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.
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625 Liberty Avenue, Suite 1700 | Pittsburgh, PA 15222
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.
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
82
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
83
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
84
demonstrated that construction activities mobilized sediments to the extent that the filters were
impacted.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
85
Federal Energy Regulatory Commission
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
86
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Senior Environmental Coordinator
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
87
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640Date: January 15, 2016
Senior Environmental Coordinator
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
88
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
89
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
90
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
91
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
92
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
93
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
94
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
95
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
96
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
97
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
98
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
99
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
100
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
101
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
102
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
Wetlands
42. Clarify the meaning of “Not Reported” wetland acreages in table 2.3-1.
Response:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
103
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
104
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
105
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
106
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
107
Federal Energy Regulatory Commission
Request:
Resource Report 2 – Water Use and Quality
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
108
Federal Energy Regulatory Commission
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
by February 26, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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
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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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
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Dated December 24, 2015
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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
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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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Docket No. CP16-10-000
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Dated December 24, 2015
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
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Dated December 24, 2015
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
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Forest impacts and avoidance and minimization measures for bats will be addressed in the
Biological Assessment, which will be provided to USFWS.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Docket No. CP16-10-000
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Dated December 24, 2015
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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:
See Attachment RR3-18.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Docket No. CP16-10-000
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Dated December 24, 2015
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
Endangered, Threatened, and Special Concern Species
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Docket No. CP16-10-000
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
Endangered, Threatened, and Special Concern Species
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
Request:
Resource Report 3 – Fisheries, Vegetation and Wildlife
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
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Federal Energy Regulatory Commission
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
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Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
135
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Mountain Valley Pipeline, LLC
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Responses to Environmental Information Request
Dated December 24, 2015
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
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
137
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Mountain Valley Pipeline, LLC
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Dated December 24, 2015
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Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
139
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Mountain Valley Pipeline, LLC
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Responses to Environmental Information Request
Dated December 24, 2015
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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.
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
141
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
142
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
143
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
144
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
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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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
146
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
147
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
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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
317 No None. The Project should not be visible due to intervening vegetation.
035-0412-0241
House (Greek Rev)
112 Smith Brothers Rd, Newport, VA 24128
387 No None. The Project should not be visible due to intervening vegetation.
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.
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Dated December 24, 2015
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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
035-0412-0043 774 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
035-0412-0046 734 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
035-0412-0051 639 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
035-0412-0057 606 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
035-0412-0059 528 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
035-0412-0060 512 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
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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
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
151
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
152
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
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Responses to Environmental Information Request
Dated December 24, 2015
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Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
154
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
155
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
156
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.”
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
157
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.”
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
158
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
159
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
160
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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,
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
176
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
177
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
178
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
179
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
180
Federal Energy Regulatory Commission
Request:
Resource Report 4 – Cultural Resources
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
181
Federal Energy Regulatory Commission
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
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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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
183
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
184
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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
Mountain Valley Pipeline, LLC
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Dated December 24, 2015
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
Mountain Valley Pipeline, LLC
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Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
186
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
187
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
188
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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).
Mountain Valley Pipeline, LLC
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Dated December 24, 2015
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.
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Table 5.3-2 (updated)
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.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
191
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
192
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
193
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
194
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
195
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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
Phone Number: 412-395-3931
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
196
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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.
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
197
Response:
Mountain Valley expects to submit a response by February 26, 2016.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
198
Federal Energy Regulatory Commission
Request:
Resource Report 5 – Socioeconomics
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.
Respondent: Shawn Posey
Position: Senior Vice President - Construction and Engineering
Phone Number: 412-395-3931
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
199
Federal Energy Regulatory Commission
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
200
Federal Energy Regulatory Commission
Request:
Resource Report 6 – Geologic Resources
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.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
201
Federal Energy Regulatory Commission
Request:
Resource Report 6 – Geologic Resources
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
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.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
266
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Shawn Posey
Position: Senior Vice President - Construction and Engineering
Phone Number: 412-395-3931
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
267
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
268
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
269
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
270
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
271
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
272
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
273
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
274
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
275
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
276
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
Appendix 8-B – Site Specific Residential Construction and Mitigation Plans
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.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
277
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
Appendix 8-B – Site Specific Residential Construction and Mitigation Plans
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:
Mountain Valley expects to submit a response by February 26, 2016.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
278
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
Appendix 8-B – Site Specific Residential Construction and Mitigation Plans
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.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
279
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
Appendix 8-B – Site Specific Residential Construction and Mitigation Plans
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
280
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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:
Mountain Valley expects to submit a response by February 26, 2016.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
281
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
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:
Mountain Valley expects to submit a response by February 26, 2016.
Respondent: Kevin Wagner
Position: Land Director
Phone Number: 304-627-6431
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
282
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
Appendix 8-F – Visual Simulations
30. Provide a visual simulation of the communication towers from nearby roads, points of
interest, and residences.
Response:
Mountain Valley expects to provide a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
283
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
Appendix 8-F – Visual Simulations
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
284
Federal Energy Regulatory Commission
Request:
Resource Report 8 – Land Use, Recreation and Aesthetics
Appendix 8-F – Visual Simulations
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.
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
285
Federal Energy Regulatory Commission
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
286
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
287
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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).
Mountain Valley Pipeline, LLC
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Docket No. CP16-10-000
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Dated December 24, 2015
288
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
289
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
290
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
291
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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
Mountain Valley Pipeline, LLC
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Docket No. CP16-10-000
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Dated December 24, 2015
292
6 2755 ESE 51.9 42.8 52.4 0.5
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
293
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
294
Mountain Valley expects to file this information by February 26, 2016.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
295
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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
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.
Mountain Valley Pipeline, LLC
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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
Mountain Valley Pipeline, LLC
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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.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
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
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
299
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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
Mountain Valley Pipeline, LLC
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Dated December 24, 2015
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).
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
301
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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.
Respondent: Ricky Myers
Position: Engineering Manager
Phone Number: 724-873-3640
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
302
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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
Respondent: John Uhrin
Position: Construction Director
Phone Number: 724-873-3497
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
303
Federal Energy Regulatory Commission
Request:
Resource Report 9 – Air Quality and Noise
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.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
304
Federal Energy Regulatory Commission
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.
Respondent: Shawn Posey
Position: Senior Vice President - Construction and Engineering
Phone Number: 412-395-3931
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
305
Federal Energy Regulatory Commission
Request:
Resource Report 10 – Alternatives
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.
Respondent: Shawn Posey
Position: Senior Vice President - Construction and Engineering
Phone Number: 412-395-3931
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
306
Federal Energy Regulatory Commission
Request:
Resource Report 10 – Alternatives
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:
Mountain Valley expects to submit a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
307
Federal Energy Regulatory Commission
Request:
Resource Report 10 – Alternatives
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:
Mountain Valley expects to provide a response by January 22, 2016.
Respondent: Megan Neylon
Position: Senior Environmental Coordinator
Phone Number: 724-873-3645
Date: January 15, 2016
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
308
Federal Energy Regulatory Commission
Request:
Resource Report 10 – Alternatives
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.
Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000
Responses to Environmental Information Request
Dated December 24, 2015
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: