FERC Issues Assessment on Mountain Valley Pipeline Changes

Project changes could be coming to the Mountain Valley Pipeline in Greenbrier County after a public comment period ends on September 13.

According to an application filed with the Federal Energy Regulatory Commission (FERC) in February, Mountain Valley Pipeline is seeking the ability “to change the crossing method for specific wetlands and waterbodies yet to be cross by the project from the open-cut crossings to one of several trenchless methods.”

“Mountain Valley requests authorization for two minor route adjustments to avoid wetlands and waterbodies and authorization to conduct nighttime construction at eight trenchless crossings,” reads an assessment issued by FERC. “Specifically, Mountain Valley proposes to use trenchless methods at 120 locations to cross 183 waterbodies and wetlands that the Commission originally authorized as open-cut dry crossings.”

Seeking to compliment FERC’s June 23, 2017 Final Environmental Impact Statement for the Mountain Valley Pipeline Project, FERC staff concluded “that the approval of the proposed project, with appropriate mitigating measures, would not constitute a major federal action significantly affecting the quality of the human environment.”

Although many factors were considered during the environmental review, the principal reasons for these conclusions are:

– proposed trenchless crossings would avoid and/or minimize impacts on wetlands and waterbodies as compared to the open-cut crossings originally authorized for the Mountain Valley Pipeline Project.

– the FERC Staff is recommending a condition for Mountain Valley to monitor nighttime construction noise for compliance with our noise criteria.

– Mountain Valley would minimize impacts on natural and cultural resources during the proposed trenchless crossings by implementing Mountain Valley’s Erosion and Sediment Control Plan; FERC Upland Erosion Control, Revegetation, and Maintenance Plan; and Mountain Valley’s Wetland and Waterbody Construction and Mitigation Procedures.

– Mountain Valley would comply with all applicable federal requirements.

– the FERC staff would complete the process of complying with section 7 of the Endangered Species Act prior to approving construction of the proposed trenchless crossings.

– the project complies with Section 106 of the National Historic Preservation Act.

– Mountain Valley’s environmental inspection program and FERC staff’s third-party monitoring oversight program would be implemented to ensure compliance with the mitigation measures that become conditions of the FERC authorization.

In March, FERC began asking the public for feedback on potential changes to the project. The initial comment period resulted in ample feedback, including 398 discrete comments from individuals, environmental non-profit groups, and an industry group. In addition, the commission received 1,092 form letters from individuals.

Some of the feedback from the public hopes the project will do the following before construction continues:

– “address the need for the Mountain Valley Pipeline Project and associated amendments and express opposition to fossil fuels in favor of renewable energy;

– “request that a Supplemental Environmental Impact Statement be prepared for the Amendment Project;

– “request a performance bond for completion of the Project or restoration if the Project is canceled or abandoned;

– “address the potential for community spread of COVID-19 by construction workers;

– “request that the Commission not issue a Certificate for the Amendment Project until Mountain Valley obtains all permits necessary for completion of the entire Mountain Valley Pipeline Project.”

In Greenbrier County, “the Direct Pipe® crossing of the Greenbrier River is estimated to require about 103 days total for pit excavation and boring. As stated above, the actual duration could increase to some extent by weather delays or slow boring rates due to unexpectedly hard rock or changing geological makeup that may necessitate equipment change-outs.”

What is a Direct Pipe crossing? The assessment explains they are “completed using an articulated, steerable micro-tunnel boring machine (MTBM) mounted on the leading end of the pipe or casing. … The pipeline is pre-fabricated and welded in sections to the back of subsequent sections as the MTBM advances. Because the product pipe is attached to and advances with the MTBM, like microtunneling, it benefits from a continuously supported hole during the drilling process, and allows for the product pipe to be installed in varying formations such as boulders and rock.”

North of Rainelle
Near Pence Springs

The assessment also notes the process by which water table disturbances would be handled.

“In the event of landowner complaints that nearby wells or springs are impacted by the dewatering activities, Mountain Valley would evaluate any complaints and identify a suitable solution with the landowner. If it is determined by Mountain Valley through the use of qualified groundwater and surface water scientists and engineers that suitable potable water is no longer available due to construction related activities, Mountain Valley would provide adequate quantities of potable water during repair or replacement of the damaged water supply.”

Those looking to comment on the process before it continues can do so.

“The [environmental assessment] is not a decision document. It presents Commission staff’s independent analysis of the environmental issues for the Commission to consider when addressing the merits of all issues in this proceeding. Any person wishing to comment on the EA may do so. … To ensure that the Commission has the opportunity to consider your comments prior to making its decision on this project, it is important that we receive your comments in Washington, DC on or before 5 p.m. Eastern Time on September 13, 2021. For your convenience, there are three methods you can use to file your comments to the Commission. The Commission encourages electronic filing of comments and has staff available to assist you at 866-208-3676 or FercOnlineSupport@ferc.gov.”

The environmental assessment also includes an overall update on the project:

“The authorized Mountain Valley Pipeline Project facilities consist of approximately 304 miles of new natural gas pipeline and multiple above ground facilities in West Virginia and Virginia.

“Mountain Valley was authorized to begin construction of the Mountain Valley Pipeline Project in January 2018. … By the end of 2018, about 88 percent of the construction right-of-way for the Mountain Valley Pipeline Project had been cleared. … Since that date, Mountain Valley has installed and backfilled approximately 81 percent of the pipeline, and more than 52 percent of the project right-of-way has been fully restored.

“According to the most recent Mountain Valley Pipeline Project weekly construction report from the reporting period of July 24, 2021, to July 30, 2021, the construction completeness of the pipeline right-of-way for all spreads is approximately 100 percent for tree felling, 95 percent for vegetation clearing, 95 percent for upland right-of-way-preparation, and 90 to 94 percent for trenching, stringing, welding, and coating and wrapping.

“According to the status report, approximately 81 percent of the right-of-way has been backfilled and approximately 52 percent is in the final restoration stage. Mountain Valley states that at areas of waterbody crossings, trees were cleared but a 50-foot riparian buffer of other vegetation was maintained. These areas currently consist of tree stumps along with scrub-shrub and herbaceous vegetation.

“Due to permitting challenges, Mountain Valley has not been able to complete construction. Mountain Valley has subsequently engaged in a comprehensive analysis of each remaining aquatic feature proposed to be crossed. … Approximately 460 streams and 183 wetlands remain to be crossed.”


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