is

currently in agriculture use and will require no tree clearing and minimal grading. Mountain

Valley Pipeline will also abide by erosion and sedimentation control as outlined in the FERC

Plan and Procedures as well as the Project-specific erosion and sedimentation control plan.










432

West Virginia Division of Natural Resources Comments on the Application

Request:


Table 2-A-2 Waterbodies Crossed by the Mountain Valley Pipeline Project – Summary Impact

Type

The “Classification” column seems incompletely populated with information, for example,

portions of North Fork Fishing Creek are stocked with trout, Little Kanawha River also has

portions stocked with trout and is classed as a protected mussel stream.

Response:

Mountain Valley expects to submit an updated Table 2-A-2 by February 26, 2016.










433


Request:



Type

The “Fishery Type” column also seems incompletely populated with information, for example

the definition of WW, CW, and M are not identified in the notes. In addition, there is no B or B1

designation as outlined under 47CSR2.

Response:











434


Request:



Type

There are no species identified in the “Fish Species” column for any stream in West Virginia. Is

this column necessary in this Table?

Response:











435


Request:



Type

Time of year restrictions are incorrect as presented in the table even though the notes (f) identify

restrictions as outlined in USACE 401 Water Quality Certification. Spawning season dates for

West Virginia State 401 Water Quality Certification Conditions for Nationwide Permits are

April-June for warm water streams and September 15 - March 31 for trout waters and adjacent

tributaries. If stream work cannot be avoided during these dates, for the respective stream

designation, WRS requests that the impacts be evaluated to aid in our determination to grant or

deny a spawning season waiver.

Response:











436


Request:


Section 3.1.3.2 State Fisheries of Special Concern – Freshwater Mussels.

In the first sentence of the section, seventeen streams are identified as mussel streams, later in the

section there is reference to eighteen potential mussel streams. The correct number should be

reported.

Response:

Seventeen mussel streams in WV are crossed by the Project a total of 18 times (one stream is

crossed twice). Instead of stating 18 potential mussel streams, the sentence should have been

written: “Of the 18 crossings of potential mussel streams by the Project’s centerline within the

state…”










437


Request:


In previous correspondence filed with FERC, WVDNR, WRS specifically recommended

coordination with the District Wildlife Biologists concerning access, construction, maintenance

and potential mitigation for impacts of the pipeline, access roads, staging areas, ATWS, etc. to

WMAs in West Virginia. This would include a seed mix recommendation for our WMAs which

was not addressed in section 3.2.11. The coordination with Wildlife Habitat Council for use of

native plant species during restoration is appreciated, but should also be coordinated with the

District Biologists for use on WMAs. Additional consultation with WRS Wildlife Biologists

will be necessary.

Response:

In previous correspondence filed with FERC, WVDNR, WRS specifically recommended

coordination with the District Wildlife Biologists concerning access, construction, maintenance

and potential mitigation for impacts of the pipeline, access roads, staging areas, ATWS, etc. to

WMAs in West Virginia. This would include a seed mix recommendation for our WMAs which

was not addressed in section 3.2.11. The coordination with Wildlife Habitat Council for use of

native plant species during restoration is appreciated, but should also be coordinated with the

District Biologists for use on WMAs. Additional consultation with WRS Wildlife Biologists

will be necessary.

The proposed seed mixtures to be utilized on the Mountain Valley Pipeline Project were sent to

Bob Knight, Cliff Brown, Todd Dowdy, and Rob Silvester of the West Virginia Division of

Natural Resources on December 1, 2015. A response was received from Rob Silvester on

December 16, 2015 requesting that some of the proposed seed mixtures be adjusted for Wild Life

Management Areas in West Virginia Districts 1 and 3. Seed mixtures will be altered in the area

of Burnsville Wildlife Management Area as necessary to comply with Mr. Silvester’s

recommendations and additional consultation will occur with the District Biologists as necessary

prior to, during, and post construction.










438


Request:


Table 8.3-1 Federal, State, Recreation and Conservation Lands Crossed by or Located within

1.25 mile of the Proposed Mountain Valley Pipeline Project

Meadow River WMA in Greenbrier County, WV is noted to have no pipeline crossing, but 0.30

acres of impact and the Crossing Method/Special Construction Measures is identified as “Open

Cut”, this should be clarified.

Response:

As stated in Section 8.3.1.1 of Resource Report 8, the proposed route is located more than 1.0

mile from the Meadow River Wildlife Management Area (WMA) at MP 156.0; however, a

laydown yard (PY-003) would impact 0.28 acre of this WMA during operation. The pipeline

would have little visual impacts on this WMA due to the distance from the WMA, high relief

terrain, and dense forest vegetation between the WMA and the pipeline, and it is assumed that

views of the pipeline would be screened. No impacts are expected during operation of the

Project.





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